Pennsylvania Consolidated Statutes

42 Pa. Cons. Stat. § 6111 (2026)

  Handwriting.

✓ current as of May 2026
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§ 6111.  Handwriting.

(a)  Opinion evidence as to handwriting.--Where there is a question as to any writing, the opinions of the following persons shall be deemed to be relevant:

(1)  The opinion of any person acquainted with the handwriting of the supposed writer.

(2)  The opinion of those who have had special experience with, or who have pursued special studies relating to, documents, handwriting, and alterations thereof, who are called experts in this section.

(b)  Comparison of handwriting.--It shall be competent for experts in giving their testimony, under the provisions of this section, to make comparison of documents and comparison of disputed handwriting with any documents or writing admitted to be genuine, or proven to the satisfaction of the judge to be genuine, and the evidence of such experts respecting the same shall be submitted to the jury as evidence of the genuineness or otherwise of the writing in dispute.

(c)  Comparison of signatures.--It shall be competent for experts in formulating their opinions to the court and jury to place the genuine and disputed signatures or writing in juxtaposition, and to draw the attention of the jury thereto; and it shall furthermore be competent for counsel to require of an expert a statement of the principles on which he has based his work, the details of his work, and his opinion that the results are important to the point at issue, or the reasoning, analysis and investigation by which he has arrived at his opinion.

(d)  Jury question.--The opinions of the witnesses to handwriting being submitted as competent testimony to the jury, the final determination as to whether any particular handwriting is genuine or simulated shall remain, as heretofore, a question for the jury on all the evidence submitted.

