Williams v. Defendant
309 NY 283, 129 NE 2d 417 (1955)
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Rule of Law:
A statement in a hospital record regarding the cause of a patient's injuries is not admissible under the business records exception to the hearsay rule unless it is germane to the patient's diagnosis or treatment.
Facts:
- Dessi Williams was crossing a street in Brooklyn with the traffic light in his favor when he was struck by an automobile.
- Williams sustained a fractured right leg and was transported to Kings County Hospital for medical treatment.
- At trial, Williams testified that the defendant's car approached without slowing down and struck him.
- The defendant testified that his car was at a complete stop when another vehicle struck it from behind, propelling it into Williams.
- A physician at Kings County Hospital made an entry in Williams's medical record.
- The entry stated that Williams claimed 'an automobile ran into another automobile that was at a standstill, causing this car (standstill) to run into him,' which contradicted Williams's trial testimony.
Procedural Posture:
- Dessi Williams sued the defendant in a trial court for negligence.
- At trial, the court admitted the full hospital record into evidence over Williams's objection that the statement about the accident's cause was inadmissible hearsay.
- The jury returned a verdict for the defendant.
- Williams appealed to the Appellate Division, which is an intermediate appellate court.
- A divided Appellate Division affirmed the trial court's judgment.
- Williams, as the appellant, appealed the Appellate Division's decision to the Court of Appeals of New York, the state's highest court.
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Issue:
Does a statement in a hospital record describing the cause of an accident, which is not germane to the patient's diagnosis or treatment, fall under the business records exception to the hearsay rule as defined by § 374-a of the Civil Practice Act?
Opinions:
Majority - Fuld, J.
No. A statement in a hospital record regarding the cause of an accident, which is not relevant to diagnosis or treatment, is not admissible under the business records exception. The purpose of the business records exception (§ 374-a) is to admit records that are inherently trustworthy because they are made in the regular course of business and relied upon by that business. A hospital's business is to diagnose and treat patients' ailments. Therefore, only entries that are germane to diagnosis, prognosis, or treatment—or are otherwise helpful to understanding the medical or surgical aspects of the case—are admissible. Details about how an accident occurred, such as whether a car was moving under its own power or was pushed by another car, serve no medical purpose and are not relevant to diagnosis or treatment. As such, these details lack the guarantee of trustworthiness that underpins the business records exception, as there is no professional need for the recording physician to ensure their accuracy.
Dissenting - Desmond, J.
Yes. The statement was properly admitted. The statement is an admission against interest, a well-established exception to the hearsay rule, which makes its admissibility under the business records exception secondary. Even if analyzed under § 374-a, the statute is broad and commits the admissibility of such records to the trial judge's discretion. Since the plaintiff himself introduced portions of the very same hospital record, he vouched for its authenticity and cannot then object when the defendant seeks to admit other relevant parts of it. It is common practice for an examining physician to inquire about the cause of an injury, and there is no reason to adopt a restrictive interpretation that would exclude a patient's own account of the event.
Analysis:
This decision significantly clarifies and narrows the scope of the business records exception as it applies to hospital records in New York. It establishes a 'germaneness' or 'pathological purpose' test, requiring that an entry must relate directly to diagnosis or treatment to be admissible. This precedent forces a distinction between medically relevant patient history and extraneous details about fault or the mechanics of an accident. Consequently, it limits the use of hospital records to prove the cause of an injury, requiring parties to rely on other forms of evidence to establish liability.
