United States v. Harris
Headline: Ruling allows prosecutors to charge witnesses with perjury for falsely denying earlier statements to investigators, reversing a trial judge and letting criminal perjury prosecutions proceed against grand jury witnesses.
Holding: The Court reversed the trial judge and held that a witness who falsely denies having told government agents about prior conversations can be charged with perjury because such denials are material and punishable under the perjury statute.
- Allows prosecutors to charge witnesses with perjury for denying prior statements to investigators.
- Makes testimony denials to grand juries more legally risky for witnesses.
- Permits criminal cases to proceed when witnesses contradict earlier statements to agents.
Summary
Background
Two women who had been questioned by government agents about earlier conversations were asked before a grand jury in 1937 whether they had made those statements. They answered no, and the grand jury then returned indictments charging that their sworn denials were false and therefore perjury under the federal perjury statute. The trial judge quashed the indictments, believing that prior inconsistent or contradictory statements could not form the basis for perjury charges.
Reasoning
The Court considered whether the indictments properly charged perjury when they alleged that the witnesses swore falsely that they had never told government agents about the conversations. The Court concluded the indictments did charge an offense: proof that the witnesses had in fact told the agents would be direct evidence of the alleged false sworn denials, not merely impeachment evidence. The Court explained that the statute makes no distinction between false statements denying prior statements and other false factual assertions, and such denials can be material to an investigation.
Real world impact
The decision reverses the orders that quashed the indictments and sends the cases back so prosecutions may proceed. People who testify before grand juries or to investigators face greater risk of perjury charges if they falsely deny prior statements. The ruling does not determine guilt; it only allows the criminal cases to go forward under the perjury statute.
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