State v. Williams

Summary

The Louisiana Supreme Court reviewed whether La. R.S. 14:126.1 requires a false statement to be made under oath or equivalent affirmation. The court held that the statute’s plain text imposes no oath requirement, and that its title could not override the text. The court reversed the court of appeal’s decision quashing the prosecution and remanded for consideration of the defendant’s remaining assignments of error.

Holdings

1. La. R.S. 14:126.1 does not require that the offender make the alleged false statement under oath or an equivalent affirmation.
2. The title's reference to 'false swearing' cannot be used to add an oath requirement that is absent from the unambiguous statutory text.

Questions Presented

1. Whether La. R.S. 14:126.1 requires the alleged false statement to be made under oath or an equivalent affirmation.
2. Whether the title of La. R.S. 14:126.1 permits the court to import an oath requirement from related false-swearing statutes.
3. Whether the Third Circuit properly quashed the prosecution on the ground that the bill of information failed to allege a false statement made under oath.

Disposition

reversed_and_remanded