Notes of Decisions
Cited in 14 cases (1 in the last 5 years), 1980–2023 · leading case: Commonwealth v. Wholaver, E., Aplt., 177 A.3d 136 (Pa. 2018).
Commonwealth v. Wholaver, E., Aplt., 177 A.3d 136 (Pa. 2018). · cites it 4× “Concerning the court’s application of the ■rule of evidence found at 42 Pa.C.S. § 6111, Appellant simply comments, “Regardless of Jackson’s years of training and experience, the discipline in which she was trained and in which she practices lacks the hallmarks of scientific…”
In Re: Adoption of: L.B.M., A Minor, 161 A.3d 172 (Pa. 2017). · cites it 2× “” Had the General Assembly believed that an attorney representing both best and legal interests of the child would be sufficient to protect all of a child’s interests, it certainly could have imported language into the Adoption Act similar to that utilized in the dependency…”
Mishoe v. Erie Ins., 824 A.2d 1153 (Pa. 2003). · cites it 2× “"); 42 Pa.C.S. § 6111(c) ("It shall be competent for experts in formulating their opinions to the court and jury to place the genuine and disputed signatures or writing in juxtaposition.”
Gregury, J. v. Greguras, S., 196 A.3d 619 (Pa. Super. Ct. 2018). “42 Pa.C.S. § 6111(1). Rule 901(b) provides that "[a] non[-]expert's opinion that handwriting is genuine, based on a familiarity with it that was not acquired for the current litigation," is competent evidence.”
In Re: Adoption of: A.D.M., A Minor, 156 A.3d 1159 (Pa. 2017). · cites it 2× “” Had the General Assembly believed that an attorney representing both best and legal interests of the child would be sufficient to protect all of a child’s interests, it certainly could have imported language into the Adoption Act similar to that utilized in the dependency…”
Makris v. Bureau of Prof'l & Occupational Affairs, 599 A.2d 279 (Pa. Commw. Ct. 1991). “42 Pa.C.S. § 6111. Makris made no attempt to introduce any opinion testimony comparing the items to authenticate the initials on the form.”
Hamilton v. Pa. State Emps. Ret. Bd., 194 A.3d 1147 (Pa. Commw. Ct. 2018). “42 Pa.C.S. § 6111(a) - (d). Section 6111(a) makes clear that both lay and expert testimony are relevant and admissible in a case where a person's handwriting is called into question.”
Morgan v. First Pennsylvania Bank, 541 A.2d 380 (Pa. Super. Ct. 1988). · cites it 2× “3 Subsection (d) of 42 Pa.C.S. § 6111 leaves to the trier of fact, in this case the hearing judge, the determination of the genuineness of a *415 signature.”
In re Est. of Ciaffoni, 417 A.2d 1136 (Pa. 1980). “It is clear from this Court’s decision in Kane’s Estate that the comparison evidence was considered probative and material, as we held that evidence sufficient to support the Chancellor’s findings.”
Maley, J. v. Shell W. Expl. (Pa. Super. Ct. 2018). · cites it 3× “, 42 Pa.C.S. § 6111. ____________________________________________ 12 In Crompton Greaves, the district court explained as follows: Because a contract is not hearsay, to be admissible it need only be authenticated.”
In Re: Order Approving the Amendment of Pa Rules of Evidence 901(a), 902(4), 902(6) & 902(12) (Pa. 2019). · cites it 2× “It is consistent with 42 Pa.C.S. § 6111, which also deals with the admissibility of handwriting.”
In Re: Order Approving the Amendment of Pa Rule of Evidence 901 (Pa. 2020). · cites it 2× “It is consistent with 42 Pa.C.S. § 6111, which also deals with the admissibility of handwriting.”
— 42 Pa. Cons. Stat. § 6111(1) — 1 case
Gregury, J. v. Greguras, S., 196 A.3d 619 (Pa. Super. Ct. 2018). “42 Pa.C.S. § 6111(1). Rule 901(b) provides that "[a] non[-]expert's opinion that handwriting is genuine, based on a familiarity with it that was not acquired for the current litigation," is competent evidence.”
— 42 Pa. Cons. Stat. § 6111(a) — 2 cases
Commonwealth v. Wholaver, E., Aplt., 177 A.3d 136 (Pa. 2018). “Concerning the court’s application of the ■rule of evidence found at 42 Pa.C.S. § 6111, Appellant simply comments, “Regardless of Jackson’s years of training and experience, the discipline in which she was trained and in which she practices lacks the hallmarks of scientific…”
Hamilton v. Pa. State Emps. Ret. Bd., 194 A.3d 1147 (Pa. Commw. Ct. 2018). “42 Pa.C.S. § 6111(a) - (d). Section 6111(a) makes clear that both lay and expert testimony are relevant and admissible in a case where a person's handwriting is called into question.”
— 42 Pa. Cons. Stat. § 6111(a)(1) — 1 case
Com. v. Williams, K. (Pa. Super. Ct. 2023).
— 42 Pa. Cons. Stat. § 6111(a)(2) — 1 case
Commonwealth v. Wholaver, E., Aplt., 177 A.3d 136 (Pa. 2018). “Concerning the court’s application of the ■rule of evidence found at 42 Pa.C.S. § 6111, Appellant simply comments, “Regardless of Jackson’s years of training and experience, the discipline in which she was trained and in which she practices lacks the hallmarks of scientific…”
— 42 Pa. Cons. Stat. § 6111(b) — 1 case
Maley, J. v. Shell W. Expl. (Pa. Super. Ct. 2018). “, 42 Pa.C.S. § 6111. ____________________________________________ 12 In Crompton Greaves, the district court explained as follows: Because a contract is not hearsay, to be admissible it need only be authenticated.”
— 42 Pa. Cons. Stat. § 6111(b)(9) — 2 cases
In Re: Adoption of: L.B.M., A Minor, 161 A.3d 172 (Pa. 2017). “” Had the General Assembly believed that an attorney representing both best and legal interests of the child would be sufficient to protect all of a child’s interests, it certainly could have imported language into the Adoption Act similar to that utilized in the dependency…”
In Re: Adoption of: A.D.M., A Minor, 156 A.3d 1159 (Pa. 2017). “” Had the General Assembly believed that an attorney representing both best and legal interests of the child would be sufficient to protect all of a child’s interests, it certainly could have imported language into the Adoption Act similar to that utilized in the dependency…”
— 42 Pa. Cons. Stat. § 6111(c) — 1 case
Mishoe v. Erie Ins., 824 A.2d 1153 (Pa. 2003). “"); 42 Pa.C.S. § 6111(c) ("It shall be competent for experts in formulating their opinions to the court and jury to place the genuine and disputed signatures or writing in juxtaposition.”
— 42 Pa. Cons. Stat. § 6111(d) — 1 case
Com. v. Frey, R. (Pa. Super. Ct. 2014).
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