Key Takeaway
New York Appellate Division confirms computer databases qualify as business records, allowing printouts to be admitted as evidence in court proceedings.
Understanding Computer Databases as Business Records in New York Courts
In today’s digital age, businesses increasingly rely on electronic records and computer databases to track transactions, maintain customer information, and conduct daily operations. When disputes arise and these cases reach litigation, a critical question emerges: can computer-generated records be admitted as evidence in court?
The business records exception to the hearsay rule allows certain documents to be admitted as evidence even though they contain out-of-court statements. Under New York’s Civil Practice Law and Rules (CPLR) § 4518, business records can be admitted if they were made in the regular course of business, at or near the time of the events they record, and it was the regular course of that business to make such records.
The evolution of this rule to encompass digital records represents an important development in evidence law. As business records challenges continue to arise in various contexts, courts must adapt traditional evidentiary principles to modern business practices involving electronic data storage and retrieval systems.
Jason Tenenbaum’s Analysis:
Short and sweet from the Appellate Division.
J.D.M. Imports Co., Inc. v Hartstein, 2010 NY Slip Op 09186 (1st Dept. 2010)
“The court correctly found that plaintiff’s computer database was a business record (see Ed Guth Realty v Gingold, 34 NY2d 440, 451 ), and then properly admitted a print-out from the database (see People v Weinberg, 183 AD2d 932, 933 , lv denied 80 NY2d 977 ; see also Guth, 34 NY2d at 452).”
Key Takeaway
This First Department decision provides clear precedent that computer databases maintained in the ordinary course of business qualify as business records under New York law. The ruling confirms that both the electronic database itself and printouts from that database can be properly admitted as evidence, provided they meet the standard requirements for business record authentication. This principle applies broadly across different business records contexts, making digital evidence more accessible in litigation.
