Sana v. Hawaiian Cruises, Ltd.

Sana (plaintiff), a seaman employed by Hawaiian Cruises (defendant), sought maintenance and cure benefits after allegedly falling ill at work. At trial, Sana tried to introduce testimony from Beaudry, the insurer's president, about a report by Rutherford, an independent investigator, which relayed statements from Sana's coworkers about statements Sana himself had made about feeling sick -- three layers of hearsay. The trial court excluded the report and ruled for Hawaiian Cruises, and Sana appealed.