NC General Statutes

N.C. Gen. Stat. § 8-44.1 (2026)

Hospital medical records

✓ current as of July 2026

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Copies or originals of hospital medical records shall not be held inadmissible in any court action or proceeding on the grounds that they lack certification, identification, or authentication, and shall be received as evidence if otherwise admissible, in any court or quasi-judicial proceeding, if they have been tendered to the presiding judge or designee by the custodian of the records, in accordance with G.S. 1A-1, Rule 45(c), or if they are certified, identified, and authenticated by the live testimony of the custodian of such records.

Hospital medical records are defined for purposes of this section and G.S. 1A-1, Rule 45(c) as records made in connection with the diagnosis, care and treatment of any patient or the charges for such services except that records covered by G.S. 122-8.1, G.S. 90-109.1 and federal statutory or regulatory provisions regarding alcohol and drug abuse, are subject to the requirements of said statutes. (1973, c. 1332, s. 1; 1983, c. 665, s. 2.)

§ 8-45. Itemized and verified accounts.

In any actions instituted in any court of this State upon an account for goods sold and delivered, for rents, for services rendered, or labor performed, or upon any oral contract for money loaned, a verified itemized statement of such account shall be received in evidence, and shall be deemed prima facie evidence of its correctness. (1897, c. 480; Rev., s. 1625; 1917, c. 32; C.S., s. 1789; 1941, c. 104.)

Article 4A.

Photographic Copies of Business and Public Records.

Notes of Decisions

Cited in 9 cases (2 in the last 5 years), 1976–2021 · leading case: In re J.S.L.

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In re J.S.L. (2006) N.C. Ct. App. · cites it 2× “N.C. Gen.Stat. § 8-44.1 (2005) provides: Copies or originals of hospital medical records shall not be held inadmissible in any court action or proceeding on the grounds that they lack certification, identification, or authentication, and shall be received as evidence if…”

In re J.B. (2005) N.C. Ct. App. · cites it 2× “N.C. Gen.Stat. § 8-44.1 (2003) provides that copies or originals of hospital medical records shall not be held inadmissible in any court action or proceeding on the grounds that they lack certification, identification, or authentication, and shall be received as evidence if…”

State v. Tolley (1976) N.C. “While it is true that the report, assuming its contents were relevant, was apparently incompetent as hearsay, see G.S. 8-44.1; 1 Stansbury’s North Carolina Evidence § 138 (Brandis rev.”

In Re JSL (2006) N.C. Ct. App. · cites it 2× “N.C. Gen.Stat. § 8-44.1 (2005) provides: Copies or originals of hospital medical records shall not be held inadmissible in any court action or proceeding on the grounds that they lack certification, identification, or authentication, and shall be received as evidence if…”

In the Matter of JB (2005) N.C. Ct. App. · cites it 2× “N.C. Gen.Stat. § 8-44.1 (2003) provides that copies or originals of hospital medical records shall not be held inadmissible in any court action or proceeding on the grounds that they lack certification, identification, or authentication, and shall be received as evidence if…”

Miller v. Carolina Coast Emer. Physicians (2021) N.C. Ct. App. · cites it 3× “” N.C. Gen. Stat. § 8-44.1 (2019). “ ‘Medical records’ means personal information that relates to an individual’s physical or mental condition, medical history, or medical treatment, excluding X rays and fetal monitor records.”

In re the Will of Cromartie (1983) N.C. Ct. App. · cites it 2× “The Sims rule, though well grained into our law now, is but a court-devised modification of the much earlier court-adopted business records exception to the rule against hearsay.”

Donavant v. Hudspeth (1985) N.C. Ct. App. “One of the well defined exceptions to the hearsay rule is the business records exception.”

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