In Adams v. Rising Sun Med. Ctr., the Superior Court dealt with cross appeals from a wrongful death and survival jury trial. The administratrix of the decedent’s estate wanted to testify that she was present when the decedent told a doctor about her family’s medical history. According to the plaintiff, this evidence was admissible as an exception to the hearsay rule under Pa.R.E. 803(4) as a statement made for medical diagnosis or treatment. But the trial court precluded the testimony because the witness was not the person seeking medical treatment and there was no corroboration. The Superior Court disagreed with the trial court and agreed with the plaintiff. The Court held that the testimony was admissible and the exclusion of it constituted reversible error.
