Title 10. Evidence — Subtitle 1. Proof of Accounts and Records
Statutes in effect as of October 1, 2026.
Md. Code Ann., Cts. & Jud. Proc. § 10-101 (2026)
Title 10. Evidence
Subtitle 1. Proof of Accounts and Records
§ 10–101LinkCopy Citation
(a)
“Business” includes business, profession, and occupation of every kind.
(b)
A writing or record made in the regular course of business as a memorandum or record of an act, transaction, occurrence, or event is admissible to prove the act, transaction, occurrence, or event.
(c)
The practice of the business must be to make such written records of its acts at the time they are done or within a reasonable time afterwards.
(d)
The lack of personal knowledge of the maker of the written notice may be shown to affect the weight of the evidence but not its admissibility.
Md. Code Ann., Cts. & Jud. Proc. § 10-102 (2026)
Title 10. Evidence
Subtitle 1. Proof of Accounts and Records
§ 10–102LinkCopy Citation
(a)
If a business, institution, member of a profession or calling, or a department or agency of government, in the regular course of business or activity has kept or recorded a memorandum, writing, entry, print, representation, or a combination of them, of an act, transaction, occurrence, or event, and in the regular course of business has caused any or all of them to be recorded, copied, or reproduced by a photographic, photostatic, microfilm, microcard, miniature photographic, optical imaging, or other process which accurately reproduces or forms a durable medium for so reproducing the original, the original may be destroyed in the regular course of business unless its preservation is required by law. The reproduction, when satisfactorily identified, is as admissible in evidence as the original itself in a judicial or administrative proceeding whether the original is in existence or not and an enlargement or facsimile of the reproduction is likewise admissible in evidence if the original reproduction is in existence and available for inspection under direction of the court. The introduction of a reproduced record, enlargement, or facsimile does not preclude admission of the original.
(b)
This section shall be interpreted and construed to effectuate its general purpose of making uniform the law of those states which enact it.
(c)
This section may be cited as the Maryland Uniform Photographic Copies of Business and Public Records as Evidence Act.
Md. Code Ann., Cts. & Jud. Proc. § 10-103 (2026)
Title 10. Evidence
Subtitle 1. Proof of Accounts and Records
§ 10–103LinkCopy Citation
(a)
In this section the following words have the meanings indicated:
(1)
“Duplicate” means a counterpart produced by the same impression as the original, or from the same matrix, or by means of photography, including enlargements and miniatures, or by mechanical or electronic rerecording, or by chemical reproduction, or by other equivalent techniques which accurately reproduce the original.
(2)
(i)
“Original” of a writing means the writing itself or any counterpart intended to have the same effect by a person executing or issuing it.
(ii)
“Original” of a photograph includes the negative or any print therefrom.
(iii)
“Original” includes, if data is stored in a computer or similar device, any printout or other output readable by sight that reflects the data accurately.
(3)
“Photographs” include still photographs, X–ray films, video tapes, and motion pictures.
(4)
“Writing” means letters, words, or numbers, or their equivalent, set down by handwriting, typewriting, printing, photostating, photographing, magnetic impulse, mechanical or electronic recording, or other form of data compilation.
(b)
A duplicate is admissible in evidence to the same extent as an original unless:
(1)
A genuine question is raised as to the authenticity of the original; or
(2)
Under the circumstances, it would be unfair to admit the duplicate in lieu of the original.
Md. Code Ann., Cts. & Jud. Proc. § 10-104 (2026)
Title 10. Evidence
Subtitle 1. Proof of Accounts and Records
§ 10–104LinkCopy Citation
(a)
(1)
In this section the following terms have the meanings indicated.
(2)
“Health care provider” means:
(i)
A health care provider, as defined in § 3-2A-01 of this article;
(ii)
An ambulatory surgical facility;
(iii)
An inpatient facility that is organized primarily in the rehabilitation of disabled persons, through an integrated program of medical and other service provided under competent professional supervision;
(iv)
A home health agency, as defined in § 19-401 of the Health - General Article;
(v)
Any health institution, service, or program for which a certificate of need is required under Title 19 of the Health - General Article; or
(vi)
A person who is:
(1)
Substantially similar to a health care provider described in items (i) through (v) of this paragraph; and
(2)
Regulated by another state to provide health care services.
(3)
“State” means a state of the United States or the District of Columbia.
(b)
(1)
The provisions of this section apply only to a claim for:
(i)
Damages for personal injury;
(ii)
Medical, hospital, or disability benefits under §§ 19-505 and 19-506 of the Insurance Article;
(iii)
First party motor vehicle benefits under §§ 19-509 and 19-510 of the Insurance Article; and
(iv)
First party health insurance benefits.
(2)
This section does not apply to an action for damages filed under Title 3, Subtitle 2A of this article.
