Computerized Records Alone Were Insufficient to Prove Estate Recovery Claim (Mo. App.)

FROM NAELA (http://www.naela.org/):
After Joann Strayer died in 2005, the State filed an estate recovery claim in the amount of $52,931.33. The only evidence it offered in support of its claim were computerized records and a business records affidavit. The records, however, referred to "Ann Staryer." Nowhere in the records did the State identify Ann as Joann. The estate at no time stipulated to the amount owed and the State failed to offer any other evidence that its records were for the same individual. The State argued that a Social Security number on the records proved they related to the same person, but the State failed to present any evidence of what Joann Social Security Number was, so it was impossible to link up the records. When the trial court ruled that the evidence was insufficient, the State appealed. On appeal, the judgment was affirmed. The State's computerized records—without testimony as to the meaning of the data contained therein or other evidence certifying that payment was made on Strayer's behalf—did not constitute competent and substantial evidence of payment.
Declue v. State, 2011 Mo. App. LEXIS 531 (April 19, 2011)
Full case:
Wright v. State, 2011 Mo. App. LEXIS 533 (April 19, 2011)
Full case