business records exception in Connecticut

58 Connecticut opinions name it 3 courts 1981–2026 7 in the last five years

The cases below were cited by Connecticut 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 (16)

Case	Followed	Cited
Calcano v. Calcanogreen conn · 2001 · cited in 7 Connecticut opinions naming this issue, 2002–2021 2 sentences 2007In applying the business records exception, the statute [§ 52-180] should be liberally interpreted.” (Internal quotation marks omitted.) Calcano v. Calcano, 257 Conn. 230, 240 , 777 A.2d 633 (2001). 2007In applying the business records exception, the statute [§ 52-180] should be liberally interpreted.” (Internal quotation marks omitted.) Calcano v. Calcano, 257 Conn. 230, 240 , 777 A.2d 633 (2001).	1	7
New England Savings Bank v. Bedford Realty Corp.green conn · 1998 · cited in 4 Connecticut opinions naming this issue, 1998–2020 2 sentences 2017Additionally, in New England Savings Bank v. Bedford Realty Corp. , supra, 246 Conn. at 603 , 717 A.2d 713 , our Supreme Court directly quoted the language from Crest Plumbing & Heating Co. that "[t]here is no requirement in § 52-180... that the documents must be prepared by the organization itself to be admissible as that organization's business records." (Internal quotation marks omitted.) This language was cited to support the court's reasoning in its analysis that certain documents were admissible under the business records exception. 2017Additionally, in New England Savings Bank v. Bedford Realty Corp. , supra, 246 Conn. at 603 , 717 A.2d 713 , our Supreme Court directly quoted the language from Crest Plumbing & Heating Co. that "[t]here is no requirement in § 52-180... that the documents must be prepared by the organization itself to be admissible as that organization's business records." (Internal quotation marks omitted.) This language was cited to support the court's reasoning in its analysis that certain documents were admissible under the business records exception.	1	4
American Oil Co. v. Valentigreen conn · 1979 · cited in 4 Connecticut opinions naming this issue, 1993–2008 2 sentences 1997The foundation for such competency of witnesses requires "a person with some degree of computer expertise, who has sufficient knowledge to be examined and cross-examined about the functioning of the computer." American Oil Company v. Valenti, 179 Conn. 349 , 359 (1979) American Oil is the seminal case in Connecticut for the admissibility of computer records into evidence through the business records exception to the rule against hearsay. 1993They were not offered under the business records exception to the housing rule, pursuant to General Statutes, Sec. 52-180 ; American Oil Co. v. Valenti, 179 Conn. 349 , 355 , 357 , 426 A.2d 305 (1979), and should have been excluded as hearsay.	1	4
Federal Deposit Insurance v. Carabettagreen conn · 1999 · cited in 3 Connecticut opinions naming this issue, 2003–2016 2 sentences 2016See id., 376. ‘‘To admit evidence under the business record exception to the hearsay rule, a trial court judge must find that the record satisfies each of the three conditions set forth in General Statutes § 52-180. 2003We rejected that argument, stating that the transcript contained substantial evidence of the reliability of the computer hardware and software systems, and that “[t]o accept the defendants’ invitation would place an impossible burden on the proponent of the use of the business records rule as to records generated by computer.” Id., 397 .	1	3
In re Barbara J.green conn · 1990 · cited in 2 Connecticut opinions naming this issue, 2004–2024 2 sentences 2004The defendant, relies primarily upon our decision in In re Barbara J., 215 Conn. 31, 39-42 , 574 A.2d 203 (1990), in which we concluded that correspondence from a foster mother to a department worker regarding a causal connection between a foster child’s disruptive behavior and visits with her biological mother were admissible pursuant to the business records exception. 2004The defendant, relies primarily upon our decision in In re Barbara J., 215 Conn. 31, 39-42 , 574 A.2d 203 (1990), in which we concluded that correspondence from a foster mother to a department worker regarding a causal connection between a foster child’s disruptive behavior and visits with her biological mother were admissible pursuant to the business records exception.	1	2
Connecticut Light and Power Co. v. Gilmoregreen conn · 2008 · cited in 2 Connecticut opinions naming this issue, 2011–2022 2 sentences 2011See, e.g., Connecticut Light & Power Co. v. Gilmore, 289 Conn. 88, 116-17 , 956 A.2d 1145 (2008) (articulating guidelines for the admissibility of printouts of electronic records under the business records exception). 2011See, e.g., Connecticut Light & Power Co. v. Gilmore, 289 Conn. 88, 116-17 , 956 A.2d 1145 (2008) (articulating guidelines for the admissibility of printouts of electronic records under the business records exception).	1	2
