What is the test for knowingly making a false statement of fact in a perjury trial?

California, United States of America


The following excerpt is from People v. Sparks, E059720 (Cal. App. 2015):

Both perjury and welfare fraud require the defendant to knowingly make a false statement of fact. (See People v Guasti (1952) 110 Cal.App.2d 456, 464 ["The intent to swear falsely is the 'specific criminal intent' required in perjury trials."]; People v. Camillo (1988) 198 Cal.App.3d 981, 989, fn. 3 [welfare fraud requires knowingly making a false statement with the intent to deceive or defraud].) Thus, as applied to

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perjury and welfare fraud, a mistake of fact must be actual but it does not have to be reasonable.

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