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Subornation of perjury
Subornation of perjury
Subornation of perjury
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In American law, Scots law, and under the laws of some English-speaking Commonwealth nations, subornation of perjury is the crime of persuading or permitting a person to commit perjury, which is the swearing of a false oath to tell the truth in a legal proceeding, whether spoken or written.

U.S. Law

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In American federal law, Title 18 U.S.C. § 1622 provides:

Whoever procures another to commit any perjury is guilty of subornation of perjury, and shall be fined under this title or imprisoned not more than five years, or both.

The term subornation of perjury further describes the circumstance wherein an attorney at law causes a client to lie under oath or, allows another party to lie under oath.[1][2]

In California law, per the state bar code,[3] the subornation of perjury constitutes an act of "moral turpitude" on the part of the attorney, and thus, is cause for their disbarment, or for the suspension of their license to practice law.[4]

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As a crime, it has been defined as "persuading another to commit perjury."[2]

But "suborn" is more broadly defined. Amongst three definitions: to induce a person to commit a wrongful act ... esp. in a secret or underhanded manner; to induce a person to commit perjury; and to obtain perjured testimony from another.[2]

In legal practice, the condition of suborning perjury applies to an attorney who presents either testimony or an affidavit, or both, either to a judge or to a jury, which the attorney knows to be materially false, and not factual. In civil law and in criminal law, the attorney's knowledge that the testimony is materially false must rise above mere suspicion to what an attorney would reasonably have believed in the circumstances of the matter discussed in the testimony. Hence, the attorney cannot be wilfully blind to the fact that their witness is giving false, perjurious testimony.

An attorney who encourages a witness to give false testimony is suborning perjury, a crime punished either with formal disciplinary action, disbarment, jail, or a combination thereof. A false statement by an attorney in court also is a crime similar to subornation of perjury and is punished accordingly. In the professional conduct of an attorney at law, there is a fine delineation between assisting a witness to recall events and encouraging the witness to give materially false testimony. The practice of ″horse shedding the witness″ (rehearsing testimony) (also known as woodshedding), is an example of such perjurious criminal conduct by an attorney, which is depicted in the true-crime novel Anatomy of a Murder (1958), by Robert Traver – John D. Voelker, a justice of the Michigan Supreme Court – and in the eponymous film (Otto Preminger, 1959), about a rape-and-murder case wherein are explored the ethical and legal problems inherent to the subornation of perjury.[5][6][7]

See also

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References

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Revisions and contributorsEdit on WikipediaRead on Wikipedia

Subornation of perjury

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from Grokipedia
Subornation of perjury is the criminal offense of persuading, inducing, or procuring another person to commit by knowingly providing false testimony under in a judicial or proceeding. This act targets those who corruptly encourage or facilitate lies in sworn statements, distinguishing it from itself, which is the direct act of lying under . The offense originated in English as a separate from , aimed at punishing individuals who orchestrate false evidence to pervert . In federal law, subornation of perjury is codified under 18 U.S.C. § 1622, which states that whoever procures another to commit any is guilty of the offense. To prove the crime, prosecutors must establish that was actually committed by the induced party, that the corruptly procured the false , and that both the and the perjurer knew or believed the to be false. Unlike under 18 U.S.C. § 1621, which often requires corroboration via the two-witness rule, subornation cases under § 1622 focus on the procurement element without the same evidentiary hurdles for the underlying . Physical coercion is not necessary; mere encouragement or assistance suffices if done with corrupt intent. Penalties for subornation of perjury mirror those for , including fines under Title 18 of the U.S. and for up to five years, or both. The offense is also recognized in state s and other jurisdictions, such as the District of Columbia under D.C. § 22–2403, where it involves willfully procuring another to commit . Related charges, like or , may apply even if the perjury is not ultimately committed, broadening prosecutorial options to deter such conduct. This crime underscores the legal system's emphasis on the of in trials, depositions, and administrative hearings.

