official records exception (Pennsylvania) · Go Syfert
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official records exception in Pennsylvania

6 Pennsylvania opinions name it 2 courts 2003–2025 3 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
Rhoads Et Ux. v. Lancaster Park. Auth.green
pacommwct · 1987 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025See also Dep’t’s Br. at 20-22; Comm’n Op. at 3-6; cf. S.E.N., 324 A.2d at 698 (explaining that not every alleged crime necessarily proves that the teacher poses a threat). 25 White, in support, cited to Rhoads v. Lancaster Parking Authority, 520 A.2d 122, 131 (Pa. 16 Second, we examine whether the affidavit itself qualifies under the official records exception to hearsay at 42 Pa.C.S. § 6104(b).

11
Lower Makefield Township v. Lands of Dalgewiczgreen
pacommwct · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021In addition, “an expert report [does not] constitute[] inadmissible hearsay [if] the expert who prepared the report is available for cross-examination regarding the accuracy and reliability of [her] opinion.” Lower Makefield Twp. v. Lands of Dalgewicz, 4 A.3d 1114, 1122 (Pa. Cmwlth. 2010), aff’d, 67 A.3d 772 (Pa. 2013).

11
First Ward Republican Club of Philadelphia v. Commonwealth, Pa. Liquor Control Boardgreen
pacommwct · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
2 sentences

2018See First Ward Republican Club of Phila. v. Pa. Liquor Control Bd., 11 A.3d 38 (Pa. Cmwlth. 2010) (absent an authenticating witness who can provide sufficient information relating to the preparation and maintenance of the record, the record is inadmissible under the official records exception).

2018See First Ward Republican Club of Phila. v. Pa. Liquor Control Bd., 11 A.3d 38 (Pa. Cmwlth. 2010) (absent an authenticating witness who can provide sufficient information relating to the preparation and maintenance of the record, the record is inadmissible under the official records exception).

11
Pa. State Police v. Slaughtergreen
pacommwct · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
2 sentences

2017However, under Section 6104 of the Judicial Code, 42 Pa. C.S. § 6104, the documents qualify under the official records exception to the hearsay rule.11 It provides: 10 It is well settled that “[t]he standard of proof required in a proceeding before an ALJ is a preponderance of the evidence standard.” Gorry, 144 A.3d at 217 (citing Pennsylvania State Police v. Slaughter, 138 A.3d 65, 73 (Pa. Cmwlth. 2016)).

2017This is the lowest evidentiary standard and, as such, “an ALJ must affirm the [PSP]’s determination if the [PSP] presents evidence showing that it is ‘more likely than not’ that the applicant was involuntarily committed pursuant to Section 302 or 303 of the MHPA.” Gorry, 144 A.3d at 217 (citing Slaughter, 138 A.3d at 73 ). 11 In addition, we also note that Section 505 of the Administrative Agency Law provides that “Commonwealth agencies shall not be bound by technical rules of evidence at agency hearings, and all relevant evidence of reasonably probative value may be received.” 2 Pa. C.S. § 50

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
White v. Workmen's Compensation Appeal Board green
pacommwct · 1995
1 sentence

2025Appeal Bd. (Good Shepherd Rehab Hosp.), 666 A.2d 1128 , 1131 n.6 (Pa. Cmwlth. 1995).23 Turning to the second issue, we next examine whether the affidavit itself qualifies under the official records exception to hearsay at 42 Pa.C.S. § 6104(b).

12025–2025
Williams v. Burns green
pa · 2013
1 sentence

2021In addition, “an expert report [does not] constitute[] inadmissible hearsay [if] the expert who prepared the report is available for cross-examination regarding the accuracy and reliability of [her] opinion.” Lower Makefield Twp. v. Lands of Dalgewicz, 4 A.3d 1114, 1122 (Pa. Cmwlth. 2010), aff’d, 67 A.3d 772 (Pa. 2013).

12021–2021
R. Gorry v. PA State Police green
pacommwct · 2016
2 sentences

2017However, under Section 6104 of the Judicial Code, 42 Pa. C.S. § 6104, the documents qualify under the official records exception to the hearsay rule.11 It provides: 10 It is well settled that “[t]he standard of proof required in a proceeding before an ALJ is a preponderance of the evidence standard.” Gorry, 144 A.3d at 217 (citing Pennsylvania State Police v. Slaughter, 138 A.3d 65, 73 (Pa. Cmwlth. 2016)).

2017This is the lowest evidentiary standard and, as such, “an ALJ must affirm the [PSP]’s determination if the [PSP] presents evidence showing that it is ‘more likely than not’ that the applicant was involuntarily committed pursuant to Section 302 or 303 of the MHPA.” Gorry, 144 A.3d at 217 (citing Slaughter, 138 A.3d at 73 ). 11 In addition, we also note that Section 505 of the Administrative Agency Law provides that “Commonwealth agencies shall not be bound by technical rules of evidence at agency hearings, and all relevant evidence of reasonably probative value may be received.” 2 Pa. C.S. § 50

12017–2017
Goldsberry v. United States green
dc · 1991
2 sentences

2003Goldsberry v. U.S., 598 A.2d 376 (D.C.App.1991), provides one of the most extensive analyses of the admissibility of docket notations and indicates that, while hearsay, such entries are admissible under the official records exception to the hearsay rule. .

2003Pursuant to Pa.R.C.P.D.J. 1005C, such first class mailings by the Prothonotary under Allegheny County Local Rule 1005C operates as service and proof of service as required by Pa.R.C.P.D.J. 1005A and 1005B. [2] The cover sheet on the complaint included in the certified record contains a stamped date of February 27, 2001, which is "whited out." A handwritten date of June 11, 2001 is written over the "whited out" date. [3] Goldsberry v. U.S., 598 A.2d 376 (D.C.App. 1991), provides one of the most extensive analyses of the admissibility of docket notations and indicates that, while hearsay, such e

12003–2003

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 6103 (3) PA § 42 Pa. Cons. Stat. § 6104 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 48 (1993–2026) VA 13 (1992–2024) OR 10 (1970–2025) PA 6 (2003–2025) IN 5 (1987–2000) MA 3 (1975–2025) AK 3 (1974–2007) DC 2 (1980–2003) WI 2 (1976–2021) WA 2 (1999–1999) CO 2 (1980–2008)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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