{"id":1368,"date":"2017-09-27T17:44:36","date_gmt":"2017-09-27T17:44:36","guid":{"rendered":"https:\/\/courses.lumenlearning.com\/suny-fmcc-criminallaw\/?post_type=chapter&p=1368"},"modified":"2017-09-27T17:44:36","modified_gmt":"2017-09-27T17:44:36","slug":"13-3-perjury-bribery-and-obstruction-of-justice","status":"publish","type":"chapter","link":"https:\/\/courses.lumenlearning.com\/suny-sccc-criminallaw\/chapter\/13-3-perjury-bribery-and-obstruction-of-justice\/","title":{"raw":"13.3 Perjury, Bribery, and Obstruction of Justice","rendered":"13.3 Perjury, Bribery, and Obstruction of Justice"},"content":{"raw":"
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Learning Objectives<\/h3>\n
  1. Define the elements of perjury.<\/li>\n
  2. Identify the issues commonly encountered in a perjury prosecution.<\/li>\n
  3. Identify a potential defense to perjury.<\/li>\n
  4. Define perjury by inconsistent statements and subornation of perjury.<\/li>\n
  5. Analyze perjury and subornation of perjury grading.<\/li>\n
  6. Define the elements of bribery, identify the primary difficulty in a prosecution for this offense, and analyze bribery grading.<\/li>\n
  7. Define the elements of various forms of obstruction of justice, and analyze obstruction of justice grading.<\/li>\n <\/ol><\/div>\n

    Crimes against the administration of justice impede the government\u2019s ability to carry out the important functions of prosecuting and convicting criminals, which, in turn, destroys citizens\u2019 confidence that the US legal system is effective in ensuring individual safety and security. This section analyzes perjury, bribery, and obstruction of justice, along with the issues commonly encountered when prosecuting these offenses. Additional statutes criminalizing contempt of court, resisting arrest, and escape are also available for review.<\/p>\n

    \n

    Perjury History and Elements<\/h2>\n

    Witness testimony is important in a variety of settings. Juries depend on witness testimony to reach a fair and impartial verdict in civil and criminal trials, and grand juries depend on witness testimony to indict defendants for criminal conduct. Thus modern laws of perjury<\/a><\/span> are calculated to ensure that witnesses testify truthfully so that justice can be done in each individual case.<\/p>\n

    In the Middle Ages, the witnesses were the jurors, so the criminalization of false witness testimony did not occur until the sixteenth century when the idea of a trial by an impartial jury emerged. The first common-law prohibition against witness perjury criminalized false<\/strong> testimony, given under oath<\/strong>, in a judicial proceeding<\/strong>, about a material<\/strong> issue. This definition was also incorporated into early American common law (Jrank.org, 2011).<\/p>\n

    In modern times, every state prohibits perjury, as well as the federal government (18 U.S.C. \u00a7 1621, 2011). Most state statutes or state common law, in states that allow common-law crimes, define perjury as a false material statement (criminal act<\/strong>), made with the specific intent<\/strong> or purposely<\/strong> to deceive, or the general intent<\/strong> or knowingly<\/strong> that the statement was false, in a judicial or official proceeding (attendant circumstance<\/strong>), under oath (attendant circumstance<\/strong>) (Ga. Code tit. 16 \u00a7 16-10-70, 2011). The Model Penal Code defines perjury as a false material statement, that the defendant does not believe to be true, made under oath in any official proceeding (Model Penal Code \u00a7\u00a0241.1(1)). The biggest issues commonly encountered in any perjury prosecution are proving the validity of the oath, the defendant\u2019s criminal intent, the materiality of the false statement, and any requirement of corroborative evidence.<\/p>\n

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    Necessity of a Valid Oath<\/h2>\n

