State v. Ziegler

— Ernest Ziegler appeals his conviction for first degree statutory rape alleging, inter alia, that the trial court erred in admitting laboratory tests as business records. We hold that laboratory reports contained in the medical files of a physician, when the physician ordered the laboratory test and relied upon the test results in treating the patient, constitute part of the business records of the physician admissible into evidence under the Uniform Business Records as Evidence Act (hereinafter UBRA), RCW 5.45.020. We affirm and remand for resentencing.

Facts

In April 1983, Ernest Ziegler and…