(3)
Subject to the provisions of paragraphs (1) and (2) of this subsection, the provisions of this section apply to a proceeding in:
(i)
The District Court; or
(ii)
A circuit court if the amount in controversy in the action in the circuit court does not exceed the amount specified in § 4-401 of this article for that type of action.
(c)
(1)
A writing or record of a health care provider described in this section is admissible under this section if:
(i)
The writing or record is offered in the trial of a civil action in the District Court or a circuit court;
(ii)
At least 60 days, except as provided in paragraph (2) of this subsection, before the beginning of the trial, the party who intends to introduce the writing or record:
(1)
Serves notice of the party’s intent to introduce the writing or record without the support of a health care provider’s testimony, a list that identifies each writing or record, and a copy of the writing or record on all other parties as provided under Maryland Rule 1-321; and
(2)
Files notice of service and the list that identifies each writing or record with the court; and
(iii)
The writing or record is otherwise admissible.
(2)
A party who receives a notice under paragraph (1) of this subsection and intends to introduce another writing or record of a health care provider without a health care provider’s testimony shall:
(i)
Serve a notice of intent, a list that identifies each writing or record, and a copy of the writing or record at least 30 days before the beginning of the trial; and
(ii)
File notice of service and the list that identifies each writing or record with the court.
(3)
The list required under paragraphs (1) and (2) of this subsection shall include:
(i)
The name of the health care provider for each writing or record; and
(ii)
The date of each writing or record of the health care provider or each date of treatment by the health care provider.
(d)
(1)
A writing or record of a health care provider made to document a medical, dental, or other health condition, a health care provider’s opinion, or the providing of health care is admissible without the support of the testimony of a health care provider as the maker or the custodian of the writing or record as evidence of the existence of a medical, dental, or health condition, the opinion, and the necessity and the providing of health care.
(2)
A finder of fact may attach whatever weight to a writing or record that the finder of fact deems appropriate.
(e)
(1)
A written statement or bill for health care expenses is admissible without the support of the testimony of a health care provider as the maker or the custodian of the statement or bill as evidence of the amount, fairness, and reasonableness of the charges for the services or materials provided.
(2)
A finder of fact may attach whatever weight to a writing or record that the finder of fact deems appropriate.
(f)
Nothing contained in this section may be construed to limit the right of a party to:
(1)
Request a summons to compel the attendance of a witness;
(2)
Examine a witness who appears at trial; or
(3)
Engage in discovery as provided under the Maryland Rules.
Md. Code Ann., Cts. & Jud. Proc. § 10-105 (2026)
Title 10. Evidence
Subtitle 1. Proof of Accounts and Records
§ 10–105LinkCopy Citation
(a)
The provisions of this section apply to a civil action in:
(1)
The District Court; or
(2)
A circuit court if the amount in controversy in the action in the circuit court does not exceed the amount specified in § 4-401 of this article for that type of action.
(b)
(1)
(i)
Subject to the provisions of this section, a paid bill for goods or services is admissible without the testimony of the provider of the goods or services as evidence of the authenticity of the bill for goods or services provided and the fairness and reasonableness of the charges of the provider of the goods or services.
(ii)
A finder of fact may attach whatever weight to a paid bill that the finder of fact deems appropriate.
(2)
The bill shall be admitted on testimony, by the party or any other person with personal knowledge:
(i)
Identifying the original bill or an authenticated copy; and
(ii)
(1)
Identifying the provider of the goods or services;
(2)
Explaining the circumstances surrounding the receipt of the bill;
(3)
Describing the goods or services provided;
(4)
Stating that the goods or services were provided in connection with the event giving rise to the action; and
(5)
Stating that the bill was paid.
(c)
(1)
Subsection (b) of this section applies only if, at least 60 days before the beginning of the trial, the party who intends to introduce the bill:
(i)
Serves notice of the party’s intent to introduce the bill without the support of the testimony of the provider of the goods or services that were billed, a list that identifies each bill, and a copy of the bill on all other parties as provided under Maryland Rule 1-321; and
(ii)
Files notice of service and the list that identifies each bill with the court.
(2)
The list required under paragraph (1) of this subsection shall include:
(i)
The name of the provider of the goods and services for each bill; and
(ii)
The date of each bill of the provider of the goods and services.
(d)
Nothing contained in this section may be construed to:
(1)
Apply to proof of the existence of a medical, dental, or other health condition, the opinion of a health care provider, or the necessity and the providing of medical, dental, or other health care;
(2)
Limit the provisions of § 10-104 of this subtitle concerning the admissibility of a medical, dental, hospital, or other health care writing or record; or
(3)
Limit the right of a party to:
(i)
Request a summons to compel the attendance of a witness;
(ii)
Examine a witness who appears at trial; or
(iii)
Engage in discovery as provided under the Maryland Rules.