    The defendant must be under oath when making the statement at issue in any perjury prosecution, and the oath must be administered by someone of legal authority<\/em> or someone authorized to take evidence under oath<\/em> (Connecticut Jury Instructions \u00a7 531-156, 2011), including a referee, hearing examiner, commissioner, notary, or other person authorized to take evidence in connection with an official or judicial proceeding (Connecticut Jury Instructions \u00a7 53a-156, 2011). Federally and in many jurisdictions, the false statement can be written<\/strong>, as long as it is certified<\/em>, such as a signature on an income tax return (18 U.S.C. \u00a7 6065, 2011) or a report (Cal. Penal Code \u00a7 129, 2011). The Model Penal Code also considers a false written<\/strong> statement perjury, as long as the document containing the statement is made upon oath or affirmation (Model Penal Code \u00a7\u00a0241.1(3)). In spite of the attendant circumstance<\/strong> requirement that the statement be made under oath, many jurisdictions disallow a defense to a prosecution for perjury based on the assertion that the oath or affirmation was administered or taken in an irregular<\/em> manner (Ala. Code \u00a7 13A-10-108, 2011). The Model Penal Code has a similar provision (Model Penal Code \u00a7\u00a0241.1(3)). In addition, many jurisdictions have a provision that witnesses who refuse<\/em> to take an oath shall have the option of making a nonreligous affirmation that has the same legal effect<\/strong> as the oath (42 Pa. Cons. Stat. Ann. \u00a7 5901, 2011). The Model Penal Code allows for an \u201coath or equivalent affirmation\u201d (Model Penal Code \u00a7\u00a0241.1(1)).<\/p>\n <\/div>\n

    \n

    Perjury Criminal Intent<\/h2>\n

    As stated previously, in many jurisdictions, the defendant must know<\/strong> that a statement is false or must make the statement with the specific intent<\/strong> or purposely<\/strong> to deceive<\/em>. When the intent requirement is general intent or knowledge that the statement is false, proof that the statement is false could give rise to an inference of intent (State v. Kimber, 2011).<\/p>\n <\/div>\n

    \n

    Materiality Requirement<\/h2>\n

    Perjury generally requires a false statement that is material<\/strong>, which means that it substantially affected or could substantially affect the outcome of the proceeding (Mo. Ann. Stat. \u00a7 575.040, 2011). In many jurisdictions and federally, materiality is a question of fact for the trier of fact, which could be a jury<\/strong> (U.S. v. Guadin, 2011). The Model Penal Code defines materiality as a statement that could have affected the course or outcome of the proceeding and declares that materiality should be a question of law, which means it should be determined by a judge<\/strong>, not a jury<\/em> (Model Penal Code \u00a7\u00a0241.1(2)). Typically, it is not<\/em> a defense to perjury that the defendant did not know<\/strong> that the statement was material (Mo. Ann. Stat. \u00a7 575.040(3), 2011). The Model Penal Code has a similar provision (Model Penal Code \u00a7\u00a0241.1(2)).<\/p>\n <\/div>\n

    \n

    Corroborative Evidence Requirement<\/h2>\n

    Some jurisdictions have a requirement of corroborative evidence for perjury, which necessitates the testimony of two witnesses<\/strong> to support a conviction, similar to a treason conviction (Tex. Code of Criminal Procedure, \u00a7 38.18, 2011). The Model Penal Code also has this corroborative evidence requirement (Model Penal Code \u00a7\u00a0241.1(6)).<\/p>\n <\/div>\n

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    Defense of Retraction<\/h2>\n

    Many jurisdictions provide a defense to perjury if the defendant retracts<\/strong> his or her false statement in the course of the same proceeding in which it was made before it becomes manifest that the falsification will be exposed (Ala. Code \u00a7 13A-10-107, 2011). The Model Penal Code has a similar provision (Model Penal Code \u00a7\u00a0241.1(4)).<\/p>\n <\/div>\n

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    Example of a Case Lacking an Element of Perjury<\/h2>\n

    Marcus is a witness in a civil suit for damages against Lindsay. Macy\u2019s department store is suing Lindsay for the alleged theft of a diamond necklace. Marcus takes an oath sworn by the court commissioner. He thereafter testifies that he saw Lindsay try on the necklace and then walk out of the store without paying for it. When the Macy\u2019s attorney asks Marcus what he was doing at Macy\u2019s, Marcus responds that he was buying some jewelry as a gift for his wife. In actuality, Marcus was shopping for jewelry as a gift for his girlfriend<\/em>. Marcus has probably not committed perjury in this case. Marcus is testifying as a witness in a civil<\/em> rather than criminal<\/em> trial, but this satisfies the perjury requirement that the testimony be offered during a judicial<\/strong> or official<\/strong> proceeding. Before testifying, Marcus took an oath that was administered by a court commissioner, also satisfying the perjury requirement that the defendant take an oath administered by someone with the legal authority<\/em> or authorization<\/em> to take evidence under oath. Marcus\u2019s statement is false<\/em>, and he made the statement with knowledge<\/strong> of its falsity, which satisfies the perjury criminal intent requirement. However, Marcus\u2019s statement does not appear to be material<\/strong> to this judicial proceeding because the reason for Marcus\u2019s presence at Macy\u2019s will not affect the outcome of Lindsay\u2019s civil theft trial (usually called the tort of conversion). Thus Marcus is probably not subject to prosecution for and conviction of perjury, based on his testimony in this case.<\/p>\n <\/div>\n

