Piercy v. Wal-Mart Stores, Inc.

SUPPLEMENTAL OPINION ON DENIAL OF REHEARING FEBRUARY 22, 1993

Robert L. Brown, Justice.

Petitioner Brenton R. Piercy raises several points on rehearing. The petition is denied but additional comment on the use of answers to interrogatories at trial is required.

We stated in our opinion that answers to interrogatories are generally inadmissible as hearsay in a party’s case-in-chief, though they may be used for impeachment purposes, and we cited Hunter v. McDaniel Bros. Constr. Co., 274 Ark. 178, 623 S.W.2d 196 (1981) for the proposition. That statement is only partially correct. Answers to interrogatories may qualify as admissions by a party-opponent which are not hearsay, as defined, and therefore may constitute substantive evidence and be admissible in a party’s case-in-chief. Ark. R. Evid. 801 (d)(2). If an objection to such answers is raised on foundational or other grounds, it then becomes a matter for the trial court’s discretion. Answers to interrogatories are also admissible for consideration in summary judgment proceedings. Ark. R. Civ. P. 56(c).

In the present case, the circuit court denied admission of all answers to interrogatories as part of Piercy’s case-in-chief on grounds of irrelevancy. On appeal, Piercy contends that answers to interrogatories 19 and 20 were relevant and constituted admissions under Rule 801 (d)(2). That precise rule of evidence was not argued to the circuit court; nor were the two answers to interrogatories 19 and 20 specifically brought to the court’s attention. Moreover, Wal-Mart’s store manager, Roger Trover, who verified the answers, was called as a witness by Piercy. However, no attempt was made by Piercy to impeach Trover with the answers. Under the circumstances, the circuit court did not abuse its discretion in refusing to admit the answers to interrogatories into evidence.

Dudley, J., not participating.