Furda v. State, 421 Md. 332

Summary

The Maryland Court of Appeals considered whether a defendant could be convicted of perjury and making a false statement in a firearm application after answering no to a question about mental-health commitment. The court held that the application question was not impermissibly ambiguous, that the defendant knowingly and willfully answered it falsely, and that a trial court's order remained binding until reversed on appeal. The court affirmed the convictions.

Holdings

1. Question 8 was not fundamentally or impermissibly ambiguous. Its use of 'or' required an affirmative answer if either adjudication as mentally defective or commitment to a mental institution had occurred, and the term 'committed' was not rendered ambiguous merely because it could have different legal meanings in different statutory schemes.
2. The later reversal of the circuit court's denial order did not retroactively make Furda's answer truthful or negate the falsity of his statement when made.
3. The evidence was sufficient to establish that Furda knowingly gave false information in a firearm application and willfully made a false oath as to a material fact.

Questions Presented

1. Whether Question 8 on Maryland's firearm-purchase application, asking whether the applicant had ever been adjudicated mentally defective or committed to a mental institution, was impermissibly ambiguous and therefore could not support convictions for perjury and false information.
2. Whether the later appellate reversal of the circuit court's firearm-denial order rendered Furda's answer truthful retroactively.
3. Whether sufficient evidence established that Furda knowingly and willfully made a materially false statement.

Disposition

affirmed