State v. Lewisgreen conn · 1998 · cited in 2 Connecticut opinions naming this issue, 2002–2017 2 sentences 2017I conclude it's a business record." 6 "Connecticut Code of Evidence § 8-7, titled, 'Hearsay within Hearsay,' provides: Hearsay within hearsay is admissible only if each part of the combined statements is independently admissible under a hearsay exception." Dinan v. Marchand , 91 Conn.App. 492 , 498 n.6, 881 A.2d 503 (2005), aff'd, 279 Conn. 558 , 903 A.2d 201 (2006) ; see also State v. Lewis , 245 Conn. 779 , 802, 717 A.2d 1140 (1998). 7 Even if this claim was reviewable, we would conclude that it is meritless. 2017I conclude it's a business record." 6 "Connecticut Code of Evidence § 8-7, titled, 'Hearsay within Hearsay,' provides: Hearsay within hearsay is admissible only if each part of the combined statements is independently admissible under a hearsay exception." Dinan v. Marchand , 91 Conn.App. 492 , 498 n.6, 881 A.2d 503 (2005), aff'd, 279 Conn. 558 , 903 A.2d 201 (2006) ; see also State v. Lewis , 245 Conn. 779 , 802, 717 A.2d 1140 (1998). 7 Even if this claim was reviewable, we would conclude that it is meritless.	1	2
State v. Martinezgreen conn · 2017 · cited in 1 Connecticut opinions naming this issue, 2025–2025 2 sentences 2025Although the defendant’s failure to challenge Recchia’s testimony about his discharge from the Explore program would ordinarily be fatal to his challenge to the admission of that same information via the discharge report; see, e.g., State v. Martinez, 171 Conn. App. 702 , 758 n.20, 158 A.3d 373 (any error in failure to suppress defendant’s written statement to police would have been harmless given that statement was cumulative of other evidence, admission of which defendant did not challenge), cert. denied, 325 Conn. 925 , 160 A.3d 1067 (2017); we nevertheless address his claim regarding the a 2025Although the defendant’s failure to challenge Recchia’s testimony about his discharge from the Explore program would ordinarily be fatal to his challenge to the admission of that same information via the discharge report; see, e.g., State v. Martinez, 171 Conn. App. 702 , 758 n.20, 158 A.3d 373 (any error in failure to suppress defendant’s written statement to police would have been harmless given that statement was cumulative of other evidence, admission of which defendant did not challenge), cert. denied, 325 Conn. 925 , 160 A.3d 1067 (2017); we nevertheless address his claim regarding the a	1	1
State v. Martinezgreen connappct · 2017 · cited in 1 Connecticut opinions naming this issue, 2025–2025 2 sentences 2025Although the defendant’s failure to challenge Recchia’s testimony about his discharge from the Explore program would ordinarily be fatal to his challenge to the admission of that same information via the discharge report; see, e.g., State v. Martinez, 171 Conn. App. 702 , 758 n.20, 158 A.3d 373 (any error in failure to suppress defendant’s written statement to police would have been harmless given that statement was cumulative of other evidence, admission of which defendant did not challenge), cert. denied, 325 Conn. 925 , 160 A.3d 1067 (2017); we nevertheless address his claim regarding the a 2025Although the defendant’s failure to challenge Recchia’s testimony about his discharge from the Explore program would ordinarily be fatal to his challenge to the admission of that same information via the discharge report; see, e.g., State v. Martinez, 171 Conn. App. 702 , 758 n.20, 158 A.3d 373 (any error in failure to suppress defendant’s written statement to police would have been harmless given that statement was cumulative of other evidence, admission of which defendant did not challenge), cert. denied, 325 Conn. 925 , 160 A.3d 1067 (2017); we nevertheless address his claim regarding the a	1	1
D'AMATO v. Johnstongreen conn · 1953 · cited in 1 Connecticut opinions naming this issue, 2020–2020	1	1
U.S. Bank Trust, N.A. v. Jonesgreen ca1 · 2019 · cited in 1 Connecticut opinions naming this issue, 2020–2020	1	1
Milford Bank v. Phoenix Contracting Group, Inc.green connappct · 2013 · cited in 1 Connecticut opinions naming this issue, 2017–2017	1	1
State v. Billiegreen conn · 1998 · cited in 1 Connecticut opinions naming this issue, 2013–2013	1	1
Constantopoulos v. Commissioner of Correctiongreen conn · 1998 · cited in 1 Connecticut opinions naming this issue, 2013–2013	1	1
Berkeley Federal Bank & Trust, FSB v. Ogalingreen connappct · 1998 · cited in 1 Connecticut opinions naming this issue, 2013–2013	1	1
General Motors Acceptance Corporation v. Capitol Garage, Inc.green conn · 1967 · cited in 1 Connecticut opinions naming this issue, 1991–1991	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Connecticut. Read the followed side critically anyway.

