Frampton v. Hartzell

In Frampton v. Hartzell (1960) 179 Cal. App. 2d 771, after an automobile accident, the plaintiff was hospitalized for paranoia. Following a suicide attempt, she was admitted to a state hospital, where she remained at the time of trial. Eight hospital medical staff members met to discuss whether plaintiff's insanity was a result of her automobile accident. One staff member testified as an expert witness and was permitted to relate the opinion of other doctors who had participated in the meeting. The court found "the testimony concerning the opinion of the other doctors was obviously hearsay" and inadmissible because "the opportunity of cross-examining the other doctors as to the basis of their opinion, etc., is denied the party as to whom the testimony is adverse." ( Id. at p. 773.) The error was found to be harmless. ( Id. at pp. 776-777.)