State v. Spikes

This cause presents two issues: (1) whether *408the admission in evidence of hospital records under R. C. 2317.422 violated appellee’s confrontation right;3 and (2) whether due process of law and Crim. R. 16 require that the prosecutor provide defense counsel with the complete criminal records of all witnesses and of the defendant.

I

R. C. 2317.422 permits the admission in evidence of hospital records which are properly certified. Neither the preparer nor the custodian is required to testify. R. C. 2945.41 provides: “The rules of evidence in civil causes, where applicable, govern in all criminal…