Citation Edit

Harned v. Credit Bureau of Gillette, 513 P.2d 650 (Wyo. 1973) (full-text).

Factual Background Edit

The plaintiff, credit bureau and assignee of an open account, sued for a sum due. At trial it introduced a recapitulation of the account prepared from certain computer printout sheets. These printout sheets, in turn, had been prepared from the original invoices. The defendant argued that such evidence was inadmissible since it was not the best evidence.

State Appellate Court Proceedings Edit

The appellate court reversed and remanded for a new trial for two reasons. First, the recapitulation was an only summary, and since the original invoices were not produced, the plaintiff violated the best evidence rule. Second, the evidence was not admissible under the Uniform Business Records as Evidence Act,[1] since the recapitulation was not made in the regular course of business, though the computer printouts were. Thus, the court felt, there was no guaranty of reliability of the recapitulation.


  1. Wyo. Stat. §1-172.

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