Coyne v. Campbell

On July 5, 1957 plaintiff sustained a whiplash injury when his automobile was struck in the rear by a motor vehicle driven by defendant. Inasmuch as plaintiff is a practicing physician and surgeon, he received medical treatment, physiotherapy and care from his professional colleagues and his nurse, and incurred no out-of-pocket expenses therefor. Nevertheless, in his bill of particulars, he stated that his special damages for medical and nursing care and treatment amounted to $2,235. The trial court ruled that the value of these services was not a proper item of special damages, and that no…