Weiler v. United States

Background

A man was later tried for perjury after he had testified in a prior government hearing about a purchase of automobile tires. In that earlier proceeding he denied buying or possessing the tires and said he only lent money and signed a notarized letter as an accommodation. He was later indicted for saying something false under oath. At the perjury trial he repeated his account, the Government produced several witnesses the jury could credit as showing he was the buyer, and the defendant asked the judge to tell the jury that perjury convictions require corroboration beyond a single witness.

Reasoning

The Court addressed two questions: whether the old rule barring conviction on one uncorroborated witness should be abandoned, and whether a judge must instruct the jury about that rule when asked. The Court refused to discard the long-established rule and explained that it protects witnesses and fits long practice. The Court also held that a judge must, when requested, tell the jury that more than one witness or corroborating circumstances are required, because the jury — not the judge — must decide the trustworthiness of supporting evidence.

Real world impact

Because the trial judge refused the requested instruction, the Court reversed the conviction. The opinion makes clear that perjury prosecutions cannot rest solely on an oath-against-an-oath unless the jury is properly instructed about corroboration. The decision leaves the rule intact and requires trial judges to give requested instructions about corroboration so juries can make informed credibility judgments.