State v. Morales

In State v. Morales, 170 Ariz. 360, 363-64, 824 P.2d 756, 759-60 (App. 1991), the defendant argued his name, contained in medical records, was inadmissible hearsay because the records were offered to prove that he was the same person involved in an accident and treated for injuries, but there was no indication in those records how the hospital had learned the accident victim's name. The Court found "the linking of the trauma code name to the patient's true identity is clearly part of the 'regular practice of the hospital's business activity'" and "it is very much in the hospital's interest to make certain that linkage is accurate, unlike the business in State v. McGann." Id. at 364, 824 P.2d at 760, quoting Ariz. R. Evid. 803(6)(d).