Louisiana v. Koederitz
Annotate this CaseIn an interlocutory appeal, defendant David Koederitz stood accused of second degree battery and false imprisonment. He filed a motion to exclude certain portions of the medical records from Ochsner Hospital in New Orleans, that documented the victim's treatment for a broken nose and black eye from the spring of 2013. According to those records, the victim, defendant’s estranged girlfriend and mother of his child, appeared in the emergency room at Ochsner on February 23, 2013 and “report[ed] physical altercation with boyfriend.” The state alleged that her injuries occurred on February 19, 2013, when the victim paid defendant a visit, and he kept her confined in the following days to allow her injuries to heal. The victim’s initial report and treatment of her physical injuries led to a follow-up session in the hospital with a psychiatrist on February 25, 2013, in which she again identified defendant as her assailant and informed the doctor that “this isn’t the first time he hit me.” Defendant also moved to exclude three letters ostensibly written by the victim, one before the incident that formed the basis of the instant prosecution, and two written months afterwards. The state alleged that the victim subsequently committed suicide in the spring of 2014. Given the unavailability of the victim, the state intended to introduce the medical records and letters in lieu of her live testimony at trial. The trial court granted the defense motions on grounds that introduction of the documentary evidence in substitution of the victim’s live testimony would constitute hearsay in violation of Louisiana’s evidentiary rules and would deny defendant’s Sixth Amendment right of confrontation. The court specifically found that the victim’s statements to the medical personnel at Ochsner were not reasonably related to the treatment and diagnosis of her injuries and were therefore inadmissible as a matter of the hearsay exception. The court further ruled that the letters constituted inadmissible other crimes evidence, even assuming they were properly authenticated and sufficiently connected defendant to the alleged incidents. The Supreme Court granted the state's application for review because it found that the statements made by the victim to her treating physicians identifying the person who struck her repeatedly in the face and broke her nose, as recorded in the certified records from Ochsner Hospital, were admissible under the hearsay exception. The rulings of the courts below were reversed in part and this case was remanded to the trial court for further proceedings.
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