The Importance of a Complete Record at Trial: Lessons from a Car Accident Case

courthouse_court_law_justice-scaledAll relevant evidence in a case should be produced at trial. However, the evidence included in a complete record can be subjective. Thus, the parties to a lawsuit should rely on the court’s definition of what a complete medical record consists of. 

Christina Dauzat (Dauzat) was involved in a car accident where she was rear-ended by Erin Wright (Wright). Dauzat filed a lawsuit, and a bench trial was held, which favored Dauzat and awarded damages of $17,741.51, with interest. Wright, State Farm, and Dauzat appealed the ruling.

At the beginning of the bench trial, Dauzat’s counsel introduced authorized exhibits: Exhibit D-1-6, which consisted of medical records from various hospitals. At trial, Dauzat introduced medical records and bills she believed were essential to the case, which was agreed upon at the pretrial conference. These records were classified as Exhibit P-4. State Farm had agreed to the authenticity of the bills. Therefore, the records, Exhibit P-4, were admitted into evidence. State Farm complained that Dauzat’s medical records did not contain the entire certified copies; consequently, they wanted to introduce full copies of Dauzat’s medical records. State Farm claimed Dauzat had personal bias as to which records she included.

Dauzat stated some of the documents in the complete medical records were unrelated to the case. So, she only provided the relevant documents. The trial court noted the parties had agreed to admit the medical records provided by Dauzat. State Farm did not object to Dauzat’s choice of medical records. However, it was made clear that a certified copy of the medical records is a complete copy. 

The trial court agreed to allow State Farm to introduce the entire record, Exhibits D-1 through D-6. Dauzat argued that a certified medical record copy relates to its authentication and would contain information irrelevant to this case. The trial court stated it would only include the information relevant to the accident.  

While preparing their arguments for the appeal, Wright and State Farm learned the court’s record did not include Exhibits D 1-6 and that the exhibits were returned to State Farm’s attorney. Wright and State Farm urged the appeals court to remand the matter to the trial court to clarify its ruling on the admissibility of Exhibits D-1 through D-6. During the trial, the defendants were permitted to ask Dauzat questions from portions of Exhibit D-6 that were not contained in Exhibit P-4. Wright and State Farm asserted the trial court relied upon portions of Exhibit D-6 in its Written Reasons for Judgment.

Dauzat refuted the motion to remand and asserted in their appeal response that Wright and State Farm were granted an extension to file their appeal brief. Before the extension time was exhausted, Wright and State Farm discovered their exhibits were not included in the court’s record. Dauzat maintained that Wright and State Farm did not inform the trial court that they had the exhibits at issue. Further, Wright and State Farm did not request a ruling at the end of the trial, nor did they submit the exhibits. Dauzat contended an argument is considered void when no ruling is made on it. Dauzat argued the remand would only delay justice and increase court fees.

The record showed no signs of the trial court’s acceptance of the D-1-6 exhibits or the P-4 exhibit. The trial court considered Exhibits D-1 through D-6 but did not rule on which one would be approved. The appeals court found exhibits D-1 and D-6 admissible based on statements in the trial court’s Written Reasons for Judgment. Thus, the motion to remand became moot.

This case highlights the importance of understanding what constitutes a complete record in a legal proceeding. While parties may have differing opinions on what evidence should be included, it ultimately falls on the court to determine what is relevant and admissible. The case also serves as a reminder of the importance of obtaining a clear ruling on all matters presented at trial to avoid potential confusion and delays in the appeals process.


Written by Berniard Law Firm Blog Writer: Needum Lekia

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