Admissibility of Medical and Insurance Records under the Uniform Business Records Act: Marvelle Allen v. St. Louis Public Service Company

Admissibility of Medical and Insurance Records under the Uniform Business Records Act: Marvelle Allen v. St. Louis Public Service Company

Introduction

Marvelle Allen, the appellant, brought a personal injury lawsuit against St. Louis Public Service Company, the respondent, in the Circuit Court of the City of St. Louis. The incident in question occurred on January 7, 1952, when Ms. Allen, a passenger on one of the respondent's buses, alleged that a sudden and violent jerk of the bus caused her to fall, resulting in injuries to her left shoulder, neck, and back. The case was adjudicated under the doctrine of res ipsa loquitur, with the jury ultimately rendering a verdict in favor of the defendant. Dissatisfied with the outcome, Ms. Allen appealed the decision, contending primarily with the admission of certain pieces of evidence during the trial.

Summary of the Judgment

The Supreme Court of Missouri, Division Two, reviewed the appeals raised by Ms. Allen concerning the admissibility of specific evidence presented at trial. The appellant challenged the inclusion of her hospital records and an insurance company's records of a prior claim. The court upheld the lower court's decision, affirming that both the hospital records and the insurance records were properly identified under the Uniform Business Records Act and thus admissible. The court found that the appellant did not make specific objections to potentially inadmissible portions of these records, thereby validating their inclusion in the trial proceedings.

Analysis

Precedents Cited

The court referenced several precedents to support its decision:

These cases collectively establish that properly identified business records, including medical and insurance documents, are generally admissible in Missouri courts under the Uniform Business Records Act. The precedents also clarify that hearsay objections are typically ineffective against such records when they meet the statutory requirements.

Legal Reasoning

The court's reasoning centered on the application of the Uniform Business Records Act. The Act mandates that business records, when properly identified and authenticated, are admissible as evidence, effectively negating hearsay objections. The court emphasized that:

  • Medical records maintained in the regular course of business are admissible if properly qualified.
  • Insurance records of prior claims are similarly admissible under the Act.
  • Specific objections to parts of the records can be made, but broad objections without pinpointing inadmissible sections are insufficient to exclude the entire record.

In Marvelle Allen v. St. Louis Public Service Company, the appellant failed to make specific objections to the admissible portions of her medical and insurance records. Consequently, the trial court was justified in admitting the entire exhibits, and the appellate court affirmed this decision, finding no error.

Impact

This judgment reinforces the robust application of the Uniform Business Records Act in Missouri, particularly concerning the admissibility of medical and insurance records in personal injury cases. It clarifies that as long as records are properly authenticated and qualified, objections based solely on hearsay or lack of cross-examination rights are insufficient to exclude them. This precedent ensures that relevant business records can be reliably used in litigation, provided they meet statutory requirements, thereby streamlining the evidentiary process and reducing the burden on plaintiffs to challenge every aspect of such records.

Complex Concepts Simplified

Uniform Business Records Act (UBRA)

The Uniform Business Records Act is a standardized law adopted by many jurisdictions to streamline the admittance of business records in court proceedings. Under UBRA, business records, including medical and insurance documents, are admissible as evidence without the need for the witness who created them to testify, provided they are properly authenticated.

Hearsay Rule

Hearsay refers to an out-of-court statement offered to prove the truth of the matter asserted. Generally, hearsay is inadmissible unless it falls under an established exception. However, records admitted under UBRA are exceptions to the hearsay rule, meaning they can be presented as evidence even if they contain hearsay.

Res Ipsa Loquitur

Res ipsa loquitur is a legal doctrine that allows a party to prove negligence through circumstantial evidence. It means "the thing speaks for itself," implying that the nature of the accident is such that negligence can be inferred without direct evidence.

Cross-Examination

Cross-examination is a critical aspect of legal proceedings, allowing a party to challenge the testimony and evidence presented by the opposing side. However, records admitted under UBRA do not inherently grant a right to cross-examine the original creator of the records, as the records are considered reliable if properly authenticated.

