Is a business record admissible as evidence in a civil case?

California, United States of America


The following excerpt is from People v. Joshua, G054730 (Cal. App. 2019):

Inadmissible hearsay is not transformed into admissible evidence simply because it is entered into a business record. "'When multiple hearsay is offered, an exception for each level of hearsay must be found in order for the evidence to be admissible. [Citations.]" (People v. Ayers (2005) 125 Cal.App.4th 988, 995.) The mere fact a document qualifies as a business or official record does not mean everything in the record is admissible. The exception does not make admissible that which would be inadmissible if the person making the record was called as a witness and examined concerning it in court. (Hutton v. Brookside Hospital (1963) 213 Cal.App.2d 350, 355.)

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