AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

The Plaintiff was injured in a car accident caused by the Defendant, who admitted fault and agreed that the Plaintiff should be compensated. During the trial, the Plaintiff sought to introduce medical bills as evidence of her expenses, but the trial court excluded them on hearsay grounds. The Plaintiff argued that the bills were necessary to establish the reasonableness of her medical expenses (paras 2-4).

Procedural History

• District Court of Grant County: The Plaintiff was awarded $19,000 in damages by a jury. However, the trial court excluded certain medical bills as hearsay, which the Plaintiff sought to admit as evidence of her medical expenses (paras 1, 4).

Parties' Submissions

• Plaintiff-Appellant: Argued that the trial court erred in excluding the medical bills, claiming that the Defendant's evidentiary objections were overly general and that a non-treating physician should be allowed to testify about the reasonableness of the costs reflected in the bills (paras 5, 7).
• Defendant-Appellee: Contended that the medical bills were hearsay and could only be admitted under the business-records exception, which required a proper foundation that the Plaintiff failed to establish (para 4).

Legal Issues

• Were the Defendant's evidentiary objections too general to justify the exclusion of the medical bills?
• Can a non-treating physician testify about the reasonableness of medical expenses reflected in bills that are not admitted into evidence?
• Did the trial court err in excluding the Plaintiff's medical bills as hearsay?

Disposition

• The Court of Appeals affirmed the trial court's decision to exclude the medical bills and upheld the jury's $19,000 verdict (para 16).

Reasons

Per Wechsler J. (Donnelly and Bosson JJ. concurring):

• The Court found that the Defendant's objections were sufficiently specific and did not violate evidentiary rules. The Plaintiff's reliance on precedent regarding general objections was misplaced, as those cases involved the admission, not exclusion, of evidence (para 5).
• The medical bills were deemed hearsay because they were out-of-court statements offered to prove the truth of the amounts charged. The Plaintiff failed to establish an exception to the hearsay rule, such as the business-records exception or the residual exception, which would have required a foundation demonstrating the bills' trustworthiness (paras 6-8, 14).
• The Court rejected the Plaintiff's argument that the bills could be authenticated solely by her testimony that she received them. It emphasized that the amounts in the bills needed to be corroborated by admissible evidence, such as testimony from a records custodian or a qualified witness (paras 4, 12-13).
• The Court noted that other jurisdictions, such as Massachusetts, have statutory exceptions for admitting medical bills, but New Mexico lacks such a statute. The Plaintiff also failed to provide notice under the residual hearsay exception, which could have allowed the bills to be admitted (paras 11, 14).
• The trial court did not abuse its discretion in excluding the bills, as the Plaintiff did not meet the evidentiary requirements to establish their admissibility (para 15).