Olesen v. Henningsen
Supreme Court of Iowa
77 N.W.2d 40 (1956)
After Olesen's (plaintiff's) car hit the rear of a wagon owned by Henningsen and Simonson (defendants) that lacked a lit tail lamp, the timing of the accident mattered because Iowa law required such a lamp only after a certain time of day; the defense introduced a time-stamped phone company record of Olesen's post-accident call to the sheriff, verified by company employees as genuine and corroborated by other evidence, though the unidentified operators who created it did not testify. The jury found for the defendants, and Olesen appealed, arguing the phone record was inadmissible hearsay.
Whether a contemporaneous record of an event, made in the regular course of business by someone with personal knowledge to transmit information about the event, is admissible evidence of that event.