Wednesday, December 18, 2013

Meyers v. United States case brief

Meyers v. United States case brief summary
171 F.2d 800 (D.C. Cir. 1948)


CASE SYNOPSIS
Defendant appealed a United States District Court for the District of Columbia judgment upholding a jury conviction of suborning perjury, in violation of Title 22, § 2501, D.C. Code (1940).

CASE FACTS
Defendant was indicted for suborning perjury from his codefendant before a United States Senate subcommittee. He was convicted on all counts and he appealed. Defendant argued that codefendant's statements to subcommittee were truthful, and therefore not perjury.

DISCUSSION

  • The court admitted that defendant could not have suborned perjury if there were no perjury, however, codefendant's testimony taken as a whole over several days consisted of statements codefendant knew to be false, and therefore they were perjurious. 
  • Sufficient evidence existed for a jury to find that defendant suborned perjury. 
  • Although defendant did not assign error to what he called the "bizarre procedure" of allowing witness to testify to codefendant's testimony, the court held no reversible error merely because subcommittee transcript was best evidence. 
  • The court stated that the best evidence rule was limited to cases where contents of a writing were to be proved and that one who remembers any oral statement may testify as to its contents.

CONCLUSION
Judgment upholding jury conviction that defendant suborned perjury was affirmed. The court held that codefendant's testimony, taken as a whole, was knowingly false and therefore perjurious. The court also held that sufficient evidence existed for a jury to convict defendant of suborning perjury.


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