Mahlandt v. Wild Canid Survival & Research Center, Inc.
United States Court of Appeals for the Eighth Circuit
588 F.2d 626 (8th Cir. 1978)
Mahlandt (plaintiff) sued on behalf of his son Daniel for injuries allegedly caused by a wolf owned by the Wild Canid Survival & Research Center, Inc. (Center) and kept at the home of its Director of Education, Kenneth Poos (defendants); Mahlandt sought to introduce a note Poos left saying the wolf bit a child, a similar verbal statement Poos made to his boss, and minutes of a Center directors' meeting (which Poos did not attend) discussing the legal implications of the incident. The trial court excluded all three statements as hearsay, the jury found for Poos and the Center, and Mahlandt appealed.
Whether minutes of a meeting of a corporation and statements made by an employee of the corporation within the scope of his employment are admissible against the corporation.