Sea-Land Service, Inc. v. Lozen International, LLC
United States Court of Appeals for the Ninth Circuit
285 F.3d 808 (9th Cir. 2002)
Relevant factsFree
In a shipping-delay dispute, Lozen (defendant) sought to introduce an email from Sea-Land employee Martinez forwarding another Sea-Land employee's email about a rail delay, prefaced with "Yikes, Pls note the rail screwed us up"; the district court excluded the email as hearsay.
IssueFree
Whether a statement made by a company employee while acting within the scope of her employment is admissible against the company as a party-opponent admission.