    \n

    Example of Perjury<\/h2>\n

    Review the example in Section 13 \"Example of a Case Lacking an Element of Perjury\"<\/a> with Marcus. Change this example so that Marcus testifies that he did not<\/em> see Lindsay walk out of the Macy\u2019s department store without paying for the necklace because he does not want to admit that he was shopping for jewelry to buy his girlfriend. Anthony, the Macy\u2019s civil trial attorney, cross-examines Marcus, and forces him to admit that he saw Lindsay steal the necklace, and that he was lying<\/em> previously. Marcus has most likely committed perjury in this example. Marcus made a false<\/strong> statement, under a validly administered oath<\/strong>, in a judicial<\/strong> proceeding, with knowledge<\/strong> of its falsity. Marcus\u2019s statement was material<\/strong> because, if believed, it would have helped exonerate Lindsay in her civil case. In many jurisdictions, the trier of fact, which could be a judge or jury<\/em>, determines whether or not the statement is material. Marcus\u2019s admission that he was lying is not a retraction<\/strong> that could serve as a defense because it was not made until the lie was about to be exposed. Thus all the elements of perjury appear to be present, and Marcus may be subject to prosecution for and conviction of this offense.<\/p>\n

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    Figure 13.6<\/span> Diagram of Defenses to Perjury<\/p>\n \"Diagram<\/a><\/div>\n <\/div><\/div>\n

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    Perjury by Inconsistent Statements<\/h2>\n

    Some jurisdictions criminalize perjury by inconsistent or contradictory statements<\/a><\/span>, which is slightly different from criminal perjury (Ala. Code \u00a7 13-10-104, 2011).3 Perjury by inconsistent statements is easier to prove than traditional perjury because the prosecution can simply offer evidence that the defendant made statements that are inconsistent, in a judicial proceeding, after taking a validly administered oath. Corroborative evidence is not required, and the prosecution does not have the burden of proving that one of the statements is false, just that one or the other was false and not believed by the defendant to be true (Ala. Code \u00a7 13A-10-104, 2011). The Model Penal Code has a similar provision (Model Penal Code \u00a7\u00a0241.1(5)).<\/p>\n

    \n

    Example of Perjury by Inconsistent Statements<\/h2>\n

    Review the example with Marcus in Section 13 \"Example of Perjury\"<\/a>. If Marcus\u2019s jurisdiction criminalizes perjury by inconsistent statements, Marcus could most likely be prosecuted for this offense. Marcus made two inconsistent statements while under a validly administered oath in Lindsay\u2019s conversion trial, which is a judicial proceeding. In Marcus\u2019s criminal perjury by inconsistent statements prosecution, the prosecutor need only offer evidence of the inconsistent statements to the trier of fact. The prosecutor does not<\/em> have to provide corroborative evidence and does not<\/em> have the burden of proving that the first statement was false<\/strong>, which will simplify and expedite the trial and may subject Marcus to conviction of this offense.<\/p>\n <\/div>\n <\/div>\n

    \n

    Subornation of Perjury<\/h2>\n

    Most jurisdictions criminalize subornation of perjury<\/a><\/span>, which is typically procuring another to commit perjury (criminal act<\/strong>) with specific intent<\/strong> or purposely<\/strong>, or general intent<\/strong> or knowingly<\/strong>, and factually<\/strong> and legally causing<\/strong> the resulting harm<\/strong> that perjury is in fact committed<\/em> (N.C. Gen. Stat. \u00a7 14-210, 2011).<\/p>\n

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    Example of a Case Lacking an Element of Subornation of Perjury<\/h2>\n

    Review the example given with Marcus in Section 13 \"Example of Perjury\"<\/a>. Add to this example and assume that Marcus begs Janelle, another witness in Lindsay\u2019s conversion trial, to say that she did not see him at Macy\u2019s the day Lindsay stole the necklace. Janelle flatly refuses. Marcus has not committed subornation of perjury in this case. Although Marcus tried<\/em> to procure Janelle to commit perjury<\/strong>, with specific intent<\/strong> or purposely<\/strong>, Janelle did not cooperate and did not commit the perjury. Thus the harm<\/strong> element of subornation of perjury is lacking<\/em>, and Marcus can be prosecuted only for attempted<\/em> subornation of perjury or solicitation<\/em> to commit perjury, rather than the completed offense.<\/p>\n

