Williams v. Alexander

Williams (plaintiff) was struck by a car driven by Alexander (defendant), and the two gave sharply different accounts of the accident at trial. To corroborate his version, Alexander introduced statements attributed to Williams in a hospital record stating that one car had hit another, pushing Alexander's car into Williams. The trial court admitted the record and the appellate court affirmed; Williams appealed.

Whether a hospital record's account of how an accident occurred is admissible under the business-records exception when that account serves no diagnostic or treatment purpose.