Conn. Gen. Stat. » Title 04 — MANAGEMENT OF STATE AGENCIES · Chapter 50 — Office of Policy and Management: General Provisions; Budget and Appropriations; State Planning
Connecticut General Statutes

Conn. Gen. Stat. § 4-104 (2026)

Inspection and subpoena of hospital records

✓ current as of May 2026
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Each private hospital, public hospital society or corporation receiving state aid shall, upon the demand of any patient who has been treated in such hospital and after his discharge therefrom, permit such patient or his physician or authorized attorney to examine the hospital record, including the history, bedside notes, charts, pictures and plates kept in connection with the treatment of such patient, and permit copies of such history, bedside notes and charts to be made by such patient, his physician or authorized attorney. If any such hospital, society or corporation is served with a subpoena issued by competent authority directing the production of such hospital record in connection with any proceedings in any court, the hospital, society or corporation upon which such subpoena is served may, except where such record pertains to a mentally ill patient, deliver such record or at its option a copy thereof to the clerk of such court. Such clerk shall give a receipt for the same, shall be responsible for the safekeeping thereof, shall not permit the same to be removed from the premises of the court and shall notify the hospital to call for the same when it is no longer needed for use in court. Any such record or copy so delivered to such clerk shall be sealed in an envelope which shall indicate the name of the patient, the name of the attorney subpoenaing the same and the title of the case referred to in the subpoena. No such record or copy shall be open to inspection by any person except upon the order of a judge of the court concerned, and any such record or copy shall at all times be subject to the order of such judge. Any and all parts of any such record or copy, if not otherwise inadmissible, shall be admitted in evidence without any preliminary testimony, if there is attached thereto the certification in affidavit form of the person in charge of the record room of the hospital or his authorized assistant indicating that such record or copy is the original record or a copy thereof, made in the regular course of the business of the hospital, and that it was the regular course of such business to make such record at the time of the transactions, occurrences or events recorded therein or within a reasonable time thereafter. A subpoena directing production of such hospital record shall be served not less than twenty-four hours before the time for production, provided such subpoena shall be valid if served less than twenty-four hours before the time of production if written notice of intent to serve such subpoena has been delivered to the person in charge of the record room of such hospital not less than twenty-four hours nor more than two weeks before such time for production.

(1949 Rev., S. 294; 1955, S. 111d.)

To facilitate examination of hospital records, section has been implemented by Practice Book. 153 C. 445; Id., 451. Under section, only such parts of hospital record as are generally admissible can be introduced in evidence; history discussed. Id., 445. Cited. 154 C. 593. That part of a hospital record which does not qualify as an exception to the hearsay rule under Sec. 52-180 is inadmissible in evidence. 158 C. 281. Since there was no correlation between hospital's diagnosis, treatment of injuries, and place of plaintiff's fall, hospital record not admissible as to place of fall. 167 C. 631. Cited. 172 C. 275. Meaning of term “state aid” discussed. 175 C. 49. Cited. 177 C. 677. Statement made by patient to physician concerning fear of reprisal from an alleged attacker was admissible as pertinent to diagnosis and treatment. 180 C. 96. Cited. 205 C. 542; 246 C. 51. Letters written for litigation purposes at plaintiff's request and summary of doctor's opinion do not satisfy requirements for the admissibility of hospital records. 247 C. 356.

Cited. 3 CA 137; 5 CA 629; 9 CA 59; Id., 379; 17 CA 121; 20 CA 348; 21 CA 138; 28 CA 402; 31 CA 94. Section allows otherwise inadmissible hearsay to be admissible with certain limitations. 63 CA 72.

Cited. 30 CS 535.

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Notes of Decisions
Cited in 35 cases (1 in the last 5 years), 1959–2021 · leading case: Doe v. Inst. of Living, Inc., 392 A.2d 491 (Conn. 1978).
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Doe v. Inst. of Living, Inc., 392 A.2d 491 (Conn. 1978). · cites it 51× “The Institute claims that an affirmative decision was made not to apply for state grants and appropriations on the basis of several factors including awareness of the provisions of General Statutes § 4-104 pertaining to the production of patient records by hospitals receiving…”
Struckman v. Burns, 534 A.2d 888 (Conn. 1987). · cites it 6× “The records of hospitals receiving state aid may be admitted into evidence under General Statutes § 4-104 upon certification of three requirements by the record-keeper.”
State v. Daniels, 429 A.2d 813 (Conn. 1980). · cites it 8× “” General Statutes § 4-104 provides that a hospital record may be admitted in evidence as a business record “if not otherwise inadmissible.”
State v. Jeustiniano, 374 A.2d 209 (Conn. 1977). · cites it 6× “The legislature, in General Statutes § 4-104, has specifically made hospital records admissible without supporting testimony.”
Lopiano v. Lopiano, 752 A.2d 1000 (Conn. 1998). · cites it 5× “The court examined each of the items, all addressed “to whom it may concern,” and concluded that the four letters that had been written for litigation purposes at the plaintiffs request, and the fifth, a summary of the doctor’s opinion, did not satisfy the requirements of…”
Cornelio v. Stamford Hosp., 717 A.2d 140 (Conn. 1998). · cites it 8× “Historically, only General Statutes §§ 4-104 and 4-105 7 addressed such access.”
State v. Lewis, 717 A.2d 1140 (Conn. 1998). · cites it 4× “The trial court sustained the state’s objection, however, on the ground that the notes were neither hospital records *792 nor certified pursuant to General Statutes § 4-104. 9 The defendant does not challenge the merits of that ruling on appeal.”
State v. Kwaak, 572 A.2d 1015 (Conn. App. Ct. 1990). · cites it 7× “General Statutes § 4-104 (permits hospital records, if not otherwise inadmissible, to be admitted into evidence without any preliminary testimony, “if there is attached thereto the certification in affidavit form of the person in charge of the record room of the hospital .”
State v. Bermudez, 897 A.2d 661 (Conn. App. Ct. 2006). · cites it 4× “5 The defendant also argues that his hospital record was not admissible into evidence due to the failure to comply with General Statutes § 4-104, which provides in relevant part: “Any and all parts of any such [hospital] record or copy, if not otherwise inadmissible, shall be…”
State v. Kirsch, 820 A.2d 236 (Conn. 2003). · cites it 2× “Indeed, this rule is embodied in General Statutes § 4-104, which “provides that a hospital record may be admitted in evidence as a business record ‘if not otherwise inadmissible.”
Puchalsky v. Rappahahn, 774 A.2d 1029 (Conn. App. Ct. 2001). · cites it 4× “During cross-examination of the plaintiff, the defendants offered into evidence, pursuant to General Statutes §§ 4-104 and 52-180, the plaintiffs medical records from his treatment at the Hartford Hospital emergency room on the date of the incident.”
State v. Ham, 739 A.2d 1268 (Conn. App. Ct. 1999). · cites it 6× “The trial court overruled the objection and admitted the records pursuant to General Statutes § 4-104, 7 which allows hospital records, “if not otherwise inadmissible,” to be admitted into evidence without any preliminary testimony when there is attached thereto a certification…”
Show all 35 citing cases →
— Conn. Gen. Stat. § 4-104(k) — 1 case
Old Repub. Nat'l Title Ins. v. Bank of East Asia Ltd., 291 F. Supp. 2d 60 (D. Conn. 2003).
— Conn. Gen. Stat. § 4-104(l)(h) — 1 case
Wells Fargo Bank v. Hartford Nat'l Bank & Trust Co., 484 F. Supp. 817 (D. Conn. 1980).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.