Pennsylvania Consolidated Statutes

42 Pa. Cons. Stat. § 6109 (2026)

  Photographic copies of business and public records.

✓ current as of May 2026
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§ 6109.  Photographic copies of business and public records.

(a)  Short title of section.--This section shall be known and may be cited as the "Uniform Photographic Copies of Business and Public Records as Evidence Act."

(b)  General rule.--If any business institution, member of a profession or calling, or any department or agency of government, in the regular course of business or activity, has kept or recorded any memorandum, writing, entry, print, representation, or combination thereof, of any act, transaction, occurrence or event, and in the regular course of business has caused any or all of the same to be recorded, copied or reproduced by any photographic, photostatic, microfilm, microcard, miniature photographic, or other process which accurately reproduces or forms a durable medium for so reproducing the original, the original may be destroyed, in the regular course of business, unless its preservation is required by law. Any such reproduction in order to comply with this section must accurately reproduce all lines and markings which appear on the original. Such reproduction, when satisfactorily identified, is as admissible in evidence as the original itself in any judicial or administrative proceeding, whether the original is in existence or not, and an enlargement or facsimile of such reproduction is likewise admissible in evidence if the original reproduction is in existence and available for inspection under direction of the tribunal. The introduction of a reproduced record, enlargement or facsimile does not preclude admission of the original.

 

Cross References.  Section 6109 is referred to in sections 1378, 1380, 1516, 1550, 3753 of Title 75 (Vehicles).

Notes of Decisions
Cited in 29 cases (3 in the last 5 years), 1985–2025 · leading case: Commonwealth v. Cummings, 487 A.2d 897 (Pa. 1985).
Commonwealth v. Cummings, 487 A.2d 897 (Pa. 1985). · cites it 8× “I would hold that, on the facts stated, the photocopy was sufficiently identified and was admissible pursuant to 42 Pa.C.S. § 6109. The sole issue on this appeal is whether the prosecution must fall because a photocopy of a document, rather than the original, was offered to…”
Am. States Ins. v. Maryland Cas. Co., 628 A.2d 880 (Pa. Super. Ct. 1993). · cites it 2× “Shaffner, a vice-president of the Robinson-Connor Agency, the successor to the Winters-Boland Agency which issued the PREA and the AEC insurance *190 policies and the custodian of the microfilm records, in introducing these records.”
Morabito's Auto Sales v. Com., Dept. of Transp., 715 A.2d 384 (Pa. 1998). · cites it 2× “Specifically, in 42 Pa.C.S. § 6109(b), it is provided that “[a]ny such reproduction .”
Commonwealth v. Jasper, 610 A.2d 949 (Pa. 1992). · cites it 2× “Second, more accurately according to the court is its admissibility under 42 Pa.C.S. § 6109, the Uniform Photographic Copies of Business and Public Records as Evidence Act, which sanctions the admissibility of accurately reproduced copies of original records, citing for…”
Commonwealth v. Estman, 915 A.2d 1191 (Pa. 2007). · cites it 2× “[3] The statute in effect that Morabito asserted should have been used to determine if the photocopies of the documents should be admitted into evidence was 42 Pa.C.S. § 6109(b) which states that "any such reproduction .”
Bergen v. Commonwealth, Dep't of Transp., 785 A.2d 157 (Pa. Commw. Ct. 2001). · cites it 2× “In addition, the department may treat the received documents as documents of the department and use any of the methods of storage permitted under the provisions of 42 Pa.C.S. § 6109 (relating to photographic copies of business and public records) and may reproduce such documents…”
Gallant v. Commonwealth, Dep't of Transp., 805 A.2d 1 (Pa. Commw. Ct. 2002). · cites it 2× “In addition, the department may treat the received documents as documents of the department and use any of the methods of storage permitted under the provisions of 42 Pa.C.S. § 6109 (relating to photographic copies of business and public records) and may reproduce such documents…”
Scott v. Com., Bureau of Driver Licensing, 790 A.2d 291 (Pa. 2002). “§ 6103 (relating to proof of official records), *636 42 Pa.C.S. § 6109 (relating to photographic copies of business and public records) and 75 Pa.”
Tripson v. Commonwealth, Dep't of Transp., 773 A.2d 195 (Pa. Commw. Ct. 2001). “The Department asserts that these certifications complied with the requirements of Sections 6109 and 6103 of the Judicial Code, 42 Pa.C.S. §§ 6109 and 6103, and Section 1516(b) of the Vehicle Code, as amended, 75 Pa.”
Commonwealth v. Little, 512 A.2d 674 (Pa. 1986). · cites it 2× “, [s]uch reproduction, when satisfactorily identified, is as admissible in evidence as *552 the original itself in any judicial or administrative proceeding, whether the original is in existence or not____ 42 Pa.C.S. § 6109(b). The Commonwealth produced the testimony of the…”
Koterba v. Commonwealth, Dep't of Transp., Bureau of Driver Licensing, 736 A.2d 761 (Pa. Commw. Ct. 1999). “In addition, the department may treat the received documents as documents of the department and use any of the methods of storage permitted under the provisions of 42 Pa.C.S. § 6109 (relating to photographic copies of business and public records), and may reproduce such…”
Hoover v. Commonwealth, Dep't of Transp., Bureau of Driver Licensing, 725 A.2d 1254 (Pa. Commw. Ct. 1999). · cites it 2× “In addition, the department may treat the received documents as documents of the department and use any of the methods of storage permitted under the provisions of 42 Pa. C.S. § 6109 (relating to photographic copies of business and public records), and may reproduce such…”
— 42 Pa. Cons. Stat. § 6109(a)(11) — 1 case
Com. v. Mescolotto, L. (Pa. Super. Ct. 2014).
— 42 Pa. Cons. Stat. § 6109(b) — 13 cases
Morabito's Auto Sales v. Com., Dept. of Transp., 715 A.2d 384 (Pa. 1998). “Specifically, in 42 Pa.C.S. § 6109(b), it is provided that “[a]ny such reproduction .”
Commonwealth v. Cummings, 487 A.2d 897 (Pa. 1985). “I would hold that, on the facts stated, the photocopy was sufficiently identified and was admissible pursuant to 42 Pa.C.S. § 6109. The sole issue on this appeal is whether the prosecution must fall because a photocopy of a document, rather than the original, was offered to…”
Commonwealth v. Estman, 915 A.2d 1191 (Pa. 2007). “[3] The statute in effect that Morabito asserted should have been used to determine if the photocopies of the documents should be admitted into evidence was 42 Pa.C.S. § 6109(b) which states that "any such reproduction .”
Commonwealth v. Little, 512 A.2d 674 (Pa. 1986). “, [s]uch reproduction, when satisfactorily identified, is as admissible in evidence as *552 the original itself in any judicial or administrative proceeding, whether the original is in existence or not____ 42 Pa.C.S. § 6109(b). The Commonwealth produced the testimony of the…”
Anderson v. Commonwealth, 497 A.2d 947 (Pa. Commw. Ct. 1985).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.