    \n

    Figure 13.7<\/span> Comparison of Perjury by Inconsistent Statements and Subornation of Perjury<\/p>\n \"Comparison<\/a><\/div>\n <\/div>\n <\/div><\/div>\n

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    Perjury Grading<\/h2>\n

    Perjury is generally graded<\/strong> as a felony (N.C. Gen. Stat. \u00a7 14-209, 2011), with a potential sentencing enhancement for committing perjury that causes another to be sentenced to prison or the death penalty (Ga. Code tit. 16, \u00a7 16-10-70, 2011). The Model Penal Code grades perjury as a felony of the third degree (Model Penal Code \u00a7\u00a0241.1(1)). Subornation of perjury is also graded<\/strong> as a felony (N.C. Gen. Stat. \u00a7 14-210, 2011). However, because of the procedural difficulties in successfully convicting a defendant of perjury and subornation of perjury, these crimes are not often prosecuted. Nonetheless, the threat of a felony conviction still serves as a deterrent and helps to ensure that witnesses testify truthfully in judicial and official proceedings and give accurate statements in certified writings.<\/p>\n <\/div>\n <\/div>\n

    \n

    Bribery Elements<\/h2>\n

    Bribery<\/a><\/span> is often compared to extortion<\/strong>, yet extortion is considered a crime of threatened force or violence, while bribery involves financial inducement (U.S. v. Adcock, 2011). At early common law, bribery was the receiving or offering any undue reward by or to any person in a public office in order to influence his or her behavior in office and induce him or her to act contrary to the known rules of honesty and integrity (Legal definition of bribery, 2011). In modern times, many criminal statutes define bribery as conferring, offering, agreeing to confer, or soliciting, accepting, or agreeing to accept any benefit<\/em> upon a public official (criminal act<\/strong>) with the specific intent<\/strong> or purposely<\/strong> or the general intent<\/strong> or knowingly<\/strong> to form an agreement or understanding that the public official\u2019s vote, opinion, judgment, action, decision, or exercise of discretion will be influenced<\/em> by the benefit (N.Y. Penal Law \u00a7 200.00, 2011; N.Y. Penal Law \u00a7 200.10). The crime of bribery is often extended to apply to persons other than public officials, such as employees, agents, or fiduciaries for the purpose of influencing the bribed individual\u2019s on-the-job conduct (N.Y. Penal Law \u00a7 180.00, 2011). This type of bribery is typically called commercial bribery<\/a><\/span> (N.Y. Penal Law \u00a7 180.00, 2011). Bribery can also cover members of a state legislature (Cal. Penal Code \u00a7 85, 2011; Cal. Penal Code \u00a7 86; Cal. Penal Code \u00a7 93), any judicial officer, juror, referee, umpire (Cal. Penal Code \u00a7 92, 2011), or witness (Or. Rev. Stat. \u00a7 162.265, 2011; Or. Rev. Stat. \u00a7162.275, 2011) when a bribe is conferred or offered, asked for, received, or agreed to be received to influence their vote or decision. The Model Penal Code criminalizes as bribery the act of conferring, offering, agreeing to confer, soliciting, accepting, or agreeing to accept any pecuniary<\/a><\/span> (which means monetary<\/strong>) benefit in exchange for a public servant, party official, voter\u2019s decision, opinion, recommendation, vote, or other exercise of discretion (Model Penal Code \u00a7\u00a0240.1(1)). The Model Penal Code also criminalizes as bribery the act of conferring, offering, agreeing to confer, soliciting, accepting, or agreeing to accept any<\/em> benefit in exchange for a judicial or administrative officer\u2019s decision, vote, recommendation, or other exercise of official discretion (Model Penal Code \u00a7\u00a0240.1(2)).<\/p>\n

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    Prosecutorial Burden in Bribery Prosecutions<\/h2>\n

    Similar to perjury, bribery is notoriously difficult<\/em> to prove<\/em>, which is a factor prosecutors must consider when deciding whether or not to charge an individual(s) with this offense. The most difficult bribery element to prove beyond a reasonable doubt is the criminal intent element of specific intent<\/strong> or purposely<\/strong> or general intent<\/strong> or knowingly<\/strong> to enter into an agreement that influences<\/em> the bribed individual\u2019s decision.<\/p>\n <\/div>\n

