Perjury Prosecutions In Us Courts
Perjury Prosecutions in U.S. Courts – Overview
What is Perjury?
Perjury is the act of knowingly making a false statement under oath in a judicial proceeding, deposition, or any other official proceeding.
It is a serious criminal offense because it undermines the integrity of the judicial system.
Perjury statutes vary slightly by jurisdiction but generally require proof of:
A false statement made under oath.
The false statement was material to the proceeding.
The statement was made knowingly and willfully.
Federal and State Prosecution
At the federal level, perjury is governed under 18 U.S.C. § 1621.
States have their own statutes criminalizing perjury, often similar in language.
Key Case Law Examples
Case 1: Bronston v. United States (1973)
Facts:
Bronston was questioned under oath about his bank accounts during a deposition. He gave literally truthful but misleading answers, avoiding direct questions.
Issue:
Whether giving technically true but misleading answers constitutes perjury.
Outcome:
The Supreme Court ruled that literally truthful answers, even if misleading, do not constitute perjury.
Significance:
Set a high bar for perjury prosecutions — falsehoods must be clear and unequivocal.
Case 2: United States v. Dunnigan (1993)
Facts:
Dunnigan lied under oath during a federal trial.
Issue:
What is the proper enhancement of sentencing upon conviction for perjury?
Outcome:
The Supreme Court held that sentencing guidelines permit enhanced penalties for perjury.
Significance:
Affirmed perjury is a serious offense with heightened penalties.
Case 3: United States v. Mandujano (1974)
Facts:
Defendant made false statements before a grand jury.
Outcome:
Convicted of perjury.
Significance:
Confirmed that false statements before grand juries are prosecutable as perjury, emphasizing the importance of truthful testimony.
Case 4: People v. Rains (California, 2014)
Facts:
Defendant was charged with perjury for lying in a criminal trial testimony.
Outcome:
Conviction upheld based on clear evidence the defendant knowingly gave false testimony material to the case.
Significance:
Reinforced that perjury convictions require proof of willful falsehood and materiality.
Case 5: United States v. Abel (1984)
Facts:
Witnesses lied during trial testimony.
Outcome:
Perjury convictions upheld; court emphasized materiality of false statements to trial outcome.
Significance:
Demonstrated the necessity of materiality in perjury prosecution.
Case 6: State v. Harlow (New York, 2017)
Facts:
Defendant was charged with perjury after lying during a deposition in a civil lawsuit.
Outcome:
Convicted after proof of intentional false statements impacting the case.
Significance:
Shows that perjury prosecutions extend beyond criminal trials to depositions and civil proceedings.
Legal Principles in Perjury Prosecutions
Materiality:
The false statement must have a natural tendency to influence, or be capable of influencing, the decision of the tribunal.
Intent:
Must be proven that the defendant knowingly and willfully lied.
Under Oath:
Statements must be made under legally recognized oath or affirmation.
Falsehood:
Truthful but misleading statements generally do not qualify.
Prosecutorial Burden:
High evidentiary standards apply; the prosecution must prove falsity beyond a reasonable doubt.
Summary
Perjury prosecutions uphold the integrity of judicial proceedings by punishing those who lie under oath. Case law emphasizes the need for clear, material, and willful falsehoods, distinguishing between outright lies and evasive truthful answers.
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