Department of Public Aid v. Estate of Wall

Mr. JUSTICE KARNS,

dissenting:

I do not agree that the statute relied upon by the majority (Ill. Rev. Stat. 1977, ch. 23, par. 10 — 13.4) is sufficient, without more, to prove the Department’s claims. To my reading, the statute is simply a means for authenticating certified copies of Department records, thereby rendering them competent evidence.

I do not believe that the tabulation of bills here presented constitutes a Department “record” within the meaning of the statute. Section 10— 13.4 provides in pertinent part that:

“The books, papers, records and memoranda of the Illinois Department or of the administrative enforcement unit, or parts thereof, may be proved in any hearing, investigation, or legal proceeding by a photostatic or other copy thereof under the certificate of the Director of the Illinois Department or the County Superintendent. 006 ’’(Emphasis added.)

The tabulation presented by the Department was not a “photostatic or other” copy of payment records in Wall’s behalf; it was a typewritten list of myriad expenditures whose sums were totalled in the director’s certificate. Neither the court nor the appellee was provided with any means of ascertaining whether the bills in fact belonged to decedent or that the represented sums were compiled accurately. (See In re Estate of Buddeke (1977), 49 Ill. App. 3d 431, 364 N.E.2d 446, and Grand Liquor Co. v. Department of Revenue (1976), 36 Ill. App. 3d 277, 343 N.E.2d 555.) I do not regard as sufficient the Department’s assertion that “a record of these payments are now on file in the offices of the Illinois Department of Public Aid and as such are part of the records and files under my keeping as Director of Public Aid,” because it places the burden of proving the Department’s claim on the opposing party.

While voluminous documents may be presented properly in tabular form, the moving party should supply the basis for tabulation. Professor Wigmore notes that “[m]ost courts require, as a condition [of admitting a summary] that the mass thus summarily testified to shall, if the occasion seems to require it, be placed at hand in court, or at least be made accessible to the opposing party, in order that the correctness of the evidence may be tested by inspection if desired, or that the material for cross-examination may be available.” 4 Wigmore, Evidence §1230, at 535 (Chadbourne rev. 1972).

The affidavit of the director imports verity as to the existence and accuracy of Department records. However, the records remain subject to cross-examination as to their factual basis and the accuracy of their compilation. It is necessary for effective cross-examination that records of the individual expenditures be supplied; otherwise, scrutiny is limited to the Department’s arithmetic in computing the total.

The majority dwell at length on the public records exception to the hearsay rule as independent grounds for admission of the tabulation, although the decision rests on the cited statute. The Department apparently did not rely on the common-law exception, judging from the record, as they presented no evidence as to the nature or performance of public duty in the keeping of the records.

Accordingly, I would affirm the judgment below.