    \n

    Example of Bribery<\/h2>\n

    Isabel, a defendant on trial for perjury, notices the judge presiding in her case shopping at Macy\u2019s department store. Isabel thereafter buys an expensive watch, has it wrapped, walks up to the judge, and offers it to him as a gift. Isabel has most likely committed bribery in this case. Although the judge did not accept Isabel\u2019s \u201cgift,\u201d most states criminalize as bribery the offer<\/strong> of any benefit, so the act of bribery is complete when Isabel proffers the watch. In addition, based on these facts, Isabel\u2019s connection to the judge is only through her perjury prosecution, so her act appears calculated to influence his decision in that case, especially because the watch is expensive and not merely a token. Note that a prosecutor is required to prove beyond a reasonable doubt<\/em> Isabel\u2019s specific intent<\/strong> or purposely<\/strong> or general intent<\/strong> or knowingly<\/strong> to enter into an agreement with the judge influencing his decision, which is challenging even under the obvious circumstances apparent in this case.<\/p>\n <\/div>\n

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    Another Example of Bribery<\/h2>\n

    Review the example with Isabel in Section 13 \"Example of Bribery\"<\/a>. Add to this example and assume that the judge graciously accepts Isabel\u2019s gift and thereafter rules in her favor, acquitting<\/em> her of perjury. In this example, both<\/em> the judge and Isabel have likely committed bribery because most states criminalize the conferring, offering, and<\/em> accepting<\/strong> and receiving<\/strong> a bribe as the criminal act elements. Thus both Isabel and the judge may be subject to prosecution for and conviction of this offense, and the judge\u2019s acquittal of Isabel will ease the prosecutor\u2019s burden in proving the specific intent<\/strong> or purposely<\/strong> or general intent<\/strong> or knowingly<\/strong> to enter into an agreement corruptly influencing the decision making in this case.<\/p>\n <\/div>\n

    \n

    Example of a Case Lacking an Element of Bribery<\/h2>\n

    Isabel notices a gentleman struggling to pay his bill at a local coffee shop. Isabel steps up and charitably offers to pay the gentleman\u2019s bill. Later in the day, while watching her son\u2019s professional baseball game, Isabel notices that the umpire looks familiar. After pondering it for a few minutes, she realizes that he is the same gentleman who could not pay his bill at the coffee shop. Isabel and the umpire probably have not<\/em> committed bribery in this case. Although Isabel gave the umpire money, and he was the decision maker in her son\u2019s baseball game, Isabel did not give the money, nor did the umpire accept it, with the specific intent<\/strong> or purposely<\/strong> or general intent<\/strong> or knowingly<\/strong> to enter into an agreement influencing<\/em> the umpire\u2019s decisions. Thus the criminal intent element for bribery appears to be lacking, and neither Isabel nor the umpire are subject to prosecution for and conviction of this offense.<\/p>\n <\/div>\n

    \n

    Bribery When No Authority to Act Is Present<\/h2>\n

    In many states and under the Model Penal Code, it is no defense<\/em> to bribery that the individual bribed does not<\/em> have the authority<\/strong> to act or make the decision that is the subject of the bribe (Model Penal Code \u00a7\u00a0240.1) (Ala. Code \u00a7 13A-10-61, 2011).<\/p>\n <\/div>\n

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    Example of Bribery When No Authority to Act Is Present<\/h2>\n

    Review the example with Isabel and the judge in Section 13 \"Another Example of Bribery\"<\/a>. Change this example and assume that the \u201cjudge\u201d in question is an imposter who is merely masquerading as a judge to live out a lifelong fantasy. Isabel and the \u201cjudge\u201d may still be prosecuted for and convicted of bribery in many jurisdictions and under the Model Penal Code because lack of authority<\/strong> is typically not a defense<\/em> to bribery under modern statutes criminalizing this offense.<\/p>\n

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    Figure 13.8<\/span> Diagram of Defenses to Bribery<\/p>\n \"Diagram<\/a><\/div>\n <\/div>\n

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    Bribery Grading<\/h2>\n

    Bribery is typically graded<\/strong> as a felony (N.Y. Penal Law \u00a7 200.00, 2011) with enhancements for bribery that is carried out with a larger sum of money (N.Y. Penal Law \u00a7 200.03, 2011) or bribery that results in someone\u2019s prosecution or incarceration for a felony (N.Y. Penal Law \u00a7 200.04, 2011). When a state legislator (Cal. Penal Code \u00a7 88, 2011) or a public official (Cal. Penal Code \u00a7 74, 2011) commits bribery, it is typical to disqualify<\/strong> that individual from his or her office for life, in addition to any other sentence.<\/p>\n <\/div>\n <\/div>\n

