business records exception (North Dakota) · Go Syfert
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business records exception in North Dakota

12 North Dakota opinions name it 1 courts 1955–2025 2 in the last five years

The cases below were cited by North Dakota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Cameron v. Otto Bock Orthopedic Industry, Inc.green
ca1 · 1994 · cited in 4 North Dakota opinions naming this issue, 2007–2009
2 sentences

2009“To satisfy the business records exception, each participant in the creation of the record must be acting in the course of regularly conducted business to ensure the trustworthiness and reliability of the information.” Interest of B.B., at ¶ 8 (citing Cameron v. Otto Bock Orthopedic Indus., Inc., 43 F.3d 14, 16 (1st Cir. 1994)).

2009“To satisfy the business records exception, each participant in the creation of the record must be acting in the course of regularly conducted business to ensure the trustworthiness and reliability of the information.” Interest of B.B. , at 8 (citing Cameron v. Otto Bock Orthopedic Indus., Inc. , 43 F.3d 14, 16 (1st Cir. 1994)).

44
Endicott Johnson Corporation v. Goldegreen
nd · 1971 · cited in 2 North Dakota opinions naming this issue, 1975–2021
2 sentences

2021See N.D.R.Ev. 803(6); N.D.C.C. § 31-08-01; see also Sanford v. Sanden, 343 N.W.2d 776, 778 (N.D. 1984); Endicott Johnson Corp. v. Golde, 190 N.W.2d 752, 756-57 (N.D. 1971).

1975This court, in Endicott Johnson Corporation v. Golde, 190 N.W.2d 752, 756-757 (N.D.1971), said: “The purpose of the enactment of § 31— 08-01, N.D.C.C., was to enlarge the operation of the business records exception to the hearsay evidence rule and § 31-08-01 should be liberally construed to that end.

22
State v. Hendersongreen
nd · 2024 · cited in 1 North Dakota opinions naming this issue, 2025–2025
1 sentence

2025N.D.R.Ev. 803(6); see State v. Henderson, 2024 ND 42 , ¶¶ 18–19, 4 N.W.3d 223 .

11
Sanford v. Sandengreen
nd · 1984 · cited in 1 North Dakota opinions naming this issue, 2021–2021
1 sentence

2021See N.D.R.Ev. 803(6); N.D.C.C. § 31-08-01; see also Sanford v. Sanden, 343 N.W.2d 776, 778 (N.D. 1984); Endicott Johnson Corp. v. Golde, 190 N.W.2d 752, 756-57 (N.D. 1971).

11
State v. Ramseygreen
nd · 2005 · cited in 1 North Dakota opinions naming this issue, 2009–2009
2 sentences

2009See Ramsey, 2005 ND 42, ¶ 8 , 692 N.W.2d 498 (stating that a court abuses its discretion when it misinterprets or misapplies the law). [¶ 25] However, this does not end our analysis on the issue, as we find that the admission of the CPA Report under Rule 807 was not reversible error.

2009See Ramsey, 2005 ND 42, ¶ 8 , 692 N.W.2d 498 (stating that a court abuses its discretion when it misinterprets or misapplies the law). [¶ 25] However, this does not end our analysis on the issue, as we find that the admission of the CPA Report under Rule 807 was not reversible error.

11
JR Watkins Company v. Vangengreen
nd · 1962 · cited in 1 North Dakota opinions naming this issue, 1970–1970
2 sentences

1970Watkins Company v. Vangen, 116 N.W.2d 641 at 650 (N.D.1962), wherein this court reaffirmed its view that the intent of the Uniform Act was to enlarge the operation of the business records exception to the Hearsay Evidence Rule.

1970Watkins Company v. Vangen, 116 N.W.2d 641 at 650 (N.D.1962), wherein this court reaffirmed its view that the intent of the Uniform Act was to enlarge the operation of the business records exception to the Hearsay Evidence Rule.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in North Dakota. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
State v. Bernstein green
ndctapp · 2005
2 sentences

2009State v. Bernstein, 2005 ND APP 6, ¶ 20 , 697 N.W.2d 371 (“When the judgment below is entirely favorable to the appellee, he is entitled to attempt to save the judgment upon any ground asserted in the trial court.”).

2009State v. Bernstein, 2005 ND APP 6, ¶ 20 , 697 N.W.2d 371 (“When the judgment below is entirely favorable to the appellee, he is entitled to attempt to save the judgment upon any ground asserted in the trial court.”).