Definition and Concepts

Core Definition

Subornation of perjury is the criminal offense of procuring, inducing, or knowingly assisting another person to commit perjury, which entails providing false testimony under oath in a judicial or other official proceeding. This act undermines the integrity of legal proceedings by deliberately engineering deceitful sworn statements. The term "suborn" originates from the Latin subornare, meaning "to equip secretly" or "to incite covertly," evolving in English legal contexts since the 16th century to specifically denote the secret inducement of perjury or other crimes. In contemporary usage, it focuses on the intentional persuasion or facilitation of false testimony in court. Central to subornation of perjury are three key components: the subornor's intent to deceive the tribunal, their knowledge that the proposed testimony is false, and the active procurement or facilitation of the perjurious act, such as by coaching or bribing the witness. Black's Law Dictionary defines it as "the offense of procuring another to commit perjury," a formulation consistent across editions from the 7th (1999) to the 11th (2019). Perjury itself, as the foundational offense, requires the willful assertion of a falsehood under . Subornation of perjury differs fundamentally from itself, as the former involves a third party actively inducing or procuring another individual to provide false under , whereas constitutes the direct act of willfully making a false statement under by the witness. In subornation, the suborner must know or believe the to be false and corruptly encourage its delivery, but the crime requires that actual occur for prosecution to succeed under this specific offense. By contrast, the perjurer bears direct responsibility for the false , and the two roles are treated as distinct in , with the suborner and perjurer not considered accomplices to one another. While subornation of perjury falls within the broader category of obstruction of justice offenses, it is narrower in scope, specifically targeting the inducement of false rather than the wide array of actions that impede judicial proceedings. Obstruction of justice encompasses activities such as destroying , influencing jurors, or interfering with investigations without any requirement for an or sworn statement, allowing prosecution even if no perjury ultimately takes place. In essence, subornation requires proof of corrupt procurement leading to , distinguishing it from general obstructive conduct that may not involve at all. Subornation also contrasts with witness tampering, which under federal law (18 U.S.C. § 1512) includes both coercive methods such as threats, , or and non-coercive corrupt to alter, suppress, or cause false , and can occur outside formal proceedings without requiring that actually be committed. Subornation, however, hinges specifically on or inducement to deliver knowingly false in an official proceeding, with the actual required for the offense.

Historical Background

Origins in Common Law

Subornation of perjury emerged in medieval as an extension of prohibitions against , which originated in ecclesiastical courts where false oaths were punished as violations of . In the 13th century, treated as a grave sin involving the corruption of sacred oaths, influencing early by emphasizing the moral and spiritual dimensions of false testimony in judicial proceedings. This foundation viewed inducing false oaths not merely as a procedural wrong but as a profound of testimony, akin to aiding . Henry de Bracton's influential treatise On the Laws and Customs of (c. 1250–1260) referenced in the context of jurors or witnesses swearing falsely, underscoring that such acts, including those procured by others, undermined the integrity of legal oaths and warranted severe and secular sanctions. The integration of principles into solidified subornation as a distinct offense by the , recognizing the act of procuring false testimony as equally culpable to itself. Early precedents treated subornation harshly, evolving from ancient punishments like death or to forfeiture of goods and perpetual , reflecting its status as an affront to public justice. The pivotal 1563 (5 Eliz. c. 9) marked the first legislative recognition at , allowing trials for both and subornation in secular courts and imposing fines of 40 pounds alongside for non-payment, thereby distinguishing inducement as a separate . By the late , cases in English courts, such as those under the restored , further entrenched this framework, prosecuting suborners for corrupting witnesses in civil and criminal matters. This tradition transitioned seamlessly to colonial American legal systems in the , where subornation was adopted through codes mirroring English precedents to safeguard judicial integrity in new settlements. In the , the 1648 Laws and Liberties incorporated prohibitions, punishing false oaths under judicial authority with fines, imprisonment, or corporal penalties, and implicitly extending liability to those procuring such falsehoods as part of inherited offenses. These early colonial statutes, like their English counterparts, aimed to deter the moral and legal corruption of testimony in community disputes and trials. In the evolution from principles, subornation of perjury underwent significant codification in modern legal systems during the 19th and early 20th centuries, transforming it from a misdemeanor into a statutory across key jurisdictions. In , the Act 1911 served as a pivotal consolidation, explicitly criminalizing the act of inciting, procuring, or suborning another to commit under Section 7, treating the suborner as a principal offender liable to the same penalties as itself, including up to seven years' penal servitude. This legislation simplified and unified prior fragmented statutes, such as those under the Act 1851, thereby strengthening enforcement in judicial proceedings. In the United States, federal recognition of subornation of perjury dates to the Crimes Act of , which in Section 18 addressed corrupt of false , requiring sufficient in indictments and subjecting offenders to state-level penalties, often including fines and . This early statutory framework evolved through revisions, culminating in the codification of 18 U.S.C. § 1622 in 1948 as part of the comprehensive recodification of federal , which prohibits procuring another to commit and imposes up to five years' . The provision built on intermediate acts, such as the 1909 revision, to adapt the offense to federal judicial contexts while maintaining its roots in protecting testimonial integrity. The influence of English extended to and Commonwealth nations, where subornation was integrated into codified frameworks emphasizing indictable offenses. In , the Criminal Code of 1892 incorporated the offense under sections 145 and 146, making it indictable to incite, counsel, or procure perjury, reflecting a post-federation effort to standardize across provinces. This provision has endured with minor amendments, underscoring its role in safeguarding court proceedings. Twentieth-century reforms further globalized the offense through international mechanisms, notably in the (1945-1946), where suborning false was prosecutable as a form of obstructing or , applicable to witnesses providing fabricated evidence in war crimes proceedings. This recognition highlighted subornation's applicability beyond domestic courts, influencing subsequent international tribunals by affirming penalties such as fines or imprisonment for corrupting in accountability forums.

