In Fries v. Goldsby, decided in December 1956, the Nebraska Supreme Court held, inter alia, that a chiropractor’s permanent record of plaintiff’s history, examination, diagnosis, care, and treatment were not admissible into evidence under the Uniform Business Records as Evidence Act. Because the court treated the chiropractor as an expert in his field, this holding probably applies to other medical witnesses who testify as experts in their fields of knowledge. Thus, the court has seemingly held that the permanent records of physicians, surgeons, and dentists do not fall within the purview of the Uniform Act. This note is a discussion of that holding.
Howard E. Tracy,
Evidence—The Uniform Business Records as Evidence Act Applied to Medical Records,
36 Neb. L. Rev. 600
Available at: http://digitalcommons.unl.edu/nlr/vol36/iss4/7