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Perjury

PERJURY

The American legal system, like most legal systems, relies heavily on the testimony of witnesses. Juries rely on witness testimony to reach verdicts in criminal and civil trials; grand juries rely on witness testimony to investigate crimes and to bring criminal charges; Congress relies on witness testimony in its legislative hearings; and a wide range of administrative agencies rely on witness testimony in making both policy decisions and rulings in specific matters. The decisions of each of these bodies are only as reliable as the witnesses appearing before them. The law making perjury a crime is one effort to encourage witnesses to be truthful.

Perjury at common law

Although false swearing or "bearing false witness" has been considered a spiritual offense since at least biblical times, perjury did not become a secular crime in England until much more recently. In the Middle Ages, witnesses as we know them did not exist. The witnesses were the jurors, and so it was the verdict, not a particular witness, that was either true or false. Correspondingly, it was the jurors, not the witnesses, who would be punished for a "false" or "perjurious" verdict. By the sixteenth century, when the modern trial by an independent and impartial jury began to emerge, perjury by witnesses also came to be punished separately, first by the Court of Star Chamber and later by English common law courts. By the mid-seventeenth century, common law perjury was defined as swearing falsely, under oath, in a judicial proceeding, about a material issue. This same definition of perjury was generally incorporated into early American common law and statutes.

Modern perjury statutes

Each of the fifty states has its own perjury statute, and federal law contains two general perjury provisions (18 U.S.C. §§ 1621, 1623). Although differences abound among these statutes, most modern perjury statutes have four elements: (1) the statement must be made under oath; (2) the statement must be false; (3) the speaker must intend to make a false statement; and (4) the statement must be material to the proceeding. Each element must be proven by the prosecution beyond a reasonable doubt.

Oath. The oath may take many different forms, so long as it contains a solemn declaration to tell the truth. It must, however, be administered by a person legally authorized to do so and in a setting in which the oath is authorized to be administered. The oath can apply both to oral testimony and to written declarations made under the penalties of perjury.

Falsity. To be perjurious, a statement made under oath must be false. Thus, a perjury conviction cannot be based upon a statement that is so vague or ambiguous that it cannot be considered affirmatively false. Similarly, as the Supreme Court held in Bronston v. United States, (409 U.S. 352 (1973)), a statement that is misleading, but not actually false, cannot lead to a perjury conviction. In that case, the defendant Bronston had testified under oath in a bankruptcy hearing, during which he was asked whether he had ever had any Swiss bank accounts. Bronston responded that his company had once had a Swiss bank account. Although Bronston's response was literally true, it was misleading because it suggested that Bronston had not had a personal Swiss bank account, which he had. The Supreme Court nevertheless held that Bronston could not be prosecuted for perjury because his answer, even if deliberately deceptive, was not actually false. While the Court did not condone Bronston's misleading testimony, it reasoned that it was the questioner's responsibility to ensure that Bronston's answers were not ambiguous or non-responsive.

Intent. To be guilty of perjury, a defendant must do more than make a false statement under oath. The defendant must also intend to do so. Sometimes referred to as "scienter," this intent requirement is expressed in various ways. The federal perjury statutes require the false statement to be made "willfully" or "knowingly." Other state statutes require the statement to be made with an intent to mislead or with a belief that the statement was untrue. The intent requirement means that an "honest mistake" or an unknowing falsehood cannot be perjurious.

Materiality. The final element of most perjury statutes is the requirement that the false statement be "material" to the proceeding in which it is made. To be material, a statement must have the tendency or capacity to influence the court or other body before which the statement is made. Materiality is a broad concept, and a statement will be considered material not only if it directly relates to the matters at issue in the proceeding, but also if it could lead to the discovery of other relevant evidence or if it could enhance (or detract from) the credibility of a witness.

