Hahnemann University Hospital v. Dudnick

Brief Fact Summary. The plaintiff, Dudnick (the “plaintiff”), refused to pay the portion of her hospital bill that remained after her insurance covered a substantial portion. The plaintiff believed that the cost of the hospitalization was unreasonable, and at trial the plaintiff asserted that the computer printout of her bill was unreliable and therefore inadmissible.

Synopsis of Rule of Law. Computer printouts are business records under the rules of evidence if they are authenticated by a witness who 1) is in charge of the records and familiar with them, 2) the facts are recorded as they occur in normal business, and 3) are recorded according to normal business practice.

Facts. The plaintiff had an insurance policy that covered ninety percent of her hospital bills, and one hundred percent once the bill went above ten thousand dollars. The plaintiff refused to pay her portion, asserting that the bill was unreasonably high. At trial, the plaintiff challenged the reliability of the computer printout admitted by the hospital, as well as challenging the bills excessive amount, and the partiality of the trial judge.

Issue. Whether a computer printout generated by a business attains a level of reliability accorded to more conventional business records that would merit its admission into evidence through traditional methods of authentication?

Held. The court affirmed each of the lower court’s decisions, including the admission of the computer printouts as a business record. Modern technology has enabled computer printouts to be presumptively reliable once a witness who is responsible for and familiar with the printout can verify the printouts. The witness needs to verify that the data recorded in the records is recorded contemporaneously with receiving the data, and the data is recorded according to normal business practice.

Discussion. Computer-generated records now carry the same weight as more traditional business records. The burden is on the party opposing the admission to prove that the source of information or the preparation was unreliable. There is no need to authenticate computer printouts with computer experts because computer use is so ubiquitous in modern times.