Johnson v. Dallas County
Connie A. Johnson appealed the trial court's judgments regarding her worker's compensation claim against Dallas County. Johnson, injured in 1988, initially settled with the County and also secured an award from the Texas Worker's Compensation Commission for medical expenses. The County later challenged this award, arguing it had already paid medical expenses through its self-funded health insurance plan, thus precluding a double recovery for Johnson. Johnson contended the collateral source rule prevented the County from taking credit for these payments. The trial court sided with the County, awarding Johnson only $1933.22 for out-of-pocket costs and denying pre-judgment interest and appellate attorney's fees. The appellate court affirmed the trial court's decision, concluding that the collateral source rule was inapplicable as the County was not a tortfeasor and had made payments from its own self-insurance fund.