Also cited on this issue (55)

Case	Cited	Years
River Dock & Pile, Inc. v. O & G Industries, Inc. green conn · 1991 2 sentences 2002In River Dock & Pile, Inc. v. O & G Industries, Inc., 219 Conn. 787, 794 , 595 A.2d 839 (1991), our Supreme Court stated: “The witness whose testimony provides the foundation for the admission of a business record must testify to the three statutory requirements, but it is not necessary that the record sought to be admitted was made by that witness or even that the witness have been employed by the business at the time the record was made.” Thus, Santovasi did not even have to pre pare the map to be eligible to provide the foundation for its admission into evidence under the business records e 2002In River Dock & Pile, Inc. v. O & G Industries, Inc., 219 Conn. 787, 794 , 595 A.2d 839 (1991), our Supreme Court stated: “The witness whose testimony provides the foundation for the admission of a business record must testify to the three statutory requirements, but it is not necessary that the record sought to be admitted was made by that witness or even that the witness have been employed by the business at the time the record was made.” Thus, Santovasi did not even have to pre pare the map to be eligible to provide the foundation for its admission into evidence under the business records e	5	1994–2021
State v. Scott neutral connappct · 1993 2 sentences 1999“General Statutes § 52-180 requires that evidence proffered under the business records exception to the hearsay rule satisfy three requirements: (1) that the record was made in the regular course of business; (2) that it was the regular course of the business to make the writing; and (3) that the writing was made at the time of the transaction or occurrence or within a reasonable time thereafter.” (Internal quotation marks omitted.) State v. Scott, 31 Conn. App. 660, 665 , 626 A.2d 817 (1993). 1999“General Statutes § 52-180 requires that evidence proffered under the business records exception to the hearsay rule satisfy three requirements: (1) that the record was made in the regular course of business; (2) that it was the regular course of the business to make the writing; and (3) that the writing was made at the time of the transaction or occurrence or within a reasonable time thereafter.” (Internal quotation marks omitted.) State v. Scott, 31 Conn. App. 660, 665 , 626 A.2d 817 (1993).	4	1994–1999
Hartford Division, Emhart Industries, Inc. v. Amalgamated Local Union 376 green conn · 1983 2 sentences 1999“To be admissible under the business record exception to the hearsay rule, a trial court judge must find that the record satisfies each of the three conditions set forth in General Statutes § 52-180. 3 The court must determine, before concluding that it is admissible, that the record was made in the regular course of business, that it was the regular course of such business to make such a record, and that it was made at the time of the act described in the report, or within a reasonable time thereafter.” (Internal quotation marks omitted.) Bell Food Services, Inc. v. Sherbacow, 217 Conn. 476, 1999“To be admissible under the business record exception to the hearsay rule, a trial court judge must find that the record satisfies each of the three conditions set forth in General Statutes § 52-180. 3 The court must determine, before concluding that it is admissible, that the record was made in the regular course of business, that it was the regular course of such business to make such a record, and that it was made at the time of the act described in the report, or within a reasonable time thereafter.” (Internal quotation marks omitted.) Bell Food Services, Inc. v. Sherbacow, 217 Conn. 476,	4	1986–1999