United States Law

In the , subornation of perjury is primarily governed by federal statute under 18 U.S.C. § 1622, which states: "Whoever procures another to commit any is guilty of subornation of perjury, and shall be fined under this title or imprisoned not more than five years, or both." This provision was enacted on June 25, 1948, as part of the comprehensive revision and codification of Title 18 of the , drawing from earlier statutes in the Revised Statutes of 1875 (sections 5393 and 5394). It was amended in 1994 (Pub. L. 103–322) to update the fine structure, but no major changes to its core elements have occurred since. The statute applies in federal jurisdictions where the underlying perjury occurs in proceedings before a of the , a federal , , or other federal administrative bodies authorized to receive under . At the state level, laws on subornation of perjury vary but often mirror the federal definition, treating it as a punishable similarly to itself. For example, California's Penal Code § 127 provides: "Every person who willfully procures another person to commit is guilty of subornation of , and is punishable in the same manner as he would be if personally guilty of the so procured." This aligns closely with the federal language but operates within state court proceedings, without explicit provisions for lesser inducements, emphasizing willful procurement in judicial or official settings. Other states, such as New York, criminalize subornation through accomplice liability for under Penal Law §§ 20.00 and 210.15, treating it as a class D when the induced is and consists of . This reflects a common pattern of jurisdictional adaptation to local proceedings. As of November 2025, 18 U.S.C. § 1622 maintains its original scope amid evolving federal laws like 18 U.S.C. § 1623 for specific judicial contexts. However, the offense is reinforced in standards, particularly the American Bar Association's Model Rule of Professional Conduct 3.3, which requires lawyers to maintain candor toward the by prohibiting the knowing offer of or failure to correct known false , thereby deterring subornation among legal practitioners.

International and Commonwealth Perspectives

In the , subornation of perjury is criminalized under Section 7 of the Perjury Act 1911, which holds liable any person who aids, abets, counsels, procures, or suborns another to commit an offence under the Act. This provision applies to , , and , where the offence is treated as a misdemeanour punishable on by up to seven years' imprisonment, a fine, or both. maintains a separate framework under and the Criminal Procedure (Scotland) Act 1995, though subornation remains prosecutable as aiding with similar maximum penalties. In , subornation of perjury is addressed through Section 21 of , which deems the suborner a party to the offence of under Section 131, thereby subjecting them to the same penalties as the principal offender. itself, as defined in Section 131, involves making a under with intent to mislead in judicial or other authorized proceedings, and under Section 132, it carries a maximum of 14 years' as an . This approach emphasizes the protection of judicial integrity, with subornation often prosecuted alongside obstruction of justice under Section 139 if inducement involves threats or other interferences. Australia's legal systems, being federated, address subornation of perjury primarily through state and rooted in principles, leading to variations in statutory wording and penalties. In , Section 333 of the Crimes Act 1900 criminalizes procuring, inducing, or attempting to induce another to commit , punishable by up to seven years' . Similar provisions exist in other jurisdictions, such as Victoria's Crimes Act 1958 (Section 314), which punishes subornation of with up to 15 years' , aligning it with penalties, though maximum terms typically range from seven to ten years depending on the context, such as whether the false evidence relates to a serious . These laws underscore a unified heritage but adapt to local procedural needs. Beyond nations, civil law systems present distinct conceptualizations of subornation. In , the Penal Code's Article 434-14 punishes the provocation of false under —termed "subornation de faux témoignage"—through gifts, promises, or other inducements, with penalties of up to seven years' and a 100,000 fine, escalating if linked to or . This integrates subornation as an aggravated form of in the base offence of false under Article 434-13, focusing on judicial and investigative proceedings within the framework. In , influenced by British , Section 194 of the addresses the fabrication or use of false evidence intended to procure for a capital offence, including subornation aspects, with punishments ranging from seven years' rigorous to life if an innocent person is executed as a result. These provisions highlight a global emphasis on deterring interference in , though civil law traditions prioritize inducement mechanisms over 's aiding-and-abetting model.

