business record exception (Michigan) · Go Syfert
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business record exception in Michigan

9 Michigan opinions name it 2 courts 1972–2026 4 in the last five years

The cases below were cited by Michigan 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 (5)

CaseFollowedCited
Maiden v. Rozwoodgreen
mich · 1999 · cited in 3 Michigan opinions naming this issue, 2022–2026
2 sentences

2026Although police reports have been described as “generally . . . inadmissible hearsay,” In re Forfeiture of a Quantity of Marijuana, 291 Mich App 243, 254 ; 805 NW2d 217 (2011), caselaw has also recognized that such reports may fall within certain hearsay exceptions and that their contents may be plausibly admissible when based on the police officer’s personal observations, see, e.g., Maiden, 461 Mich at 124 (holding that “[t]he police report itself is plausibly admissible under the business record exception, MRE 803(6)”); Latits v Phillips, 298 Mich App 109, 113-114 ; 826 NW2d 190 (2012) (expl

2025See, e.g., Maiden, 461 Mich at 124 (holding that the “police report itself is plausibly admissible under the business record exception, MRE 803(6)”); Latits v Phillips, 298 Mich App 109, 113-114 ; 826 NW2d 190 (2012) (explaining that police reports may be plausibly admissible under an applicable hearsay exception but that any witness statements would constitute inadmissible secondary hearsay, absent their own applicable hearsay exception).

23
Melendez-Diaz v. Massachusettsgreen
scotus · 2009 · cited in 1 Michigan opinions naming this issue, 2020–2020
1 sentence

2020The United States Supreme Court has indicated that the business record exception is inapplicable “if the regularly conducted business activity is the production of evidence for use at trial” or “calculated for use essentially in the court, not in the business.” Melendez-Diaz, 557 US at 321-322 (quotation omitted).

11
People v. Ortizgreen
michctapp · 2002 · cited in 1 Michigan opinions naming this issue, 2016–2016
2 sentences

2016Nevertheless, the conversation between Mason and MS falls under the hearsay exception set forth in MRE 803(3) because it introduces statements of Mason’s “then existing state of mind . . . (such as intent, plan, motive, design, mental feeling, pain, and bodily health).” People v Ortiz, 249 Mich App 297, 309 ; 642 NW2d 417 (2001) (“It is well accepted that evidence that demonstrates an individual’s state of mind will not be precluded by the hearsay rule.”).

2016Nevertheless, the conversation between Mason and MS falls under the hearsay exception set forth in MRE 803(3) because it introduces statements of Mason’s “then existing state of mind . . . (such as intent, plan, motive, design, mental feeling, pain, and bodily health).” People v Ortiz, 249 Mich App 297, 309 ; 642 NW2d 417 (2001) (“It is well accepted that evidence that demonstrates an individual’s state of mind will not be precluded by the hearsay rule.”).

11
People v. Lewisred
mich · 1940 · cited in 1 Michigan opinions naming this issue, 1972–1972
2 sentences

1972In People v Lewis, 294 Mich 684, 688 (1940), the Michigan Supreme Court held that the business record exception (now MCLA 600.2146; MSA 27A.2146) to the hearsay rule is inapplicable in criminal cases on the ground that a contrary rule would violate the constitutional right of confrontation guaranteed persons accused of crime.

1972In People v Lewis, 294 Mich 684, 688 (1940), the Michigan Supreme Court held that the business record exception (now MCLA 600.2146; MSA 27A.2146) to the hearsay rule is inapplicable in criminal cases on the ground that a contrary rule would violate the constitutional right of confrontation guaranteed persons accused of crime.

11
People v. Gauthiergreen
michctapp · 1970 · cited in 1 Michigan opinions naming this issue, 1972–1972
2 sentences

1972In People v Gauthier, 28 Mich App 318, 321-322 (1970), Judge Gillis of this Court examined the Lewis rule and stated: "We proceed here on the assumption that Justice Wiest’s declaration is decisionally binding on this Court and that the Supreme Court did not intend its holding in Lewis to be limited to the facts of the case.

1972In People v Gauthier, 28 Mich App 318, 321-322 (1970), Judge GILLIS of this Court examined the Lewis rule and stated: "We proceed here on the assumption that Justice WIEST's declaration is decisionally binding on this Court and that the Supreme Court did not intend its holding in Lewis to be limited to the facts of the case.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
Latits v. Phillips green
michctapp · 2012
2 sentences

2026Although police reports have been described as “generally . . . inadmissible hearsay,” In re Forfeiture of a Quantity of Marijuana, 291 Mich App 243, 254 ; 805 NW2d 217 (2011), caselaw has also recognized that such reports may fall within certain hearsay exceptions and that their contents may be plausibly admissible when based on the police officer’s personal observations, see, e.g., Maiden, 461 Mich at 124 (holding that “[t]he police report itself is plausibly admissible under the business record exception, MRE 803(6)”); Latits v Phillips, 298 Mich App 109, 113-114 ; 826 NW2d 190 (2012) (expl

2026Although police reports have been described as “generally . . . inadmissible hearsay,” In re Forfeiture of a Quantity of Marijuana, 291 Mich App 243, 254 ; 805 NW2d 217 (2011), caselaw has also recognized that such reports may fall within certain hearsay exceptions and that their contents may be plausibly admissible when based on the police officer’s personal observations, see, e.g., Maiden, 461 Mich at 124 (holding that “[t]he police report itself is plausibly admissible under the business record exception, MRE 803(6)”); Latits v Phillips, 298 Mich App 109, 113-114 ; 826 NW2d 190 (2012) (expl

