Olson v. Hodges
Supreme Court of Iowa
19 N.W.2d 676 (1945)
After a car crash, Olson (plaintiff) testified at trial that Hodges (defendant) had been driving recklessly, but Hodges introduced a statement Olson signed shortly after the accident attesting that Hodges had actually been driving carefully; Olson explained he was hospitalized and sedated when he signed it and had no memory of doing so or reading it. The trial judge admitted the statement but instructed the jury to consider it only for assessing Olson's credibility as a witness, not as proof of what actually happened, and the jury found for Olson; Hodges appealed the limiting instruction.
Whether an opposing party may introduce a party-declarant's admission not only to impeach the declarant's testimony but also as substantive evidence against the declarant.