Spruill v. GarciaAnnotate this Case
In this personal injury action, the Supreme Court affirmed the trial court's judgment in favor of Yashana Spruill and against Angela Tyler only on liability, holding that the trial court erred in admitting certain medical records, but the error was harmless.
Spruill was a passenger in Tyler's vehicle when it was involved in an accident with a vehicle driven by Brendon Garcia. Spruill sued Tyler and Garcia seeking damages for personal injuries allegedly resulting from the accident. The jury reached a verdict in favor of Spruill against Tyler only on liability and awarded $0 in damages. Spruill appealed, arguing that her medical records were improperly admitted into evidence because they had not been properly authenticated and were inadmissible hearsay. The Supreme Court held (1) as to the admission of the medical records, neither the requirements of the authentication statute nor Va. R. Evid. 2:308(6) were satisfied; but (2) in the unique context of this case, the admission of the medical records was harmless error.