Baker v. Elcona Homes Corp.
United States Court of Appeals for the Sixth Circuit
588 F.2d 551 (1978)
A truck driven by Slabach (defendant), an employee of Elcona Homes (defendant), collided with a car at an intersection, killing four occupants and seriously injuring Cindy Baker (plaintiff); with no eyewitness able to say which vehicle had the green light, the case turned heavily on a police report prepared by an experienced accident-reconstruction officer, Sgt. Hendrickson, who arrived about six minutes after the crash and recorded both Slabach's statement and his own notation that the other car had run the red light. The trial court admitted the report and entered judgment for the defendants; Baker and the other plaintiffs appealed, challenging the report's admission.
Whether a police officer's assessment of fault in an accident report -- specifically, which driver had the red light -- is admissible under the public-records hearsay exception as a factual finding from a legally authorized investigation.