## Facts

- A patient incurred hospital charges while insured under a policy that covered 90% up to $10,000 and 100% thereafter.
- The insurer paid $10,601.59, leaving an unpaid balance of $1,111.11.
- The hospital sued in the Law Division to recover the unpaid balance.
- At a bench trial, the hospital offered a computer-generated billing printout to prove the account.
- A hospital employee responsible for billing records testified about the hospital’s record-keeping and billing practices to authenticate the printout.
- The patient objected that the printout was unreliable and not properly authenticated, argued the hospital failed to prove charges were reasonable and necessary, and alleged judicial bias.

## Issues

1. Whether a hospital’s computer-generated billing printout is admissible as a business record under N.J.R.E. 803(c)(6) when authenticated by a qualified employee without computer-expert testimony.
2. Whether the hospital was required to present evidence beyond the admitted billing record to prove the charges were reasonable and necessary.
3. Whether the trial judge’s conduct demonstrated bias depriving the patient of a fair trial.

## Decision

- The Appellate Division affirmed the judgment for the hospital for $1,111.11 plus interest and costs.
- The court upheld admission of the computer-generated billing printout as a business record under N.J.R.E. 803(c)(6) based on testimony from a knowledgeable hospital employee.
- The court held the hospital’s proof of the charges was sufficient and the patient failed to present competent rebuttal evidence.
- The court rejected the judicial-bias claim and found no denial of a fair trial.

## Legal Principles

- Computer-generated records are evaluated under the same business-records exception framework as traditional records under N.J.R.E. 803(c)(6).
- A computer printout may be admitted when a custodian or other qualified witness testifies that:
  - the record is kept in the regular course of business,
  - information is entered in the ordinary course of business at or near the time of the event, and
  - the record-keeping practice is regular and reliable.
- Authentication of computerized business records does not require computer-expert testimony where a competent witness can explain the regular record-keeping process.
- Once properly authenticated, computerized business records are treated as presumptively reliable; the opponent bears the burden to show an untrustworthy source or method of preparation.
- An itemized provider bill admitted as a business record may constitute prima facie evidence of reasonable charges; mere disagreement with the amount does not rebut that showing.

## Conclusion

The court affirmed a hospital’s collection judgment, holding that a properly authenticated computerized billing printout is admissible as a business record without computer-expert testimony, and that the admitted bill supported the reasonableness of the charges absent competent rebuttal or proof of unfair trial.


Hahnemann Univ. Hosp. v. Dudnick, 292 N.J. Super. 11, 678 A.2d 266 (App. Div. 1996)