Whaley v. Alaska Workers' Compensation Board

RABINOWITZ, Justice,

concurring.

I do not agree with the court’s conclusion that Whaley’s hearsay testimony was properly excluded because it was “untrustworthy.” AS 44.62.460 dispenses with the rules of evidence in administrative proceedings, and subsection (d) of that statute provides that evidence which would be inadmissible in a civil action, such as hearsay evidence, shall be admitted in an administrative proceeding if it is the kind of evidence “on which responsible persons are accustomed to rely in the conduct of serious affairs.”1 Certainly “responsible persons” routinely and justifiably rely on their physicians’ statements in the conduct of their “serious affairs;” to argue to the contrary would be ludicrous. Thus, I believe that Whaley’s proffered testimony met the threshold requirement for admissibility;2 the question of the trustworthiness of that testimony goes only to the weight of the testimony, not to its admissibility.3

Notwithstanding my disagreement with the majority on this point, I agree that the rulings of the Board and the superior court on the merits of Whaley’s claim should be affirmed because the Board’s error in excluding Whaley’s testimony was harmless.

The statute which permits the introduction of hearsay testimony, AS 44.62.460(d), further provides that “[hjearsay evidence may be used to supplement or explain direct evidence but is not sufficient by itself to support a finding unless it would be admissible over objection in a civil action ” (emphasis supplied). Here there was no direct evidence establishing a causal connection between Whaley’s work-related medical problems and his later heart problems, and thus Whaley’s testimony about his doctors’ statements would not have been sufficient to support a finding that his heart problems were related to his on-the-job injury. Thus, the Board’s erroneous evidentiary ruling was harmless, and the Board’s decision should be affirmed.

.See also 8 A.A.C. 45.120(c).

. See Cook v. Alaska Workmen’s Comp. Bd., 476 P.2d 29, 31-32 (Alaska 1970).

. Although there may be reasons why Whaley’s testimony might have been untrustworthy, such as intentional fabrication, or inaccurate recollection, that testimony would not be excluded on trustworthiness grounds alone even in a civil or criminal action. See Alaska R.Evid. 601, which rejects the notion that a witness may be incompetent to testify because he has an interest in the outcome of the case.