Materiality was traditionally considered to be an issue of law to be decided by the judge presiding over a perjury prosecution. In 1995, however, in addressing the related crime of making an unsworn false statement, the Supreme Court ruled that the materiality of a false statement was an issue for the jury. Shortly thereafter, the Supreme Court applied the same reasoning to the materiality element in perjury prosecutions. Thus, as with the other elements of the crime, the materiality element in a perjury case must be proven by the prosecution to the jury beyond a reasonable doubt.

Perjury prosecutions

Perjurious testimony or declarations can be given in a wide variety of contexts. Perjury prosecutions, however, most often result from false testimony given in a criminal trial or before a grand jury. Less frequently, a perjury prosecution will be based on false testimony given in a civil trial. In rare cases, false testimony in a civil deposition can lead to a perjury prosecution. Under federal law and in most states, perjury is a felony.

In many cases, perjury charges are brought when a prosecution for other criminal conduct is not possiblefor example, when the defendant has already been acquitted of the other criminal conduct, or the statute of limitations on that conduct has expired, or there simply is not enough evidence of the other criminal conduct. The perjury conviction of Alger Hiss in 1950 is perhaps the most famous modern example of such a prosecution. Although Hiss was never charged with spying, he was prosecuted for perjury for lying to the federal grand jury that was investigating the spying allegations.

Related offenses

Subornation. Willfully procuring another person to commit perjury was traditionally considered to be a separate offense called subornation of perjury. This separate offense is largely superfluous, however, because one who causes or induces another to commit a crime is punishable under general principles of accomplice liability or solicitation. Although some states and the federal government still recognize subornation as a separate offense, the Model Penal Code recommends that the separate offense be eliminated.

False statement. Federal law (18 U.S.C. § 1001) makes it a crime to make a false statement to the government. The elements of this offense are substantially similar to the elements of perjury. The statement must be false, it must be made "knowingly and willfully," and it must be material. Unlike with perjury, the statement need not be made under oath; however, it must be made in a matter within the jurisdiction of the executive, legislative, or judicial branches of the federal government. The jurisdictional element is construed broadly and includes not only false statements made directly to the government (for example, statements to an F.B.I. agent about an ongoing investigation), but also false statements made indirectly to the government (for example, statements to a defense contractor that will be relied upon by the government).

A few states have enacted general laws against making false statements to public officials or agencies, but most of those laws are limited to written statements, and some require that the statement be made after written notice that a false statement is punishable as a crime.

Michael A. Simons

See also Counsel: Role of Counsel; Jury: Legal Aspects; Obstruction of Justice.

BIBLIOGRAPHY

American Law Institute. Model Penal Code and Commentaries: Official Draft and Revised Comments, part 2, article 241. Philadelphia: ALI, 1980.

Blackstone, William. Commentaries on the Laws of England, vol. 4. Oxford, U.K.: Clarendon Press, 1769. Reprint, New York: Oceana,1966.

Fitzpatrick, Bridget, and Torraco, John. "False Statements." American Criminal Law Review 36 (Summer 1999): 607627.

Gordon, Michael D. "The Invention of a Common Law Crime: Perjury and the Elizabethan Courts." The American Journal of Legal History 24 (1980): 145170.

Holdsworth, William. A History of English Law, vol. 4. 3d ed. London: Methuen, 1977.

Kislak, Rebecca, and Donoghue, John J. "Perjury." American Criminal Law Review 36 (1999): 957982.

Nesland, James, and Godward, Cooley. "Perjury and False Declarations." In Otto G. Obermaier and Robert G. Morvillo, eds., White Collar Crime: Business and Regulatory Offenses. New York: Law Journal Seminars-Press, 1990. Pages 101 to 1081.

Perkins, Rollin M., and Boyce, Ronald N. Criminal Law, 3d ed. Mineola, N.Y.: Foundation Press, 1982.

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Perjury

PERJURY

A crime that occurs when an individual willfully makes a false statement during a judicial proceeding, after he or she has taken an oath to speak the truth.