22009–2009
In Re TT green
nd · 2004
2 sentences

2007A finding is clearly erroneous "if there is no evidence to support it, if the reviewing court is left with a definite and firm conviction a mistake has been made, or if the finding is induced by an erroneous view of the law." Id. [¶ 23] The juvenile court found B.B. was deprived as alleged in the petition, specifically citing "repeated domestic violence, substance abuse issues and failure to follow through with appropriate rehabilitative treatment/counseling regimens by both [parents]." Although the court's findings are minimal, they are sufficient to understand the basis for the court's depri

2007A finding is clearly erroneous “if there is no evidence to support it, if the reviewing court is left with a definite and firm conviction a mistake has been made, or if the finding is induced by an erroneous view of the law.” Id. [¶23] The juvenile court found B.B. was deprived as alleged in the petition, specifically citing “repeated domestic violence, substance abuse issues and failure to follow through with appropriate rehabilitative treatment/counseling regimens by both [parents].” Although the court’s findings are minimal, they are sufficient to understand the basis for the court’s depriv

22007–2007
In Re BB green
nd · 2007
2 sentences

2013In In re J.S.L., at ¶ 20, we discussed In re B.B., 2007 ND 115, ¶¶ 8-9 , 735 N.W.2d 855 , in which we held that child assessment reports contained “hearsay within hearsay” and such a “report was not admissible under the business records exception because of the presence of statements made by individuals who were not acting in the regular course of business, and because the person who prepared the report did not have personal knowledge of the events detailed in those statements.” We noted, however, that such statements may be admissible under the public records exception in N.D.R.Ev. 803(8).

2013In In re J.S.L., at ¶ 20, we discussed In re B.B., 2007 ND 115, ¶¶ 8-9 , 735 N.W.2d 855 , in which we held that child assessment reports contained “hearsay within hearsay” and such a “report was not admissible under the business records exception because of the presence of statements made by individuals who were not acting in the regular course of business, and because the person who prepared the report did not have personal knowledge of the events detailed in those statements.” We noted, however, that such statements may be admissible under the public records exception in N.D.R.Ev. 803(8).

12013–2013
Grand Forks County Social Services v. T.L. green
nd · 2009
2 sentences

2013We then distinguished B.B. because the trial court in J.S.L. had relied on the residual exception in N.D.R.Ev. 807. [¶ 36] In In re J.S.L., 2009 ND 43, ¶ 24 , 763 N.W.2d 783 , however, we held that while the report “may have been admissible under the combined force of the business records exception and the public records exception, the [trial] court’s decision to admit the Report under the residual exception was an abuse of discretion.” Nonetheless, we explained admission of the report was not reversible error: However, this does not end our analysis on the issue, as we find that the admission

2013We then distinguished B.B. because the trial court in J.S.L. had relied on the residual exception in N.D.R.Ev. 807. [¶ 36] In In re J.S.L., 2009 ND 43, ¶ 24 , 763 N.W.2d 783 , however, we held that while the report “may have been admissible under the combined force of the business records exception and the public records exception, the [trial] court’s decision to admit the Report under the residual exception was an abuse of discretion.” Nonetheless, we explained admission of the report was not reversible error: However, this does not end our analysis on the issue, as we find that the admission

12013–2013
Northwestern Improvement Company v. Norris green
nd · 1955
1 sentence

1962In Northwestern Improvement Co. v. Norris, N.D., 74 N.W.2d 497 , we held that the purpose of the statute was to enlarge the operation of the business records exception to the hearsay evidence rule, that the statute should be liberally construed to that end, and that the ruling of the trial court on the admission or exclusion of records under the statute will not be reversed in the absence of a manifest abuse of discretion.

11962–1962
State v. Ramstad green
nd · 1958
1 sentence

1962To the same effect is State v. Ramstad, N.D., 87 N.W.2d 736 .

11962–1962
Loper v. Morrison green
cal · 1944
2 sentences

1955Loper v. Morrison, 23 Cal.2d 600 , 145 P.2d 1 ; Fuller v. White, Cal.App., 193 P.2d 100 .

1955Loper v. Morrison, 23 Cal.2d 600 , 145 P.2d 1 ; Fuller v. White, Cal.App., 193 P.2d 100 .

11955–1955

Where else courts name it

NY 343 (1975–2026) CA 170 (1944–2026) TX 162 (1966–2026) FL 144 (1982–2026) IL 137 (1975–2026) PA 129 (1971–2026) IN 95 (1974–2020) OH 86 (1988–2026) GA 76 (1976–2025) NJ 63 (1969–2026) WA 62 (1976–2026) LA 60 (1977–2022) CT 58 (1981–2026) VA 57 (1975–2025) MO 46 (1978–2025) NC 45 (1978–2026) MI 36 (1968–2025) AL 36 (1982–2026) MD 34 (1975–2026) NM 34 (1976–2021) OR 32 (1967–2026) ME 30 (1981–2024) TN 24 (1977–2020) MA 23 (1992–2026) DC 23 (1978–2021) KS 20 (1974–2023) CO 20 (1979–2026) SC 18 (2002–2024) IA 17 (2008–2025) ID 17 (1983–2026) NE 16 (1982–2026) AZ 15 (1965–2024) AR 14 (1986–2026) MS 14 (1983–2017) MN 14 (1958–2016) UT 14 (1981–2026) SD 13 (1953–2026) ND 12 (1955–2025) KY 12 (1987–2024) WI 10 (1975–2025) MT 9 (1957–2024) OK 9 (1977–2014) HI 9 (1977–2025) AK 8 (2002–2025) NH 8 (1984–2019) NV 5 (1985–2025) DE 5 (2001–2025) RI 4 (2004–2017) WV 3 (1997–2002) VT 2 (2019–2019) WY 2 (2023–2023)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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