Pyle, J.
STATEMENT OF THE CASE
Michael E. Hitchens (“Hitchens”) appeals the small claims court’s judgment in favor of Collection Specialists, Inc. (“Collection Specialists”) concerning a bill for dental work.
We affirm.
ISSUE
Whether the small claims court denied Hitchens the due process of law when it admitted a letter containing hearsay into evidence.
….
On April 26, 2013, the small claims court held a bench trial. During the trial, Collection Specialists offered into evidence a letter from Dr. Laconi in which he described his perspective of events. Specifically, Dr. Laconi recounted that he had told Hitchens that he would not know how much the procedure would cost until he received a bill for the replacement screws and bridge. He also wrote that Hitchens “was very aware of his treatment plan and was very willing to have it completed. He had [six (6)] appointments with us before the work was completed and never once stated he was unhappy with the treatment he received.” (Ex. 4). Hitchens objected to the admission of the letter, arguing that it was essentially unsworn testimony that was not subject to cross-examination. The small claims court overruled the objection, citing the nature of small claims trials, which favor speedy resolution over rules of evidence or procedure. Hitchens next testified in his defense and contradicted Dr. Laconi’s letter. He stated that he did not realize he would be charged for the repair because he thought that Dr. Laconi had broken the screws while attempting to remove the bridge. (Tr. 31). He also testified that if he had known the repairs would cost so much, he would not have gone through with them.
At the conclusion of the trial, the court entered a judgment in favor of Collection Specialists. On May 21, 2013, Hitchens filed a motion to correct errors in which he argued that the small claims court had denied him due process when it admitted Dr. Laconi’s unsworn letter because he did not have an opportunity to cross-examine Dr. Laconi. Then, on May 22, 2013, the small claims court denied Hitchens’ motion to correct errors. He now appeals. We will provide additional facts as necessary.
….
In light of West’s testimony and the Supreme Court’s decision in Matusky, we find that the small claims court did not deny Hitchens due process by admitting Dr. Laconi’s letter or by basing its judgment on the letter. In Rzeszutek v. Beck, 649 N.E.2d 673 (Ind. Ct. App. 1995), trans. denied, we faced a situation similar to Matusky in which an appellant challenged the small claims court’s acceptance of unsworn hearsay evidence, as well as the court’s judgment based exclusively on that evidence. In that case, the nature of the hearsay evidence the small claims court admitted was almost identical to the nature of the evidence the court admitted in the instant case. See id. at 675. It was an unsworn, but signed, document a witness who had not prepared the document presented under oath. Id.[Footnote omitted.] On appeal, we wrote that the effect of re-writing the Small Claims Rules to provide that a judgment could not be based exclusively on hearsay evidence would “impose technical rules upon largely untrained litigants[,] completely thwarting the express purpose of providing an uncomplicated and simple method of resolution of issues in order to dispense speedy justice between the parties.” Id. at 681. For the same reasons, we decline to impose such technical rules here, and we conclude that the trial court did not deny Hitchens due process.
Affirmed.
MATHIAS, J., and BRADFORD, J., concur.