Bell Food Services, Inc. v. Sherbacow green conn · 1991 2 sentences 2001In applying the business records exception, the statute [§ 52-180] should be liberally inteipreted.” (Citations omitted; internal quotation marks omitted.) Bell Food Services, Inc. v. Sherbacow, 217 Conn. 476, 485 , 586 A.2d 1157 (1991). 2001In applying the business records exception, the statute [§ 52-180] should be liberally inteipreted.” (Citations omitted; internal quotation marks omitted.) Bell Food Services, Inc. v. Sherbacow, 217 Conn. 476, 485 , 586 A.2d 1157 (1991).	3	1999–2001
Hutchinson v. Plante green conn · 1978 2 sentences 1992Although police reports are admissible under the business records exception to the hearsay rule; Hutchinson v. Plante, 175 Conn. 1, 4 , 392 A.2d 488 (1978); statements of witnesses repeated in the report do not fall within this exception because the witnesses are not engaged in the business of reporting their observations of automobile accidents. 1992Although police reports are admissible under the business records exception to the hearsay rule; Hutchinson v. Plante, 175 Conn. 1, 4 , 392 A.2d 488 (1978); statements of witnesses repeated in the report do not fall within this exception because the witnesses are not engaged in the business of reporting their observations of automobile accidents.	3	1992–1998
State v. Milner green conn · 1988 2 sentences 2024Page 12 CONNECTICUT LAW JOURNAL 0, 0 14 ,0 0 Conn. App. 1 In re S. F. bility to justify [the business records exception to the hearsay rule] . . . .’ ’’); cf. State v. Milner, 206 Conn. 512 , 520–21, 539 A.2d 80 (1988) (holding that one page police report detailing contents of telephone call was inadmissible as business record when caller was anony- mous and had no duty to report). 2024Page 12 CONNECTICUT LAW JOURNAL 0, 0 14 ,0 0 Conn. App. 1 In re S. F. bility to justify [the business records exception to the hearsay rule] . . . .’ ’’); cf. State v. Milner, 206 Conn. 512 , 520–21, 539 A.2d 80 (1988) (holding that one page police report detailing contents of telephone call was inadmissible as business record when caller was anony- mous and had no duty to report).	2	2020–2024
Crest Plumbing & Heating Co. v. DiLoreto green connappct · 1987 2 sentences 1989In Crest Plumbing & Heating Co. v. DiLoreto, 12 Conn. App. 468, 475 , 531 A.2d 177 (1987), this court discussed the business records exception to the hearsay rule, as codified in General Statutes § 52-180. 2 There, we held that there is no requirement in the statute that a document must be prepared by the organization itself to be admissible as that organization’s business record. 1989In Crest Plumbing & Heating Co. v. DiLoreto, 12 Conn. App. 468, 475 , 531 A.2d 177 (1987), this court discussed the business records exception to the hearsay rule, as codified in General Statutes § 52-180. 2 There, we held that there is no requirement in the statute that a document must be prepared by the organization itself to be admissible as that organization’s business record.	2	1989–2017
State v. Kirsch green conn · 2003 2 sentences 2006Section 52-180 (a) recognizes “the inherent trustworthiness of records on which businesses rely to conduct their daily affairs.” State v. Kirsch, 263 Conn. 390, 400 , 820 A.2d 236 (2003). 2006Section 52-180 (a) recognizes “the inherent trustworthiness of records on which businesses rely to conduct their daily affairs.” State v. Kirsch, 263 Conn. 390, 400 , 820 A.2d 236 (2003).	2	2004–2006
