Proposed Jury Instructions for Perjury
NOTICE TO COUNSEL AND JUDGES: As provided in the Court's Order accepting the proposed jury instructions for a period of working review, the Court's provisional approval "is for the purpose of refining and testing the application and accuracy of the pattern instructions and does not ensure error-free trials, and their use does not carry a no-reversal guarantee. It is not intended that this provisional acceptance is a final approval of the content of any instruction and each judge may use or refuse any instruction as he or she sees fit[,]" according to law. (emphasis added).
6. of ______________________________ who was then
tried in that Court,
7. upon the charge of __________________________,
8. which charge was at that time a felony offense,
9. which testimony the Defendant ______________________________
knew was false,
10. and that the Defendant ______________________________
wilfully and absolutely testified falsely,
11. and that the Defendant ______________________________
at the time he so testified was under (an oath) (an affirmation) to speak the
truth,
12. which (oath) (affirmation) was lawfully administered
by ________________________ to the Defendant ______________________________,
13. that ______________________________ was the ([deputy]
Clerk of the Circuit Court) (Judge of the Circuit Court) and as such had competent
authority under law to administer such (oath) (affirmation),
14. that in such felony trial the said testimony of
the Defendant ______________________________ was as to a material (matter) (thing).
If after impartially considering, weighing and comparing
all the evidence, (both that of the State and that of the Defendant) the jury
and each member of the jury is convinced beyond a reasonable doubt of the truth
of the charge as to each of these elements of Perjury, you may find ______________________________
guilty of Perjury as charged. If the jury and each member of the jury has a
reasonable doubt of the truth of the charge as to any one or more of these elements
of Perjury, you shall find the Defendant ______________________________ not
guilty.
3. on or about the _____ day of ________________,
199__,
4. did testify falsely on a material matter as follows,
to-wit: ______________________ _______________________________________________________________________
5. in a trial in the Circuit Court of _______________
County,
6. of ______________________________ who was then tried
in that Court,
7. upon the charge of __________________________,
8. which charge was at that time a felony offense,
9. which testimony the Defendant ______________________________
knew was false,
10. and that the Defendant ______________________________
wilfully and absolutely testified falsely,
11. and that the Defendant ______________________________
at the time he so testified was under (an oath) (an affirmation) to speak the
truth,
12. which (oath) (affirmation) was lawfully administered
by ________________________ to the Defendant ______________________________,
13. that ______________________________ was the ([deputy]
Clerk of the Circuit Court) (Judge of the Circuit Court) and as such had competent
authority under law to administer such (oath) (affirmation),
14. that in such felony trial the said testimony of
the Defendant ______________________________ was as to a material (matter) (thing).
If after impartially considering, weighing and comparing
all the evidence, (both that of the State and that of the Defendant) the jury
and each member of the jury is convinced beyond a reasonable doubt of the truth
of the charge as to each of these elements of Perjury, you may find ______________________________
guilty of Perjury as charged. If the jury and each member of the jury has a
reasonable doubt of the truth of the charge as to any one or more of these elements
of Perjury, you shall find the Defendant ______________________________ not
guilty (and deliberate the lesser included offense as hereinafter instructed).
Before the Defendant, ______________________________
can be convicted of False Swearing, the State of West Virginia must overcome
the presumption that the Defendant, ______________________________ is innocent
and prove to the satisfaction of the jury beyond a reasonable doubt that:
1. The Defendant, ______________________________,
2. in __________________ County, West Virginia,
3. on or about the _____ day of ________________, 199__,
4. did testify falsely as follows, to-wit: ____________________
______________________________________________________________________ ___________________________________________________________,
5. in a trial in the Circuit Court of _______________
County,
6. of ______________________________ who was then tried
in that Court,
7. upon the charge of __________________________,
8. which charge was at that time a felony offense,
9. which testimony the Defendant ______________________________
knew was false,
10. and that the Defendant ______________________________
wilfully and absolutely testified falsely,
11. and that the Defendant ______________________________
at the time he so testified was under (an oath) (an affirmation) to speak the
truth,
12. which (oath) (affirmation) was lawfully administered
by ______________________ to the Defendant ______________________________,
13. that ______________________________ was the ([Deputy]
Clerk of the Circuit Court) (Judge of the Circuit Court) and as such had competent
authority under law to administer such (oath) (affirmation).
