expenses); and Alaska Village, Inc. v. Smalley, 720 P.2d 945, 950 (Alaska 1986) (past medical expenses). In the award of damages for medical expenses, the Alaska courts usually have referred to or Saslow, 395 P.2d at 42; Nesbett, “costs” “expenses,” 432 P.2d at 615 n. 18; Schreiner, 502 P.2d at 145. The Alaska Supreme Court has held that the proper measure is the reasonable value of medical services even in cases where medical expenses are actually paid by a collateral source. See Aydltett, 511 P.2d at 1313-15. Generally, a parent has the primary right of action for past medical expenses incurred on behalf of an unemancipated minor. However, a parent may waive the right to recover by failing to object in the event the injured child sues for those expenses, or by testifying on the child’s behalf when the child is suing for those expenses. Smalley, 720 P.2d at 950. AS 09.17.040(a) dictates that the verdicts in personal injury shall be itemized between past and future economic and non-economic losses. Medical expenses constitute an economic loss.
expenses); and Alaska Village, Inc. v. Smalley, 720 P.2d 945, 950 (Alaska 1986) (past medical expenses). In the award of damages for medical expenses, the Alaska courts usually have referred to “costs” or “expenses,” Saslow, 395 P.2d at 42; Nesbett, 432 P.2d at 615 n. 18; Schreiner, 502 P.2d at 145. The Alaska Supreme Court has held that the proper measure is the reasonable value of medical services even in cases where medical expenses are actually paid by a collateral source. See Aydltett, 511 P.2d at 1313-15. Generally, a parent has the primary right of action for past medical expenses incurred on behalf of an unemancipated minor. However, a parent may waive the right to recover by failing to object in the event the injured child sues for those expenses, or by testifying on the child’s behalf when the child is suing for those expenses. Smalley, 720 P.2d at 950. AS 09.17.040(a) dictates that the verdicts in personal injury shall be itemized between past and future economic and non-economic losses. Medical expenses constitute an economic loss.
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