Ramos v. Pennsylvania Board of Probation and Parole

Ramos v. Pennsylvania Board of Probation and Parole, 954 A.2d 107 (Pa. Cmwlth. 2008) involved a five-month gap in time between the parole agent's request and receipt of parolee's conviction records. The Board found, as fact, that the parole agent had attempted on three occasions to obtain the official verification within that five-month period, which finding was based upon the parole agent's written notes in the record. The Court held in Ramos that the Board's factual finding was made in error because it could not take judicial notice of the parole agent's notes, as it purported to do in its adjudication.