If after impartially considering, weighing and comparing
all the evidence, (both that of the State and that of the Defendant) the jury
and each member of the jury is convinced beyond a reasonable doubt of the truth
of the charge as to each of these elements of False Swearing, you may find ______________________________
guilty of False Swearing as charged. If the jury and each member of the jury
has a reasonable doubt of the truth of the charge as to any one or more of these
elements of False Swearing, you shall find the Defendant ______________________________
not guilty.
6. of ______________________________ who was then
tried in that Court,
7. upon the charge of __________________________,
8. which charge was at that time a felony offense,
9. which testimony the Defendant ______________________________
knew was false,
10. and that the Defendant ______________________________
wilfully and absolutely testified falsely,
11. and that the Defendant ______________________________
at the time he so testified was under (an oath) (an affirmation) to speak the
truth,
12. which (oath) (affirmation) was lawfully administered
by ___________________________ to the Defendant ______________________________,
13. that ______________________________ was the ([Deputy]
Clerk of the Circuit Court) (Judge of the Circuit Court) and as such had competent
authority under law to administer such (oath) (affirmation).
If after impartially considering, weighing and comparing
all the evidence, (both that of the State and that of the Defendant) the jury
and each member of the jury is convinced beyond a reasonable doubt of the truth
of the charge as to each of these elements of False Swearing, you may find ______________________________
guilty of False Swearing as charged. If the jury and each member of the jury
has a reasonable doubt of the truth of the charge as to any one or more of these
elements of False Swearing, you shall find the Defendant ______________________________
not guilty.
4. did intentionally and wilfully procure and induce
______________________________ a witness, to commit false swearing and testify
falsely to-wit:_________________ ____________________________________________________________________,
and,
5. which testimony occurred in a trial in the Circuit
Court of _______________ County,
6. of ______________________________ who was then tried
in that Court,
7. upon the charge of __________________________,
8. which charge was at that time a felony offense,
9. that such testimony was false,
10. and that the witness ______________________________
knew that such testimony was false,
11. and that the witness ______________________________
wilfully, knowingly and absolutely testified falsely,
12. and that the witness ______________________________
at the time he so testified was under (an oath) (an affirmation) to speak the
truth,
13. which (oath) (affirmation) was lawfully administered
by ______________________________ to the witness ______________________________,
14. that ______________________________ was the ([deputy]
Clerk of the Circuit Court) (Judge of the Circuit Court) and as such had competent
authority under law to administer such (oath) (affirmation),
15. that in such felony trial the said testimony of
the witness ______________________________ was as to a non-material matter.
If after impartially considering, weighing and comparing
all the evidence, (both that of the State and that of the Defendant) the jury
and each member of the jury is convinced beyond a reasonable doubt of the truth
of the charge as to each of these elements of False Swearing, you may find ______________________________
guilty of False Swearing as charged. If the jury and each member of the jury
has a reasonable doubt of the truth of the charge as to any one or more of these
elements of False Swearing, you shall find the Defendant ______________________________
not guilty.
______________________________________________________________ __________
5. in a: (proceeding before
the Grand Jury of the Circuit Court of _________________ County),
(a hearing in the Circuit Court of _______________ County), (hearing in the
Circuit Court of _______________ County, before the Family Law Master),
(deposition in a civil case, to-wit: _______________ vs. _______________, civil
action number _______________, pending in the Circuit
Court of _______________ County),
(answers to interrogatories in a civil case, to-wit: _______________ vs.
_______________, civil action number _______________,
pending in the Circuit Court of _______________ County)
(affidavit in a civil case, to-wit: _______________ vs. _______________, civil
action number _______________, pending in the Circuit
Court of _______________ County),
(Financial Disclosure Form in a civil case, to-wit: _______________ vs.
_______________, civil action number _______________,
pending in the Circuit Court of _______________ County),
(affidavit in a civil case, to-wit: _______________ vs. _______________, civil
action number _______________, pending in the Circuit
Court of _______________ County before the Family Law
Master),
6. which (testimony) (information disclosed) (answers
to interrogatories) was false,
7. and that the Defendant ______________________________
knew that such (testimony) (information disclosed) (answers to interrogatories)
was false,
8. and that the Defendant ______________________________
willfully and absolutely testified falsely,
9. and that the Defendant ______________________________
at the time he so (testified) (disclosed information) (answered interrogatories)
was under an (oath) (affirmation) to speak the truth,
10. which (oath) (affirmation) was lawfully administered
by ___________________________ to the Defendant ______________________________,
11. that ______________________________ was the ([Deputy]
Clerk of the Circuit Court) (Judge of the Circuit Court) (family law master)
(Notary Public)and as such had competent authority under law to administer such
(oath) (affirmation).
