Williams v. Alexander

In Williams v. Alexander (309 NY 283 [1955]), which concerned an automobile accident, the Court addressed squarely the issue of whether hospital records are admissible pursuant to the business records exception to the bar against hearsay. The defendant had offered into evidence the plaintiff's description of the accident's occurrence as set down in hospital records. The Court reasoned that business records are deemed trustworthy both because they reflect routine business operations and because the person making the particular entry has the responsibility to keep accurate records that can be relied upon for business purposes (Williams at 286) and that hospital records in particular are trustworthy as they are "designed to be 'relied upon in affairs of life and death' " (Williams at 288, quoting Wigmore, Evidence 1707 at 36 [3d ed 1940]). The Court ruled that hospital records were admissible when they "reflect acts, occurrences or events that relate to diagnosis, prognosis or treatment or are otherwise 'helpful to an understanding of the medical or surgical aspects of the patient's hospitalization.' " (Id. at 287.) The Court held that inasmuch as the description of the accident was unrelated to the plaintiff's diagnosis, prognosis or treatment, the records were not admissible.