Wednesday, December 18, 2013

Hahnemann v. Dudnick case brief

Hahnemann v. Dudnick case brief summary
678 A.2d 266 (N.J. Super. 1996)


CASE SYNOPSIS
Defendant patient challenged the decision of the Superior Court of New Jersey, Law Division, Camden County, which entered judgment, including interest and costs, in favor of plaintiff hospital in plaintiff's action to recover unpaid medical expenses.

CASE FACTS
Plaintiff hospital instituted a collection action against defendant patient for an outstanding hospital bill incurred by defendant. At the time of defendant's hospitalization, she was insured by a policy that provided coverage for 90 percent of the charges up to $ 10,000; thereafter, the insurance company would pay 100 percent of the charges. In accordance with the terms of its policy, defendant's insurance company paid $ 10,601.59 towards this hospitalization. The total amount outstanding after receipt of the insurance payment was $ 1,111.11, which remained unpaid. After a bench trial, the trial court found defendant liable.

DISCUSSION

  • On appeal, the court affirmed the trial court's decision, holding that the trial court did not err by admitting into evidence a computer printout of plaintiff's records. 
  • The court held that the hospital records were a classic example of the type of business record that is an exception to the hearsay rule, N.J. R. Evid. 803(c)(6). 
  • The court also held that plaintiff did not fail to establish that the charges were reasonable and necessary. 
  • Moreover, the court held that defendant offered no evidence that the bill was not usual or customary.

CONCLUSION
The court affirmed the trial court's decision to enter judgment in favor of plaintiff hospital, holding that the trial court did not err when it allowed into evidence a computer printout of defendant patient's hospital records. It further found that plaintiff did not fail to establish that the charges against defendant were reasonable and necessary.


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