    \n

    Obstruction of Justice<\/h2>\n

    Obstruction of justice<\/a><\/span> takes many forms and is a classic example of an offense against the administration of justice. States and the federal government exercise broad latitude in enacting statutes that criminalize interference with any aspect of law enforcement procedure or the prosecution and conviction of criminal offenders. Some typical examples of obstruction of justice are as follows: giving false identification to a law enforcement officer (720 ILCS \u00a7 5\/31-4.5, 2011), impersonating a law enforcement officer (Fla. Stat. Ann. \u00a7 843.08, 2011), refusing to aid a law enforcement officer when requested (N.Y. Penal Law \u00a7 295.10, 2011), giving false evidence (720 ILCS \u00a7 5\/31-4, 2011), hiding or concealing oneself and refusing to give evidence (720 ILCS \u00a7 5\/31-4, 2011), tampering with evidence (Or. Rev. Stat. \u00a7 162.295, 2011), and tampering with a witness (18 U.S.C. \u00a7 1512, 2011) or juror (Ariz. Rev. Stat. \u00a7 13-2807, 2011). All these acts are generally supported by specific intent<\/strong> or purposely<\/strong> or general intent<\/strong> or knowingly<\/strong>. The Model Penal Code prohibits threatening unlawful harm to any person or public servant with purpose to influence his decision, opinion, recommendation, vote, or other exercise of discretion (Model Penal Code \u00a7\u00a0240.2). Obstruction of justice offenses are most often graded<\/strong> as a misdemeanor or felony, depending on the offense.<\/p>\n

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    Example of Obstruction of Justice<\/h2>\n

    Barry Bonds, a baseball player and record-breaking home run hitter for the San Francisco Giants, was found guilty by a federal jury for obstruction of justice<\/strong>, based on his refusal to answer a question during a grand jury investigation of his steroid use (Macur, J., 2011). Bonds was also charged with three counts of perjury<\/strong>, but the jury could not agree to convict, resulting in a mistrial on all three counts (Ortiz, J. L., 2011). The perjury charges stemmed from Bonds\u2019s claim while testifying under oath that he never knowingly used steroids, never knowingly used human growth hormones, and was never injected with a substance by anyone other than his trainer. The obstruction of justice conviction resulted from Bonds\u2019s evasive answer to the question of whether his personal trainer had ever injected him with steroids (Macur, J., 2011). Instead of answering yes or no to this question, Bonds began reminiscing about his friendship with the trainer, who went to prison four times in five years for also refusing to testify in the investigation (Macur, J., 2011). The perjury charges support the obstruction of justice charge, so the defense asked for a court dismissal of the obstruction of justice conviction in order to clear the way for an appeal (Ortiz, J. L., 2011). Note that Bonds\u2019s obstruction of justice<\/strong> charge of evading the question and refusing to give evidence appears easier<\/em> to prove than the perjury<\/strong> charges, which have a daunting criminal intent requirement, as discussed in Section 13 \"Perjury Criminal Intent\"<\/a>.<\/p>\n

    \n

    The Barry Bonds Verdict Video<\/h4>\n

    Associated Press: Bonds Guilty of Obstruction, Jury Hung on Others<\/p>\n

    The verdict in the federal Barry Bonds case is explained in this video:<\/p>\n

    \n (click to see video)<\/a>\n <\/div>\n <\/div>\n <\/div>\n <\/div>\n
    \n

    Additional Crimes against the Government<\/h2>\n

    Additional crimes against the government that impair the orderly administration of justice are contempt<\/strong> (N.C. Gen. Stat. \u00a7 5A-11, et seq., 2011), resisting arrest<\/strong> (18 Pa. Cons. Stat. Ann. \u00a7 5104, 2011), and escape<\/strong> (Tex. Penal Code \u00a7 38.06, 2011). Review the statutes in the endnotes for common elements and grading of these offenses.<\/p>\n

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    Figure 13.9<\/span> Diagram of Perjury, Bribery, and Obstruction of Justice<\/p>\n \"Diagram<\/a><\/div><\/div>\n

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    Key Takeaways<\/h3>\n