Jackson v. Household Finance Corp.

Docket NumberSC18-357
Decision Date02 July 2020
The Supreme Court approved the decision of the Second District Court of Appeal in this foreclosure case, holding that the proper predicate for admission of records into evidence under the business records exception to the hearsay rule can be laid by a qualified witness testifying to the foundational elements of the exception Household Finance Corp III (HFC) field a foreclosure complaint against Petitioners, alleging that Petitioners defaulted under the terms of the note and mortgage. During...

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15 cases
  • Miller v. State
    • United States
    • Florida Supreme Court
    • February 29, 2024
    ...extensive "knowledge" and "experience"—acquired over twenty years—supports the trial court’s decision. See Jackson v. Household Fin. Corp. III, 298 So. 3d 531, 536 n.3 (Fla. 2020) ("Even with respect to expert testimony, oftentimes, the amount of training or experience required is minimal."......
  • Smithey v. State
    • United States
    • Florida District Court of Appeals
    • December 31, 2020
    ...admissible as an excited utterance opened the door to impeachment under section 90.806(1) ); see also Jackson v. Household Fin. Corp. III , 298 So. 3d 531, 535 (Fla. 2020) (explaining that the hearsay exceptions "constitute categories of admissible hearsay").But some Florida courts do not c......
  • R.L.G. v. State
    • United States
    • Florida District Court of Appeals
    • June 16, 2021
    ...question of whether a statement is hearsay is a matter of law and is subject to de novo review on appeal." Jackson v. Household Fin. Corp. III, 298 So. 3d 531, 535 (Fla. 2020). Following this binding precedent, we review the trial court's decision to overrule the juvenile's hearsay objectio......
  • Symonette v. State
    • United States
    • Florida District Court of Appeals
    • February 24, 2021
    ...these documents are inadmissible in evidence. See, e.g., §§ 90.803(6), 90.803(8), 90.901, Fla. Stat. (2020) ; Jackson v. Household Fin. Corp. III, 298 So. 3d 531, 535 (Fla. 2020) ("A party can lay a foundation for the [admission of documents pursuant to the] business records exception in th......
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3 books & journal articles
  • Private Sector Business Records
    • United States
    • James Publishing Practical Law Books Archive Is It Admissible? - 2021 Documentary evidence
    • August 2, 2021
    ...former are generally admissible as the following sections indicate. The latter may be 2 Jackson v. Household Finance Corporation III , 298 So.3d 531 (Supreme Court of Florida, 2020). To lay a foundation for the admission of documents pursuant to the business records exception to hearsay, a ......
  • Private sector business records
    • United States
    • James Publishing Practical Law Books Is It Admissible? Part II. Documentary evidence
    • May 1, 2022
    ...former are generally admissible as the following sections indicate. The latter may be 2 Jackson v. Household Finance Corporation III , 298 So.3d 531 (Supreme Court of Florida, 2020). To lay a foundation for the admission of documents pursuant to the business records exception to hearsay, a ......
  • Chapter 11-9 Unique Considerations for Foreclosures
    • United States
    • Full Court Press Florida Foreclosure Law 2022 Chapter 11 Discovery
    • Invalid date
    ...system within which such documents are kept, the Florida Supreme Court receded from this position in Jackson v. Household Fin. Corp. III, 298 So. 3d 531 (Fla. 2020).63 Prior to the ruling Jackson, Florida district courts often required the presentation of detailed testimony consisting of pe......