22025–2026
In re Forfeiture of a Quantity of Marijuana green
michctapp · 2011
2 sentences

2026Although police reports have been described as “generally . . . inadmissible hearsay,” In re Forfeiture of a Quantity of Marijuana, 291 Mich App 243, 254 ; 805 NW2d 217 (2011), caselaw has also recognized that such reports may fall within certain hearsay exceptions and that their contents may be plausibly admissible when based on the police officer’s personal observations, see, e.g., Maiden, 461 Mich at 124 (holding that “[t]he police report itself is plausibly admissible under the business record exception, MRE 803(6)”); Latits v Phillips, 298 Mich App 109, 113-114 ; 826 NW2d 190 (2012) (expl

2026Although police reports have been described as “generally . . . inadmissible hearsay,” In re Forfeiture of a Quantity of Marijuana, 291 Mich App 243, 254 ; 805 NW2d 217 (2011), caselaw has also recognized that such reports may fall within certain hearsay exceptions and that their contents may be plausibly admissible when based on the police officer’s personal observations, see, e.g., Maiden, 461 Mich at 124 (holding that “[t]he police report itself is plausibly admissible under the business record exception, MRE 803(6)”); Latits v Phillips, 298 Mich App 109, 113-114 ; 826 NW2d 190 (2012) (expl

12026–2026
Solomon v. Shuell green
mich · 1990
2 sentences

2024Whether the document itself was admissible depends on an analysis of MRE 803(6) (the business-record exception), which at the time of trial provided, in relevant part: A memorandum, report, record, or data compilation, in any form, of acts, transactions, occurrences, events, conditions, opinions, or diagnoses, made at or near the time by, or from information transmitted by, a person with knowledge, if kept in the course of a regularly conducted business activity, and if it was the regular practice of that business activity to make the memorandum, report, record, or data compilation, all as sho

2024Whether the document itself was admissible depends on an analysis of MRE 803(6) (the business-record exception), which at the time of trial provided, in relevant part: A memorandum, report, record, or data compilation, in any form, of acts, transactions, occurrences, events, conditions, opinions, or diagnoses, made at or near the time by, or from information transmitted by, a person with knowledge, if kept in the course of a regularly conducted business activity, and if it was the regular practice of that business activity to make the memorandum, report, record, or data compilation, all as sho

12024–2024
People v. Perkins green
mich · 1986
2 sentences

1998This was sufficient to preserve the issue for appellate review. [1] People v. Adair, 452 Mich. 473, 485 , 550 N.W.2d 505 (1996), citing People v. Perkins, 424 Mich. 302, 308 , 379 N.W.2d 390 (1986).

1998This was sufficient to preserve the issue for appellate review. [1] People v. Adair, 452 Mich. 473, 485 , 550 N.W.2d 505 (1996), citing People v. Perkins, 424 Mich. 302, 308 , 379 N.W.2d 390 (1986).

11998–1998
People v. Adair green
mich · 1996
2 sentences

1998This was sufficient to preserve the issue for appellate review. [1] People v. Adair, 452 Mich. 473, 485 , 550 N.W.2d 505 (1996), citing People v. Perkins, 424 Mich. 302, 308 , 379 N.W.2d 390 (1986).

1998This was sufficient to preserve the issue for appellate review. [1] People v. Adair, 452 Mich. 473, 485 , 550 N.W.2d 505 (1996), citing People v. Perkins, 424 Mich. 302, 308 , 379 N.W.2d 390 (1986).

11998–1998
Central Fabricators, Inc v. Big Dutchman Division of US Industries, Inc neutral
mich · 1976
2 sentences

1982The policy behind the business record exception was capsulized adeptly in Central Fabricators, Inc v Big Dutchman Division of US Industries, Inc, 398 Mich 352, 356-357 ; 247 NW2d 804 (1976): "The exception to the hearsay rule for records made in the regular course of business " 'is justified on grounds analogous to those underlying other exceptions to the hearsay rule.

1982The policy behind the business record exception was capsulized adeptly in Central Fabricators, Inc v Big Dutchman Division of US Industries, Inc, 398 Mich 352, 356-357 ; 247 NW2d 804 (1976): "The exception to the hearsay rule for records made in the regular course of business " 'is justified on grounds analogous to those underlying other exceptions to the hearsay rule.

11982–1982

Where else courts name it

NY 127 (1973–2026) FL 46 (1985–2024) CT 45 (1983–2024) IL 42 (1977–2026) TX 39 (1989–2025) OH 36 (1990–2026) PA 33 (1986–2026) IN 32 (1982–2020) CA 31 (1963–2024) GA 28 (1983–2025) NJ 26 (1979–2025) MO 26 (1973–2024) WA 15 (2004–2022) MD 14 (1978–2023) VA 11 (2002–2023) AL 11 (1986–2016) MS 10 (1986–2019) LA 10 (1966–2014) MI 9 (1972–2026) NM 7 (2007–2019) NC 7 (2011–2025) ID 6 (1983–2009) UT 5 (1983–2020) HI 5 (2007–2019) ME 5 (1985–2020) TN 5 (1989–2016) SC 4 (1996–2022) MA 4 (1973–2025) DC 4 (1988–2010) IA 4 (1983–2024) CO 3 (1981–2021) OK 3 (1998–2010) ND 3 (1981–2007) NE 3 (2015–2026) OR 3 (2017–2023) WV 2 (1980–1980) VT 2 (2010–2011) AZ 2 (1973–2020) NV 2 (1988–1999) AK 2 (1978–2016) DE 2 (2022–2025) AR 2 (1997–2019)

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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