Elements and Proof

Required Elements of the Crime

Subornation of perjury under requires proof of four core elements: (1) that the procured was false; (2) that the suborner knew or believed the to be false; (3) that the suborner procured, induced, or otherwise caused the to occur; and (4) that the false was material to the relevant proceeding. These elements derive from 18 U.S.C. § 1622, which criminalizes procuring another to commit , incorporating the underlying requirements of under 18 U.S.C. §§ 1621 or 1623. The prosecution must establish that an actual act of by the witness occurred, as subornation cannot stand independently without the completed perjurious act. The first element demands that the testimony in question be demonstrably false, meaning it contradicts established facts or prior truthful statements by the witness. The second element focuses on the subornor's knowledge of this falsity; the defendant must have known, believed, or had reasonable grounds to believe that the testimony would be untrue, and similarly must have known or believed that the witness was aware of its falsity. This knowledge is a critical component, distinguishing subornation from mere encouragement of inaccurate recollection. The third element requires active procurement or inducement by the suborner, which must be done "corruptly"—that is, with the specific intent to cause the witness to provide false testimony under oath. Mere suggestion or passive involvement is insufficient; the suborner must willfully induce the perjury through persuasion, coercion, or other means aimed at deception. The fourth element, materiality, applies to the false testimony itself and is met if the statement has a natural tendency to influence or is capable of influencing the decision of the tribunal or proceeding to which it is directed. This standard ensures that only testimony with potential impact on the outcome qualifies, as established in federal precedents interpreting perjury statutes. The for subornation emphasizes willful inducement, requiring proof that the suborner acted with deliberate intent to subvert the truth-seeking process, beyond simple negligence or mistake. The overall burden of proof rests with the prosecution, which must demonstrate all elements beyond a . Proving the subornor's knowledge often relies on , such as communications evidencing witness coaching or prior discussions revealing awareness of the truth, given the rarity of direct admissions.

Challenges in Prosecution

Prosecuting subornation of perjury presents significant evidentiary hurdles, primarily due to the need to prove the subornor's corrupt beyond a . Under , prosecutors must demonstrate not only that occurred but also that the knowingly procured it with awareness of its falsity, often relying on since direct admissions are rare. Suborners frequently deny any knowledge of the falsehood, claiming mere encouragement of without to deceive, which necessitates indirect proof such as audio recordings of inducements or from the perjurer themselves. A key challenge lies in securing the of the induced perjurer, as successful prosecutions often depend on the witness turning state's evidence against the suborner in exchange for immunity or reduced charges. Federal immunity provisions under 18 U.S.C. § 6002 allow courts to compel by granting use immunity, protecting the perjurer from prosecution based on their compelled statements, though this does not shield against charges for the original false . Without such , building a case becomes exceedingly difficult, as the perjurer may invoke the Fifth Amendment or remain silent to avoid . Statute of limitations further complicates prosecutions, with federal cases subject to a five-year period under 18 U.S.C. § 3282 from the date of the offense. Delays in discovery, such as post-trial revelations of suborned in civil or criminal proceedings, can render charges untimely if the inducement occurred more than five years prior, even if the perjury's impact emerges later. This timing issue is particularly acute in complex litigation where of procurement surfaces only after extended investigations. Conviction rates for subornation remain notably low, reflecting these evidentiary and procedural barriers. U.S. Department of Justice practices indicate that subornation charges are infrequently pursued compared to related offenses like obstruction of justice or , which are easier to establish without proving actual . Similarly, in the , Crown Prosecution Service guidelines under the Perjury Act 1911 outline subornation as an indictable offense but emphasize due to proof challenges, resulting in rare applications alongside broader perverting-the-course-of-justice charges.