Paquette v. Hadley green connappct · 1997 2 sentences 2006Police reports are normally admissible under the business records exception to the hearsay rule as set forth in General Statutes § 52-180. 1 See Paquette v. Hadley, 45 Conn. App. 577, 581 , 697 A.2d 691 (1997). 2006Police reports are normally admissible under the business records exception to the hearsay rule as set forth in General Statutes § 52-180. 1 See Paquette v. Hadley, 45 Conn. App. 577, 581 , 697 A.2d 691 (1997).	2	2003–2006
State v. Heinz green conn · 1984 2 sentences 1993General Statutes § 52-180; Emhart Industries, Inc. v. Amalgamated Local Union 376, U.A.W., 190 Conn. 371, 383-84 , 461 A.2d 422 (1983).’ LaFaive v. DiLoreto, 2 Conn. App. 58, 62-63 , 476 A.2d 626 , cert. denied, 194 Conn. 801 , 477 A.2d 1021 (1984).” State v. Waterman, 7 Conn. App. 326, 341 , 509 A.2d 518 , cert. denied, 200 Conn. 807 , 512 A.2d 231 (1986). 1986General Statutes § 52-180; Emhart Industries, Inc. v. Amalgamated Local Union 376, U.A.W., 190 Conn. 371, 383-84 , 461 A.2d 422 (1983).” LaFaive v. DiLoreto, 2 Conn. App. 58, 62-63 , 476 A.2d 626 , cert. denied, 194 Conn. 801 , 477 A.2d 1021 (1984).	2	1986–1993
Royston v. Factor green conn · 1984 2 sentences 1993General Statutes § 52-180; Emhart Industries, Inc. v. Amalgamated Local Union 376, U.A.W., 190 Conn. 371, 383-84 , 461 A.2d 422 (1983).’ LaFaive v. DiLoreto, 2 Conn. App. 58, 62-63 , 476 A.2d 626 , cert. denied, 194 Conn. 801 , 477 A.2d 1021 (1984).” State v. Waterman, 7 Conn. App. 326, 341 , 509 A.2d 518 , cert. denied, 200 Conn. 807 , 512 A.2d 231 (1986). 1986General Statutes § 52-180; Emhart Industries, Inc. v. Amalgamated Local Union 376, U.A.W., 190 Conn. 371, 383-84 , 461 A.2d 422 (1983).” LaFaive v. DiLoreto, 2 Conn. App. 58, 62-63 , 476 A.2d 626 , cert. denied, 194 Conn. 801 , 477 A.2d 1021 (1984).	2	1986–1993
Knapp v. Inland Wetlands Commission green conn · 1986 2 sentences 1993General Statutes § 52-180; Emhart Industries, Inc. v. Amalgamated Local Union 376, U.A.W., 190 Conn. 371, 383-84 , 461 A.2d 422 (1983).’ LaFaive v. DiLoreto, 2 Conn. App. 58, 62-63 , 476 A.2d 626 , cert. denied, 194 Conn. 801 , 477 A.2d 1021 (1984).” State v. Waterman, 7 Conn. App. 326, 341 , 509 A.2d 518 , cert. denied, 200 Conn. 807 , 512 A.2d 231 (1986). 1989State v. Waterman, 7 Conn. App. 326, 341 , 509 A.2d 518 , cert. denied, 200 Conn. 807 , 512 A.2d 231 (1986).	2	1989–1993
State v. Waterman green conn · 1986 2 sentences 1993General Statutes § 52-180; Emhart Industries, Inc. v. Amalgamated Local Union 376, U.A.W., 190 Conn. 371, 383-84 , 461 A.2d 422 (1983).’ LaFaive v. DiLoreto, 2 Conn. App. 58, 62-63 , 476 A.2d 626 , cert. denied, 194 Conn. 801 , 477 A.2d 1021 (1984).” State v. Waterman, 7 Conn. App. 326, 341 , 509 A.2d 518 , cert. denied, 200 Conn. 807 , 512 A.2d 231 (1986). 1989State v. Waterman, 7 Conn. App. 326, 341 , 509 A.2d 518 , cert. denied, 200 Conn. 807 , 512 A.2d 231 (1986).	2	1989–1993
Lafaive v. Diloreto green connappct · 1984 2 sentences 1993General Statutes § 52-180; Emhart Industries, Inc. v. Amalgamated Local Union 376, U.A.W., 190 Conn. 371, 383-84 , 461 A.2d 422 (1983).’ LaFaive v. DiLoreto, 2 Conn. App. 58, 62-63 , 476 A.2d 626 , cert. denied, 194 Conn. 801 , 477 A.2d 1021 (1984).” State v. Waterman, 7 Conn. App. 326, 341 , 509 A.2d 518 , cert. denied, 200 Conn. 807 , 512 A.2d 231 (1986). 1993General Statutes § 52-180; Emhart Industries, Inc. v. Amalgamated Local Union 376, U.A.W., 190 Conn. 371, 383-84 , 461 A.2d 422 (1983).’ LaFaive v. DiLoreto, 2 Conn. App. 58, 62-63 , 476 A.2d 626 , cert. denied, 194 Conn. 801 , 477 A.2d 1021 (1984).” State v. Waterman, 7 Conn. App. 326, 341 , 509 A.2d 518 , cert. denied, 200 Conn. 807 , 512 A.2d 231 (1986).	2	1986–1993
