United States v. Duncan
United States Court of Appeals for the Fifth Circuit
919 F.2d 981 (5th Cir. 1990)
Relevant factsFree
Duncan and other defendants were charged with mail fraud and conspiracy for schemes to defraud insurance companies. At trial, the prosecution introduced insurance-company records that themselves incorporated hospital business records documenting medical treatment; Duncan objected that these were hearsay within hearsay, but the district court admitted them, and Duncan was convicted and appealed.
IssueFree
Whether information in an insurance company's business record that was obtained from hospital records is sufficiently trustworthy to be admissible under the business-records exception to the hearsay rule.