Penalties and Consequences

Criminal Sanctions

In the , subornation of perjury is a federal under 18 U.S.C. § 1622, punishable by a fine or for not more than five years, or both. The maximum fine for individuals is $250,000, as established by the general federal sentencing provisions in 18 U.S.C. § 3571 for offenses. If the subornation forms part of a broader , such as under 18 U.S.C. § 371 ( to defraud the ), penalties may be enhanced, potentially extending up to five years or more depending on the scope of the underlying scheme. At the state level, penalties for subornation of perjury vary significantly by jurisdiction, often aligning with those for itself. For example, in jurisdictions like New York, subornation may be prosecuted as a under or related statutes, with maximum sentences up to seven years or more depending on the offense class. In cases involving minor inducements or less severe circumstances, some states classify it as a , resulting in shorter terms of imprisonment, such as up to one year, and lesser fines. Internationally, criminal sanctions reflect the offense's gravity in undermining judicial integrity, with maximum penalties scaled to the jurisdiction's legal framework. In the , under section 5 of the Perjury Act 1911, subornation of perjury is punishable by up to seven years upon conviction on . In , subornation of perjury is addressed under section 137 of as an , punishable by a maximum of fourteen years . In , federal law under the Criminal Code Act 1995 imposes a maximum of ten years for subornation in connection with judicial proceedings. Fines in these jurisdictions are generally discretionary and proportionate to the offense's impact, often unlimited or tied to statutory scales. Sentencing for subornation of perjury considers various aggravating factors, particularly in the U.S. federal system under the Sentencing Guidelines § 2J1.3 (effective November 1, 2025). The base offense level is 12. If the subornation was in furtherance of another offense, such as obstruction of justice, the court may apply a to another guideline (e.g., §2J1.2), which includes adjustments for substantial interference with (e.g., +8 levels for causing a mistrial). Repeat offenses or significant harm to the judicial process further aggravate the sentence, potentially leading to higher ranges within the statutory maximums.

Professional and Civil Repercussions

Subornation of perjury by attorneys constitutes professional misconduct under the American Bar Association's Model Rule 8.4, which prohibits lawyers from violating or inducing others to violate the Rules of Professional Conduct, potentially resulting in , suspension, or other disciplinary actions imposed by state bar associations. Such conduct also breaches Rule 3.3 on candor toward the , requiring lawyers to avoid offering known false evidence and to take remedial measures if falsity becomes apparent, with violations triggering formal investigations and sanctions to protect the integrity of legal proceedings. In , a for subornation of perjury—a involving —mandates immediate suspension pending final judgment and often leads to summary under Business and Professions Code § 6102(a), which requires the State Bar to investigate and recommend discipline upon receipt of a certified record. For instance, in In re Jones (1971), the disbarred an attorney convicted of subornation of perjury, emphasizing that such acts undermine public trust in the profession and warrant severe repercussions beyond criminal penalties. Beyond legal professionals, individuals convicted of subornation may lose licenses in related fields, such as commissions, where involvement in false oaths or fraudulent notarizations results in , fines, or civil penalties to deter of . Reputational harm is a common collateral effect, as convictions for subornation erode professional credibility, limit future opportunities, and invite scrutiny in an era of heightened ethical oversight. Civil arises when subornation causes tangible , such as contributing to a wrongful conviction; affected parties, including exonerees, may pursue tort claims for legal malpractice, fraud, or , seeking compensatory for lost , economic losses, and suffering. In the , the imposes sanctions for dishonesty akin to subornation, including striking off the roll or fines, under principles requiring integrity and avoidance of misleading conduct in litigation. Recent developments, including the U.S. Department of Justice's Office of Professional Responsibility's 2025 investigative summaries, highlight increased scrutiny of prosecutorial and defense violations involving false , reinforcing ABA Rule 3.3's emphasis on candor amid ongoing reforms to enhance accountability in high-stakes cases.