Conclusion

The Supreme Court of Missouri's decision in Marvelle Allen v. St. Louis Public Service Company underscores the importance of the Uniform Business Records Act in facilitating the admissibility of business-related evidence in legal disputes. By affirming that properly authenticated medical and insurance records are admissible, the court has provided clarity and consistency in evidentiary standards. This judgment not only reinforces existing legal principles regarding business records but also ensures that such records can be effectively utilized in personal injury cases, thereby enhancing the efficiency and fairness of judicial proceedings.

Case Details

Year: 1956
Court: Supreme Court of Missouri, Division Two.

Judge(s)

[664] EAGER, P.J.

Attorney(S)

Morris Morley and John J. Morris for appellant. (1) The lower court erred in admitting into evidence the stated portion of the medical record offered by defendant, being Defendant's Exhibit 6-E; the court erred by refusing to sustain appellant's (plaintiff's) motion to strike said evidence from the record; by refusing to instruct the jury to disregard said evidence; by refusing plaintiff's request for a mistrial. Appellant respectfully submits that such action by the lower court in admitting the medical record was erroneous for the following reasons: That such evidence constituted hearsay; was highly prejudicial and opinionated; that the admission of such record, a purported expert opinion, denied plaintiff right of cross-examination; that such record constituted an invasion of the province of the jury. Kansas City Stock Yards v. A. Reich Sons, 250 S.W.2d 692; New York Life Ins. Co. v. Taylor, 147 F.2d 297; Bartlett v. Kansas City Pub. Serv. Co., 349 Mo. 13, 160 S.W.2d 740. (2) The lower court erred in admitting into evidence the purported record involving plaintiff's prior claim in a Kroger Food Store, being Defendant's Exhibit 7. Appellant respectfully submits that such action by the lower court in admitting said records was erroneous for the following reasons: That the defendant failed to comply with the Uniform Business Records Act, in that said records (Defendant's Exhibit No. 7) were presented by a person other than the record custodian, were hearsay and prejudicial. Secs. 490.660- 490.690, RSMo 1949; Gray v. St. Louis-S.F. Ry. Co., 363 Mo. 864, 254 S.W.2d 577; Kansas City Stock Yards Co. v. A. Reich Sons, 250 S.W.2d 692. Lloyd E. Boas and Harry Bell for respondent. (1) Defendant's Exhibit 6E was properly identified as a St. Louis County Hospital Record covering the examination, diagnosis and treatment of plaintiff while she was a patient. It was properly qualified as a record kept in the usual and ordinary course of business and there is no merit to plaintiff's contention that it was violative of the hearsay rule, prejudicial and opinionated, an invasion of the province of the jury, and that plaintiff was denied the right to cross-examine the doctor making the entries therein. Melton v. St. Louis Pub. Serv. Co., 363 Mo. 474, 251 S.W.2d 663; Borrson v. Missouri, Kansas Texas Railroad Co., 351 Mo. 214, 172 S.W.2d 826; Sullivan v. Kansas City Pub. Serv. Co., 231 S.W.2d 822; Eickmann v. St. Louis Pub. Serv. Co., 363 Mo. 651, 253 S.W.2d 122; Galli v. Wells, 209 Mo. App. 460, 239 S.W. 894. (2) There is no merit to appellant's contention that Exhibit 7 was erroneously admitted. It was a properly identified claim file, shown to have been kept by Manufacturers and Merchants Indemnity Company in the regular and ordinary course of business, and appellant waived any right to object to the admission thereof for the reason that appellant offered and read a part of said file to the jury. Gray v. St. Louis-S.F. Ry. Co., 363 Mo. 864, 254 S.W.2d 577; Melton v. St. Louis Pub. Serv. Co., 363 Mo. 474, 251 S.W.2d 663; Dorn v. St. Louis Pub. Serv. Co., 250 S.W.2d 859; Biener v. St. Louis Pub. Serv. Co., 160 S.W.2d 780. (3) The evidence contained in Defendant's Exhibits 6E and 7 related solely to plaintiff's injuries and damages, and since the jury resolved the question of liability in favor of the defendant, they did not consider the question of injuries and damages, and therefore appellant could not have been prejudiced by the introduction of such evidence, even if it was improperly admitted. Poague v. Kurn, 346 Mo. 153, 140 S.W.2d 13; Miller v. Riss Co., 259 S.W.2d 366.

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