VA Code 8.01-390(A) Interpretation
In Ingram v. Commonwealth, 1 Va. App. 335, 340, 338 S.E.2d 657, 659 (1986), in considering the authentication requirements of Code 8.01-390(A), the Court construed the requirement that a copy of an official document be authenticated by both the record's custodian and the person to whom the custodian reports. We held as follows:
To comply with the statute double authentication is necessary to prove genuineness as a prerequisite to admission of a copy.
Proper authentication under this statute requires not only certification of the copy as a true copy by the custodian of the record and the person to whom he reports, but also a showing that the persons certifying are indeed the custodian and the person to whom he reports.
The latter requirement is crucial to admission into evidence of those documents governed by Code 8.01-390.
The statute addresses the admission of all nonjudicial records as evidence; without double authentication, a court presented with a document from a source with which it is unfamiliar would have no means of judging its genuineness. 1 Va. App. at 340, 338 S.E.2d at 659-60.