Applications in Practice

Subornation of perjury commonly arises in legal proceedings when parties attempt to manipulate , such as by witnesses pre-trial to deliver fabricated accounts or by submitting affidavits known to contain falsehoods. This offense requires proof that the suborner knowingly induced the perjured statement, often occurring in both civil and criminal contexts where false evidence could sway outcomes. A historical example of such is "horse shedding," a term coined by author in the 19th century, referring to attorneys rehearsing with witnesses in secluded spaces like carriage sheds near courthouses, which risks crossing into subornation if lies are scripted. The 1959 Anatomy of a Murder depicts this tension through a defense attorney's preparation of a witness whose borders on , highlighting ethical dilemmas in strategy. Detection of subornation in courtroom settings frequently relies on , where inconsistencies or implausible details in a witness's can expose induced falsehoods, prompting further of the subornor's involvement. Post-trial investigations by prosecutorial offices or oversight bodies may uncover evidence of procurement through records, communications, or contradictory documentation that emerges after the proceeding. Whistleblower reports from co-counsel, staff, or participants can also initiate probes, as internal disclosures often reveal attempts to coordinate false narratives. Preventive measures in U.S. proceedings emphasize judicial oversight and prosecutorial diligence to deter subornation. Under Federal Rule of Evidence 603, judges must administer an or affirmation to witnesses in a form that impresses upon them the duty to testify truthfully, thereby reinforcing the legal consequences of and discouraging induced lies. Prosecutors, in turn, screen potential witnesses for by evaluating prior statements, biases, and reliability to avoid unwittingly presenting suborned . In international contexts like the , witness preparation protocols under the Bar Council and guidelines strictly limit interactions to prevent subornation risks, focusing on procedural familiarization rather than content rehearsal. These rules prohibit barristers or prosecutors from coaching evidence or discussing specific defense details, with violations potentially constituting ; instead, they permit explanations of layout, questioning styles, and the importance of truthfulness to ensure independent .

Notable Cases and Examples

In the , the case United States v. Gaudin (1995) addressed key evidentiary issues relevant to subornation of perjury prosecutions. The Court unanimously held that the determination of "materiality" in false statement offenses under 18 U.S.C. § 1001—a core element also required for under 18 U.S.C. § 1621 and thus subornation under § 1622—is a question of fact for the , not the , ensuring constitutional in such trials. A prominent modern example involves Michael Cohen's 2018 guilty plea in the Southern District of New York to charges including to about efforts to build a in during the 2016 election. This plea sparked allegations that former President suborned perjury by directing Cohen to lie under oath, though no charges were brought against Trump on this basis following a disputed report. In the , the 2010 trial HM Advocate v. Sheridan and Sheridan highlighted subornation charges in a high-profile political case. , a former Scottish politician, was convicted of for lying about attending a swingers' club during his 2006 civil libel victory against a ; his wife faced a related subornation of charge for allegedly procuring testimony, which was ultimately dropped due to insufficient corroboration. Canada's legal landscape includes the 1970 Supreme Court decision in R. v. Kyling, which clarified that subornation of perjury requires proof of actual having occurred, as the suborner is treated as a party to the offense under ; the case involved an unsuccessful attempt to induce false testimony in a criminal proceeding, underscoring the need for completed perjury for . In literature, Harper Lee's (1960) illustrates attempted subornation through the Ewell family's coercion of false testimony against in a racially charged trial, where Bob Ewell pressures relatives to perjure themselves, exposing broader themes of injustice and witness manipulation in the American South. As of , prosecutions for subornation of perjury remain infrequent, with data indicating fewer than 50 federal convictions annually in the U.S. from onward, including rare applications in post- election interference investigations despite widespread allegations of . For instance, in multidistrict litigation over venue declarations, attorneys faced scrutiny for potentially suborning perjured affidavits in at least nine cases filed between and 2024, highlighting ongoing challenges in civil contexts.

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  49. https://www.americanbar.org/groups/criminal_justice/resources/standards/prosecutorial-investigations/
  50. https://www.barcouncilethics.co.uk/wp-content/uploads/2017/10/Witness-preparation-guidance-2019.pdf
  51. https://www.cps.gov.uk/sites/default/files/documents/legal_guidance/speaking-to-witnesses-at-court-guidance-feb-2018.pdf
  52. https://supreme.justia.com/cases/federal/us/515/506/
  53. https://www.justsecurity.org/62314/buzzfeed-trump-directed-cohen-lie-encourage-procure-suborn-perjury-false-statement/
  54. https://decisions.scc-csc.ca/scc-csc/scc-csc/en/item/5087/index.do
  55. https://www.americanbar.org/groups/business_law/resources/business-lawyer/2025-summer/false-venue-claims-under-penalty-of-perjury/
  56. https://www.everycrsreport.com/files/2024-10-08_98-808_84a7f69ed52162c2bfd4059bc05826c142605ce2.pdf
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