Hanson v. Commonwealth
In Hanson v. Commonwealth, 14 Va. App. 173, 416 S.E.2d 14 (Va.App. 1992), the issue was whether the postmark on an envelope was admissible to prove the date upon which it was affixed. Hanson, 416 S.E.2d at 20.
The court held that "although a postmark is within the traditional definition of hearsay, it is admissible as an exception to the hearsay rule when used to prove the date on which the postal service affixed its postmark in the regular course of business." Hanson, 416 S.E.2d at 21.
The Virginia court held that using the postmark to prove the day upon which it was affixed is hearsay, admissible under the public records and business records exceptions to the hearsay rule. Id.