McKenna v. St. Joseph Hospital
1989 WL 36629, 1989 R.I. LEXIS 73, 557 A.2d 854 (1989)
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Rule of Law:
A statement made by a non-patient third party to medical personnel for the purpose of diagnosis or treatment falls under the Rule 803(4) exception to the rule against hearsay. Hearsay within hearsay is admissible under Rule 805 if each part of the combined statement conforms with a hearsay exception.
Facts:
- On May 9 and 10, 1980, John W. McKenna began exhibiting erratic behavior and making confusing statements.
- On the morning of May 12, McKenna saw his psychiatrist, Dr. Bruno Franek, stating he was God and could slow down his molecules to pass through doors.
- Dr. Franek diagnosed McKenna with a 'schizophrenic reaction,' prescribed Haldol (a major tranquilizer) and Artane, and administered an initial dose of Haldol.
- At 1:15 p.m. the same day, Cranston Fire Department rescue personnel found McKenna in a 'sluggish' state on a sidewalk near his car.
- The rescue personnel transported McKenna to St. Joseph Hospital, where he arrived at 1:23 p.m.
- At the hospital, Dr. Adib Mechrefe examined McKenna, concluded he was having a medication reaction, and instructed him to continue taking his prescribed medication and contact his doctor.
- McKenna was discharged from the hospital at approximately 1:45 p.m. without his family or psychiatrist being notified.
- At approximately 2:40 p.m., McKenna jumped from the Broad Street overpass onto Route 95, causing his own death.
Procedural Posture:
- Kathleen M. McKenna, wife of the deceased, initiated a negligence action against Dr. Adib Mechrefe and St. Joseph Hospital in the Superior Court (trial court).
- Before trial, Dr. Mechrefe filed a motion in limine to exclude testimony about statements made by unidentified bystanders to rescue personnel regarding the deceased's behavior.
- The trial justice granted the defendant's motion, ruling the statements were inadmissible hearsay.
- The plaintiff also filed a motion in limine to exclude evidence of her alleged affair, which the trial court granted.
- The case proceeded to a jury trial, which resulted in a verdict for the defendants.
- The plaintiff appealed the trial court's ruling on the defendant's motion in limine to the state's highest court.
- The defendants filed a cross-appeal challenging the trial court's granting of the plaintiff's motion in limine.
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Issue:
Does a statement from an unidentified bystander to emergency rescue personnel about a patient's behavior, which is then relayed by those personnel to hospital staff, constitute inadmissible hearsay, or does it fall within the Rule 803(4) exception for statements made for purposes of medical diagnosis or treatment?
Opinions:
Majority - Fay, Chief Justice
No, the statements are not inadmissible hearsay. Hearsay within hearsay is admissible if each level of hearsay qualifies for an exception. The bystanders' statements to rescue personnel and the rescue personnel's subsequent restatement to hospital staff are both admissible under the Rule 803(4) exception for statements made for purposes of medical diagnosis or treatment. The court reasoned that the first layer of hearsay—the bystanders' statements to the rescue squad—falls under Rule 803(4) because the statements were made to emergency personnel with no motive to fabricate, describing a specific situation to foster treatment for another person. The second layer—the rescue squad's restatement to hospital staff—also falls under Rule 803(4) because the crucial factor is that the statement was made to promote the efficient delivery of medical services and was accompanied by indicia of truthfulness. Since each part of the combined statement conforms with a hearsay exception, the entire statement is admissible under Rule 805, and the trial court's exclusion of this evidence was a reversible error.
Analysis:
This decision significantly broadens the application of the hearsay exception for statements made for medical diagnosis or treatment (Rule 803(4)). It establishes that the declarant need not be the patient; statements from third parties, even unidentified bystanders, can be admissible if their purpose is to aid in a patient's care. The ruling underscores the trustworthiness of statements made in emergency medical situations and provides a clearer path for admitting crucial information relayed through a chain of medical responders. This precedent is vital in negligence and malpractice cases, as it allows juries to consider contextual information that medical providers received or should have received when making treatment decisions.
