Wash. Rev. Code » Title 5 · Chapter 5.45
Revised Code of Washington

Wash. Rev. Code § 5.45.020 (2026)

Business records as evidence

✓ current as of May 2026
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A record of an act, condition or event, shall in so far as relevant, be competent evidence if the custodian or other qualified witness testifies to its identity and the mode of its preparation, and if it was made in the regular course of business, at or near the time of the act, condition or event, and if, in the opinion of the court, the sources of information, method and time of preparation were such as to justify its admission.
[ 1947 c 53 s 2; Rem. Supp. 1947 s 1263-2. Formerly RCW 5.44.110.]
Notes of Decisions
Cited in 188 cases (24 in the last 5 years), 1957–2026 · leading case: Marisa Bavand v. Onewest Bank Fsb, 385 P.3d 233 (Wash. Ct. App. 2016).
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Marisa Bavand v. Onewest Bank Fsb, 385 P.3d 233 (Wash. Ct. App. 2016). · cites it 7× “” 21 Statements made by a “custodian or other qualified witness” in a declaration based on the declarant’s review of business records satisfy CR 56(e) if the declaration satisfies the business records act—RCW 5.45.020. 22 Reviewing courts broadly interpret “custodian” and “other…”
State v. Iverson, 108 P.3d 799 (Wash. Ct. App. 2005). · cites it 8× “Thus, the victim’s prior jail booking records, which contained her name, address, physical description, and booking photos, were properly admitted as business records under RCW 5.45.020, and the court did not err in relying on the records, paired with officer testimony regarding…”
State v. Iverson, 108 P.3d 799 (Wash. Ct. App. 2005). · cites it 8× “Thus, the victims prior jail booking records, which contained her name, address, physical description, and booking photos, were properly admitted as business records under RCW 5.45.020, and the court did not err in relying on the records, paired with officer testimony regarding…”
State v. Ralph Williams' North West Chrysler Plymouth, Inc., 553 P.2d 423 (Wash. 1976). · cites it 4× “These tapes were properly authenticated and admissible under RCW 5.45.020 as business records. [14] [14] Appellants also assign error to the trial court's decision to admit the audio portions of the commercials without the video portions of the tapes.”
State v. Ziegler, 789 P.2d 79 (Wash. 1990). · cites it 5× “We hold that laboratory reports contained in the medical files of a physician, when the physician ordered the laboratory test and relied upon the test results in treating the patient, constitute part of the business records of the physician admissible into evidence under the…”
State v. Nation, 110 Wash. App. 651 (Wash. Ct. App. 2002). · cites it 4× “Business Records Exception — RCW 5.45.020 The State contends Mr. Fortney’s testimony was nevertheless admissible under the business records exception to the hearsay rule, RCW 5.”
Lodis v. Corbis Holdings, Inc., 292 P.3d 779 (Wash. Ct. App. 2013). · cites it 3× “As a result, he explains, there is no evidence to establish that he was a Corbis officer as a matter of law, so the fiduciary duty counterclaim should have been dismissed. ¶40 Business records are exceptions to the hearsay rule.”
State v. Nation, 41 P.3d 1204 (Wash. Ct. App. 2002). · cites it 4× “Business Records Exception—RCW 5.45.020 The State contends Mr. Fortney's testimony was nevertheless admissible under the business records exception to the hearsay rule, RCW 5.”
State v. Kreck, 542 P.2d 782 (Wash. 1975). · cites it 7× “020 provides: A record of an act, condition or event, shall in so far as *115 relevant, be competent evidence if the custodian or other qualified witness testifies to its identity and the mode of its preparation, and if it was made in the regular course of business, at or near…”
State v. DeVries, 72 P.3d 748 (Wash. 2003). · cites it 2× “RCW 5.45.020. This court has interpreted the UBRA as applying to medical records and has set forth criteria to ensure the reliability of these records.”
Int'l Ultimate, Inc. v. St. Paul Fire & Marine Ins., 87 P.3d 774 (Wash. Ct. App. 2004). · cites it 2× “To be admissible as business records, the exhibits must meet the business records test set forth in RCW 5.45.020. 26 We find no abuse of discretion by the trial court in admitting the challenged documents under the business records exception.”
State v. Alexander, 822 P.2d 1250 (Wash. Ct. App. 1992). · cites it 3× “This exception clearly covers that aspect of the hearsay testimony. The trial court permitted Dr.”
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