Hahnemann University Hospital v. Sonya Dudnick
292 N.J. Super. 11, 678 A.2d 266 (1996)
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Rule of Law:
A computer-generated business record is admissible under the business records exception to the hearsay rule, N.J.R.E. 803(c)(6), if a qualified witness lays a proper foundation. Once the foundation is laid, the record is presumed trustworthy, and the burden shifts to the opposing party to produce evidence that it is unreliable.
Facts:
- Sonya Dudnick was hospitalized and received treatment at Hahnemann University Hospital.
- At the time, Dudnick had an insurance policy that covered 90% of charges up to $10,000 and 100% of charges thereafter.
- The Hospital billed Dudnick for the services rendered.
- Dudnick's insurance company paid $10,601.59 towards the hospital bill.
- After the insurance payment, an outstanding balance of $1,111.11 remained, which Dudnick did not pay.
Procedural Posture:
- Hahnemann University Hospital filed a collection action against Sonya Dudnick in a New Jersey trial court.
- Following a bench trial, the trial court found in favor of the Hospital and entered a judgment for $1,111.11 plus interest and costs.
- Sonya Dudnick, as the appellant, appealed the trial court's judgment to the Superior Court of New Jersey, Appellate Division.
- Hahnemann University Hospital is the respondent on appeal.
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Issue:
Does the business records exception to the hearsay rule, N.J.R.E. 803(c)(6), render computer-generated records admissible once a qualified witness establishes they were made in the regular course of business, thereby shifting the burden to the opposing party to prove the records are untrustworthy?
Opinions:
Majority - Villanueva, J.A.D.
Yes. A computer-generated business record is admissible under N.J.R.E. 803(c)(6) without meeting special, heightened evidentiary requirements, and the burden is on the opposing party to demonstrate its untrustworthiness. The court explicitly disapproved of the outdated, six-prong test from Monarch Federal Savings & Loan Ass'n v. Genser, noting that computers are now universally used and presumed reliable. Under the modern approach, the proponent of the evidence only needs a qualified witness to lay a foundation by demonstrating that the record is what it purports to be, that the witness is familiar with the record system, and that it was the regular practice of the business to make such a record. The court held that Hahnemann's witness, the custodian of records, met this standard, and the burden then shifted to Dudnick to offer evidence questioning the bill's reliability, which she failed to do. Therefore, the computer printout of the hospital bill was properly admitted.
Analysis:
This decision significantly modernizes New Jersey's evidentiary standards for computer-generated records by explicitly disapproving the stringent, outdated Monarch test. It reflects the judiciary's recognition of the ubiquity and inherent reliability of computers in modern commerce. By shifting the burden to the opponent to prove untrustworthiness, the ruling streamlines the admission of essential evidence in commercial and collections litigation, aligning New Jersey's approach with the more practical federal standard. This precedent simplifies litigation for businesses that rely on computerized records and places the onus on challengers to raise specific, supported objections to their accuracy.
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