The common-law crime of perjury is now governed by both state and federal laws. In addition, the model penal code, which has been adopted in some form by many states and promulgated by the Commission on Uniform State Laws, also sets forth the following basic elements for the crime of perjury: (1) a false statement is made under oath or equivalent affirmation during a judicial proceeding; (2) the statement must be material or relevant to the proceeding; and (3) the witness must have the specific intent to deceive.

The punishment for perjury in most states, and under federal law, is the imposition of a fine, imprisonment, or both. Federal law also imposes sentencing enhancements when the court determines that a defendant has falsely testified on her own behalf and is convicted. Under the Federal Sentencing Guidelines, the court is required to automatically increase the defendant's sentence.

Two federal statutes govern the crime of perjury in federal proceedings. Title 18 U.S.C.A. § 1621 codifies the common law of perjury and consists of the elements listed above. In 1970, the scope of section 1621 was expanded by the enactment of 18 U.S.C.A. § 1623. Section 1623 changes the definition of intent from willfully offering false testimony to merely having knowledge that the testimony is false. In addition it adds to the definition of perjury to include the witness's use of information, including any book, paper, document, record, recording, or other material she knows contains a false material declaration, and includes proceedings that are ancillary to any court, such as affidavits and depositions, and grand jury proceedings. Section 1623 also contains a retraction defense. If, during the proceeding in which the false statement was made, the person admits to the falsity of the statement before it is evident that the falsity has been or will be exposed, and as long as the falsity does not affect the proceeding substantially, prosecution will be barred under section 1623.

Commentators believe that the existence of these two federal statutes actually frustrates the goals of Congress to encourage truthful statements. The reasoning behind this concern is that when a retraction exists, prosecutors may charge a witness with perjury under section 1621 and when a retraction does not exist, the witness may be charged under section 1623.

Two variations of perjury are subornation of perjury and false swearing; in many states these two variations are separate offenses. Subornation of perjury is a crime in which the defendant does not actually testify falsely but instead induces, persuades, instigates, or in some way procures another witness to commit perjury. False swearing is a false statement made under oath but not made during an official proceeding. Some states have created a separate offense for false swearing, while others have enacted perjury statutes to include this type of false statement. These crimes also may be punished by the imposition of a fine, imprisonment, or both.

further readings

Aycock, George W. III. 1993."Nothing But the Truth: A Solution to the Current Inadequacies of the Federal Perjury Statutes." Valparaiso Law Review 28.

Curriden, Mark. 1995. "The Lies Have It." ABA Journal 81.

Feinstein, Ami L. 1993. "United States v. Dunnigan and Sentence Enhancements for Perjury: Constitutional Perhaps, but Unnecessary in Fact." American Criminal Law Review 31.

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perjury

perjury (pûr´jərē), in criminal law, the act of willfully and knowingly stating a falsehood under oath or under affirmation in judicial or administrative proceedings. If the person accused of perjury had any probable cause for his belief that the statement he made was true, then he is not guilty of perjury. In U.S. federal law, and in most states, a false statement must be material to a point of inquiry in order to constitute perjury. Perjury is a crime and may be punished by fine or imprisonment. One can retract false testimony in the course of a criminal procedure without committing perjury. The crime of inducing another person to commit perjury is called subornation of perjury.

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Perjury

499. Perjury (See also Deceit.)

  1. Hiss, Alger (1904) imprisoned for perjury during espionage hearings. [Am. Hist.: NCE, 1247]
  2. Oakes rancher, remembered for his untrustworthy court testimony. [Australian Hist.: Brewer Dictionary, 771]
  3. Philip, King worships tickling Commodity; perjures himself. [Br. Lit.: King John ]

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perjury

per·ju·ry / ˈpərjərē/ • n. (pl. -ries) Law the offense of willfully telling an untruth in a court after having taken an oath or affirmation. DERIVATIVES: per·ju·ri·ous / pərˈjoŏrēəs/ adj.

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perjury

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