If after impartially considering, weighing and comparing
all the evidence, (both that of the State and that of the Defendant) the jury
and each member of the jury is convinced beyond a reasonable doubt of the truth
of the charge as to each of these elements of False Swearing, you may find ______________________________
guilty of False Swearing as charged. If the jury and each member of the jury
has a reasonable doubt of the truth of the charge as to any one or more of these
elements of False Swearing, you shall find the Defendant ______________________________
not guilty.
4. did intentionally and wilfully procure and induce
______________________________ a witness, to commit false swearing and testify
falsely to-wit:_________________ _____________________________________________________________________,
and,
5. which testimony occurred:
(in a misdemeanor trial in the _______________Court of _______________ County)
(in a proceeding before the Grand Jury of the Circuit Court _______________,
County)
(in a hearing in the Circuit Court of _______________ County) (in a hearing
in the Circuit Court of _______________ County, before
the Family Law Master) (in a deposition in a civil case, to-wit: _______________vs.
_______________, civil action number _______________,
pending in the Circuit Court of _______________ County)
(in answers to interrogatories in a civil case, to-wit:
_______________vs._______________, civil action number
_______________, pending in the Circuit Court of _______________
County)
(in an affidavit in a civil case, to-wit: _______________vs._______________,
civil action number _______________, pending in the
Circuit Court of _______________ County) (in
a Financial Disclosure Form in a civil case, to-wit:
_______________vs._______________, civil action number
_______________, pending in the Circuit Court of _______________
County, before the Family Law Master).
6. and that such (testimony) (information disclosed)
(answer to interrogatories) was false,
7. and that the witness ______________________________
knew that such (testimony) (information disclosed) (answer to interrogatories)
was false,
8. and that the witness ______________________________wilfully,
knowingly and absolutely (testified) (disclosed information) (answered interrogatories)
falsely,
9. and that the witness ______________________________
at the time he so (testified) (disclosed information) (answered interrogatories)
was under (an oath) (an affirmation) to speak the truth,
10. which (oath) (affirmation) was lawfully administered
by ______________________________ to the witness ______________________________,
11. that ______________________________ was the ([deputy]
Clerk of the Circuit Court) (Judge of the Circuit Court) (Magistrate) (Family
Law Master) (Notary Public) and as such had competent authority under law to
administer such (oath) (affirmation).
If after impartially considering, weighing and comparing
all the evidence, (both that of the State and that of the Defendant) the jury
and each member of the jury is convinced beyond a reasonable doubt of the truth
of the charge as to each of these elements of False Swearing, you may find ______________________________
guilty of False Swearing as charged.
4. did intentionally and wilfully procure and induce
______________________________ a witness to commit perjury and testify falsely
to-wit: _________________________ ____________________________________________________________________,
and,
5. which testimony occurred in a trial in the Circuit
Court of _______________ County
6. of ______________________________ who was then tried
in that Court,
7. upon the charge of __________________________,
8. which charge was at that time a felony offense,
9. that such testimony was false,
10. and that the witness ______________________________
knew that such testimony was false,
11. and that the witness ______________________________
wilfully, knowingly and absolutely testified falsely,
12. and that the witness ______________________________
at the time he so testified was under (an oath) (an affirmation) to speak the
truth,
13. which (oath) (affirmation) was lawfully administered
by ______________________________ to the witness ______________________________,
14. that ______________________________ was the ([deputy]
Clerk of the Circuit Court) (Judge of the Circuit Court) and as such had competent
authority under law to administer such (oath) (affirmation),
15. that in such felony trial the said testimony of
the witness ______________________________ was as to a material (matter) (thing).
If after impartially considering, weighing and comparing
all the evidence, (both that of the State and that of the Defendant) the jury
and each member of the jury is convinced beyond a reasonable doubt of the truth
of the charge as to each of these elements of Subornation Of Perjury, you may
find ______________________________ guilty of Subornation Of Perjury as charged.
If the jury and each member of the jury has a reasonable doubt of the truth
of the charge as to any one or more of these elements of Subornation Of Perjury,
you shall find the Defendant ______________________________ not guilty.
The offense charged in Count _____ of the Indictment
in this case is Subornation Of Perjury. One of three verdicts may be returned
by you under this Count of the Indictment. They are: (1) guilty of Subornation
Of Perjury; (2) guilty of False Swearing; and (3) not guilty.
Perjury is committed when any person wilfully, knowingly
and absolutely testifies falsely under an oath or affirmation lawfully administered
in a trial of the witness or any other person for a felony, concerning a material
matter or thing.
