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Rock v. Huffco Gas & Oil Co. - 922 F.2d 272 (5th Cir. 1991)

Rule:

District courts are given broad discretion in rulings on the admissibility of evidence; a court will reverse an evidentiary ruling only when the district court has clearly abused this discretion and a substantial right of a party is affected.

Facts:

An employee for an offshore catering business, Richard D. Rock, brought this negligence suit for injuries allegedly suffered during his employment. The employee has died since the instigation of this litigation, and his family members have been substituted as plaintiffs for the purposes of continuing the action. Their evidence consisted of Rock’s statements to physicians that treated his injury, medical records, and business records of his employer. Two of the defendants, Huffco Petroleum Corporation and Dual Drilling Company, filed a motion for summary judgment, which the district court granted. The court ruled that the evidence tendered by the plaintiffs constituted hearsay, which was not admissible under any of the exceptions to the hearsay rule. The plaintiffs appeal the district court's determination that none of the proffered evidence is admissible and its decision to grant the summary judgment.

Issue:

Is the evidence tendered by plaintiff inadmissible as hearsay?

Answer:

Yes.

Conclusion:

The court affirmed the district court decision, holding that pursuant to Fed. R. Evid. 803, written accident reports by the employer, medical records, and accident logs all contained statements by the employee which constituted hearsay that would not qualify for admission under the exceptions provisions of the hearsay rule. Additionally, the court ruled that under Fed. R. Evid. 801(d)(2), the reports were inadmissible as they were not admissions by party opponents but were just documentations of the employee's account of the accidents, and evidence of statements to family members were inadmissible as they lacked the circumstantial guarantees of trustworthiness. The court held that summary judgment was proper.

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