Miller v. Warren Memorial Hospital, Inc.

7 Va. Cir. 279, 1986 Va. Cir. LEXIS 160
CourtWarren County Circuit Court
DecidedJuly 30, 1986
DocketCase No. (Law) 6895
StatusPublished

This text of 7 Va. Cir. 279 (Miller v. Warren Memorial Hospital, Inc.) is published on Counsel Stack Legal Research, covering Warren County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Miller v. Warren Memorial Hospital, Inc., 7 Va. Cir. 279, 1986 Va. Cir. LEXIS 160 (Va. Super. Ct. 1986).

Opinion

By JUDGE HENRY H. WHITING

The Court must now rule on the final question of whether it erred in permitting a hospital employee to testify about her "in-house" hospital investigation of the "incident" giving rise to a claim of negligence on the part of hospital employees when a patient cut his foot on glass allegedly left upon the floor of the halls of the hospital.

The issue is reflected in the following portions of the testimony of Mrs. Richardson, a nursing supervisor asked:

Q. In your responsibility as a nursing supervis- or, would you state whether or not you determined on the shift that Mr. Miller came in, that is on the night of July 19th, and before 7:00 AM on July 30th, whether or not there were any instances of breakage or spillage, or any instance of that nature?
A. . . . when [an incident such as this one] comes to my attention I follow it up to see if — I look at the charting. I may talk with the patient to see the patient’s understanding. [280]*280My first response in this instance was to see if there was any broken glass anywhere that had been reported on any of the prior two shifts. We did not find any broken glass at all. . . [I] talked to the nurses that were involved to discuss. . . I talked with the head nurse, Miss Celia Olson. . . Then we looked together at the charting to see if the proper protocol had been followed during the night shift. (Excerpts from Richardson transcript beginning at page 5 and ending at page 8.) In the course of discharging her duties. . . to look into this particular incident regarding Mr. Miller. . . we did not find any medication that had been broken at that time on that shift or on the previous shift. . . (or found any other instances of any kind of glass of any sort being broken. (Excerpts from Richardson transcript at pages 10-11.)
Q. In the course of your completing your responsibilities to look into this particular instance, would you state whether or not any medication vials had been broken, dropped, or anything with regard to any of the patients on that floor that day?
A. No. They had not been when we investigated. No medications had been dropped. And, another way that we can check that with visually is that we, also, have a narcotic count. We have to indicate every shift if there is any medication missing that the patients did not receive, we have to affidavit the back of the narcotic record to indicate that medication was dropped, or spilled, or broken, or how it was discarded with a witness.
Q. And, did you look at those records with regard to the day that Mr. Miller was there?
A. Yes, I did.
Q. What did you find?
[281]*281A. I found that we had not had any instances where the tubexes had been broken, which would cause the narcotic count to be off. (Richardson transcript, pages 14-15.)

When this evidence was proffered, the Court admitted it over the plaintiff's objection, believing that if the witness was carrying out her responsibility for the investigation of the incident in the ordinary course of business of the hospital she would have the right to disclose what information she obtained in the discharge of that duty and the jury could assess its credibility, given the circumstances. The memoranda filed by counsel and its own independent research convince the Court that it was in error in admitting this evidence and that error was prejudicial to the defendant for the reasons which follow:

(A) ADMISSIBILITY OF EVIDENCE.

(1) There must in fact be a record.

Section 235 Friend on Evidence (2d ed.), page 518. The evidence introduced was by way of Mrs. Richardson’s oral report of her investigation. Perhaps she had a writing and that would have met that requirement but the writing was never proffered, although no objection was made on that ground, and that particular objection may have been waived for that reason since the defendant perhaps could have cured the objection by producing the actual written record. While Friend does not make that explicit statement, it is implicit in the entire discussion of the rule by Friend involving "the introduction of certain hearsay evidence found in business records." (Emphasis added, sect. 235 Friend at page 516.)

(2) Accident reports are not made in the regular course of business.

To quote Friend:

Extraordinary transactions or entries made in other than a routine manner are excluded. It is the routine nature of the entry which gives [282]*282it the "guarantee of trustworthiness" previously referred to. Id. at 518.

Cited in support of that statement are Ratliff v. Fewell, 153 Va. 315 (1927), and Fink v. Gass & Oil Co., 203 Va. 86 (1961). In Ratliff one party sought to introduce evidence from a memorandum book of a transaction of the other party which had occurred some three or more years before the entry of the transaction in the book. The Court held this evidence was inadmissible, first because it was not made contemporaneously with the transaction and, second, because it was not made "in the regular course of business." As the Court said:

Shop books, books of account, bank books, etc., are competent as evidence and frequently useful, but to be admissible or to have any value as such they must ordinarily appear to have been made in the regular course of business and as a part of the party's system of keeping his accounts. Experience has demonstrated that their admission must be hedged about with certain safeguards. (Citing cases.)
Before entries of this kind can have any probative value, certain prerequisites must appear. . . . The entry must have been a part of a regular series of entries-not, for example, a casual sale of an article not regularly dealt in, or a casual entry at the beginning of a blank book or at the end of a book already finished and laid aside. Again, the entry is not usable if it shows that it embraces in one item a number of separate transactions, or is in any other way so loosely made that regularity of entry cannot be predicted. Id. at 327-328.

In Fink the Court excluded a letter a consulting physician had written the referring physician who was on the stand describing the injuries from an accident giving rise to the litigation despite a contention that the letter was written to the doctor "in the regular course of business by a consulting physician." Id. at 138.

[283]*283The defendants characterize the nurse's record of the investigation as one made in the ordinary course of business. Courts have taken divergent positions upon this issue, most of the cases being decided under various state statutes embodying the Uniform Business Records as Evidence Act, which § 933, Evidence, 30 Am. Jur. 2d 53, says:

abrogates many of the antiquated and technical common-law rules regarding the admission of business records in evidence and expands the operation of the common-law rule for the admission of such records as an exception to the hearsay rule.

Section 934, Evidence, 30 Am. Jur.

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Bluebook (online)
7 Va. Cir. 279, 1986 Va. Cir. LEXIS 160, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miller-v-warren-memorial-hospital-inc-vaccwarren-1986.