False Swearing is committed when any person wilfully,
knowingly and absolutely testifies falsely under oath or affirmation lawfully
administered in a trial of the witness or any other person for a felony, concerning
a matter or thing not material, or on any occasion other than a trial for a
felony concerning any matter or thing material or not material, or procures
another person to commit false swearing.
Subornation of Perjury is committed when any person
intentionally and wilfully induces or procures another person to commit perjury
and the witness so induced or procured commits the offense of perjury.
The burden is on the State to prove the guilt of the
Defendant beyond a reasonable doubt and the Defendant, ______________________________
is not required to prove himself innocent. He is presumed by the law to be innocent
of this charge and this presumption remains with him throughout the entire trial.
Before the Defendant, ______________________________
can be convicted of Subornation Of Perjury, the State of West Virginia must
overcome the presumption that the Defendant, ______________________________
is innocent and prove to the satisfaction of the jury beyond a reasonable doubt
that:
1. The Defendant, ______________________________,
2. in __________________ County, West Virginia,
3. on or about the _____ day of ________________, 199__,
4. did intentionally and wilfully procure and induce
______________________________ a witness to commit perjury and testify falsely
to-wit: _________________________ _____________________________________________________________________,
and,
5. which testimony occurred in a trial in the Circuit
Court of _______________ County,
6. of ______________________________ who was then tried
in that Court,
7. upon the charge of __________________________,
8. which charge was at that time a felony offense,
9. that such testimony was false,
10. and that the witness ______________________________
knew that such testimony was false,
11. and that the witness ______________________________
wilfully, knowingly and absolutely testified falsely,
12. and that the witness ______________________________
at the time he so testified was under (an oath) (an affirmation) to speak the
truth,
13. which (oath) (affirmation) was lawfully administered
by ______________________________ to the witness ______________________________,
14. that ______________________________ was the ([deputy]
Clerk of the Circuit Court) (Judge of the Circuit Court) and as such had competent
authority under law to administer such (oath) (affirmation),
15. that in such felony trial the said testimony of
the witness ______________________________ was as to a material (matter) (thing).
If after impartially considering, weighing and comparing
all the evidence, (both that of the State and that of the Defendant) the jury
and each member of the jury is convinced beyond a reasonable doubt of the truth
of the charge as to each of these elements of Subornation Of Perjury, you may
find ______________________________ guilty of Subornation Of Perjury as charged.
If the jury and each member of the jury has a reasonable doubt of the truth
of the charge as to any one or more of these elements of Subornation Of Perjury,
you shall find the Defendant ______________________________ not guilty (and
deliberate on the lesser included offense as hereinafter instructed).
Before the Defendant, ______________________________
can be convicted of Subornation Of False Swearing, the State of West Virginia
must overcome the presumption that the Defendant, ______________________________
is innocent and prove to the satisfaction of the jury beyond a reasonable doubt
that:
1. The Defendant, ______________________________,
2. in __________________ County, West Virginia,
3. on or about the _____ day of ________________, 199__,
4. did intentionally and wilfully procure and induce
______________________________
a witness to commit False Swearing and testify falsely to-wit: _________________
____________________________________________________________________, and,
5. which testimony occurred in a trial in the Circuit
Court of _______________ County,
6. of ______________________________ who was then tried
in that Court,
7. upon the charge of __________________________,
8. which charge was at that time a felony offense,
9. that such testimony was false,
10. and that the witness ______________________________
knew that such testimony was false,
11. and that the witness ______________________________
wilfully, knowingly and absolutely testified falsely,
12. and that the witness ______________________________
at the time he so testified was under (an oath) (an affirmation) to speak the
truth,
13. which (oath) (affirmation) was lawfully administered
by ______________________________ to the witness ______________________________,
14. that ______________________________ was the ([deputy]
Clerk of the Circuit Court) (Judge of the Circuit Court) and as such had competent
authority under law to administer such (oath) (affirmation).
15. that in such trial said testimony was as to a non-material
matter.
If after impartially considering, weighing and comparing
all the evidence, (both that of the State and that of the Defendant) the jury
and each member of the jury is convinced beyond a reasonable doubt of the truth
of the charge as to each of these elements of False Swearing, you may find ______________________________
guilty of False Swearing as charged. If the jury and each member of the jury
has a reasonable doubt of the truth of the charge as to any one or more of these
elements of False Swearing, you shall find the Defendant ______________________________
not guilty.