State v. Waterman green connappct · 1986 2 sentences 1993General Statutes § 52-180; Emhart Industries, Inc. v. Amalgamated Local Union 376, U.A.W., 190 Conn. 371, 383-84 , 461 A.2d 422 (1983).’ LaFaive v. DiLoreto, 2 Conn. App. 58, 62-63 , 476 A.2d 626 , cert. denied, 194 Conn. 801 , 477 A.2d 1021 (1984).” State v. Waterman, 7 Conn. App. 326, 341 , 509 A.2d 518 , cert. denied, 200 Conn. 807 , 512 A.2d 231 (1986). 1993General Statutes § 52-180; Emhart Industries, Inc. v. Amalgamated Local Union 376, U.A.W., 190 Conn. 371, 383-84 , 461 A.2d 422 (1983).’ LaFaive v. DiLoreto, 2 Conn. App. 58, 62-63 , 476 A.2d 626 , cert. denied, 194 Conn. 801 , 477 A.2d 1021 (1984).” State v. Waterman, 7 Conn. App. 326, 341 , 509 A.2d 518 , cert. denied, 200 Conn. 807 , 512 A.2d 231 (1986).	2	1989–1993
Lauder v. State green md · 1963 2 sentences 1981We are unpersuaded by the argument that such tags are technically excludable as hearsay unless qualified under the business records exception; State v. Coleman, supra; Lauder v. State, 233 Md. 142 , 195 A.2d 610 (1963); 31A C.J.S., Evidence § 194d; since the inherent unreliability of hearsay is not present in this type of evidence. 1981We are unpersuaded by the argument that such tags are technically excludable as hearsay unless qualified under the business records exception; State v. Coleman, supra; Lauder v. State, 233 Md. 142 , 195 A.2d 610 (1963); 31A C.J.S., Evidence § 194d; since the inherent unreliability of hearsay is not present in this type of evidence.	2	1981–1981
State v. Dunbar green connappct · 2025 1 sentence 2026To require the defendant to produce a witness that could testify from personal knowledge as to the specific time that a particular document was made would unduly constrain the use of the business records exception and directly contradict the liberal interpreta- tion that this court has accorded to § 52-180.” (Footnote omitted; internal quotation marks omitted.) State v. Dunbar, 233 Conn. App. 297 , 315–17, 339 A.3d 642 , cert. denied, 353 Conn. 913 , 344 A.3d 155 (2025).	1	2026–2026
State v. Huckabee green connappct · 1999 1 sentence 2025We conclude that the trial court properly admitted the attendance report under the business records exception.’’ Id., 762–63.	1	2025–2025
State v. Williams neutral connappct · 2021 1 sentence 2025To require the defendant to produce a witness that could testify from personal knowledge as to the specific time that a particular document was made would unduly constrain the use of the business records exception and directly contradict the liberal interpretation that this court has accorded to § 52-180.’’ (Citations omitted; footnote added; internal quotation marks omitted.) State v. Williams, 202 Conn. App. 355 , 364–65, 245 A.3d 830 , cert. denied, 336 Conn. 917 , 245 A.3d 802 (2021). ‘‘To the extent [that] a trial court’s admission of evi- dence is based on an interpretation of the [Conne	1	2025–2025
State v. Bermudez green connappct · 2006 2 sentences 2022Similarly, in State v. Bermudez, 95 Conn. App. 577, 589 , 897 A.2d 661 (2006), this court concluded that a defendant’s argument that portions of medical records that were admitted into evidence ‘‘should have been excluded because [the witness] was not the treating physician is wholly without merit.’’ In so concluding, the court iterated that ‘‘[t]he statute expressly provides that the person making the record is not required to testify. . . . [T]he fact that the . . . sole witness as to the creation of the records . . . personally did not cre- ate each entry in the . . . narrative and [did] no 2022Similarly, in State v. Bermudez, 95 Conn. App. 577, 589 , 897 A.2d 661 (2006), this court concluded that a defendant’s argument that portions of medical records that were admitted into evidence ‘‘should have been excluded because [the witness] was not the treating physician is wholly without merit.’’ In so concluding, the court iterated that ‘‘[t]he statute expressly provides that the person making the record is not required to testify. . . . [T]he fact that the . . . sole witness as to the creation of the records . . . personally did not cre- ate each entry in the . . . narrative and [did] no	1	2022–2022
State v. Cooper green conn · 1980 2 sentences 2021See Struckman v. Burns, supra, 551–52 (medical opinions pertaining to diagnosis may be admitted without providing opportu- nity for cross-examination); see also Jenzack Partners, LLC v. Stoneridge Associates, LLC, supra, 334 Conn. 390 (‘‘[t]he initial rationale for the [business records] exception was that . . . business records [are] trust- worthy because their creators had relied on the records for business purposes’’ (internal quotation marks omit- ted)); State v. Cooper, 182 Conn. 207, 213 , 438 A.2d 418 (1980) (right to cross-examination ‘‘is a substantial legal right [that] may not be ab 2021See Struckman v. Burns, supra, 551–52 (medical opinions pertaining to diagnosis may be admitted without providing opportu- nity for cross-examination); see also Jenzack Partners, LLC v. Stoneridge Associates, LLC, supra, 334 Conn. 390 (‘‘[t]he initial rationale for the [business records] exception was that . . . business records [are] trust- worthy because their creators had relied on the records for business purposes’’ (internal quotation marks omit- ted)); State v. Cooper, 182 Conn. 207, 213 , 438 A.2d 418 (1980) (right to cross-examination ‘‘is a substantial legal right [that] may not be ab	1	2021–2021
Oztemel v. Bailey green conn · 2018	1	2020–2020
State v. Jackson green conn · 2018	1	2020–2020
Pirolo v. DeJesus neutral connappct · 2006	1	2020–2020
Jenzack Partners, LLC v. Stoneridge Associates, LLC green connappct · 2018	1	2020–2020
Crawford v. Commissioner of Correction green conn · 2009	1	2020–2020
State v. Saucier green conn · 2007	1	2020–2020
Dinan v. Marchand green conn · 2006	1	2017–2017
Dinan v. Marchand neutral connappct · 2005	1	2017–2017
McCahill v. Town & Country Associates, Ltd. green conn · 1981	1	2013–2013
Margolin v. Kleban and Samor, PC green conn · 2005	1	2008–2008
Crawford v. Washington green scotus · 2004	1	2006–2006
Federal Deposit Insurance v. Carabetta neutral conn · 1999	1	2006–2006
Baughman v. Collins green conn · 2000	1	2006–2006
State v. Miller green conn · 2000	1	2006–2006
State v. Christian green conn · 2004	1	2006–2006
Federal Deposit Insurance v. Carabetta neutral connappct · 1999	1	2006–2006
Baughman v. Collins green connappct · 1999	1	2006–2006
State v. Kilroy neutral connappct · 2000	1	2006–2006
Gil v. Gil green connappct · 2006	1	2006–2006

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 52-180 (42) CT § Conn. Gen. Stat. § 8-4 (19) CT § Conn. Gen. Stat. § 14-227a (6) CT § Conn. Gen. Stat. § 51-199 (6) CT § Conn. Gen. Stat. § 53a-119 (5) CT § Conn. Gen. Stat. § 8-3 (5) CT § Conn. Gen. Stat. § 1-2z (4) CT § Conn. Gen. Stat. § 4-104 (4) CT § Conn. Gen. Stat. § 52-174 (4) CT § Conn. Gen. Stat. § 53a-32 (4) CT § Conn. Gen. Stat. § 4-183 (3) CT § Conn. Gen. Stat. § 53a-122 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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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