Missouri State Contract Cases 2012 (Part 04): Admission of Business Records

by Brian Rogers on April 17, 2012

in Missouri Contract Cases

St. Francis Medical Center v. Reeves

St. Francis Medical Center sued Edward and Jennifer Reeves to collect unpaid medical bills incurred in the birth of the Reeves’s son alleging breach of express contract and action on account. The trial court entered a judgment in favor of the Reeves and St. Francis appealed. The Missouri Court of Appeals Southern District reversed, ruling that the the trial court erred in failing to admit the Reeves’s medical bills into evidence.

The medical bills were brought to trial by St. Francis’s business manager, Roberta Matlock, who had 28 years of experience handling credit, collections, and billing matters for the hospital. Matlock testified that she was familiar with the Reeves’s account, that Jennifer Reeves and her son were patients at the hospital, and that the hospital’s charges were reasonable. The Reeves objected that the medical bills should be excluded from evidence on the grounds that Matlock wasn’t qualified to testify about the reasonableness of the bills because she wasn’t a licensed medical professional.

According to the court of appeals, the case went awry when the parties began to dispute whether Matlock was qualified to testify whether the medical bills were “reasonable and necessary.” The hospital admissions documents that Reeves signed created a contract and stated that she agreed to pay St. Francis “in accordance with its regular rates and charges for services and goods at the time rendered.” The court of appeals held that the bills were admissible to support St. Francis’s express contract claim and that Matlock was qualified to testify about the hospital’s rates and charges and to lay the foundation for admitting the medical bills into evidence as business records. Therefore, the case was reversed and remanded.

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