Falasco v. Pennsylvania Board of Probation and Parole

In Falasco v. Pennsylvania Board of Probation and Parole, 104 Pa. Commw. 321, 521 A.2d 991 (Pa. Cmwlth. 1987), the Court explained: "Official notice" is the administrative counterpart of judicial notice and is the most significant exception to the exclusiveness of the record principle. The doctrine allows an agency to take official notice of facts which are obvious and notorious to an expert in the agency's field and those facts contained in reports and records in the agency's files, in addition to those facts which are obvious and notorious to the average person. Thus, official notice is a broader doctrine than is judicial notice and recognizes the special competence of the administrative agency in its particular field and also recognizes that the agency is a storehouse of information on that field consisting of reports, case files, statistics and other data relevant to its work. See FCC v. National Citizens Committee for Broadcasting, 436 U.S. 775, 98 S.Ct. 2096, 56 L.Ed.2d 697 (1978); NLRB v. Seven-Up Bottling Co., 344 U.S. 344, 73 S.Ct. 287, 97 L.Ed. 377 (1953); Department of State v. Stecher, 506 Pa. 203, 484 A.2d 755 (1984); see generally K. Davis, Administrative Law Treatise 15.1-15.20 (1980); Schwartz, Administrative Law 128 (1976); cf. 5 U.S.C. 556(e). Falasco, 521 A.2d at 995, n. 6.