Quick Summary
Bennett Meyers was convicted of suborning perjury related to Lamarre’s testimony before a Senate subcommittee. Meyers argued his conviction was unsupported by evidence, focusing on his alleged financial interests in Aviation Electric Corporation and the use of a Cadillac automobile.
Facts of the Case
Bennett Meyers, an officer in the United States Army, founded the Aviation Electric Corporation in Ohio in 1939 with an initial capital of $500. Shares were distributed among employees as the company manufactured airplane parts and secured substantial Army Signal Corps contracts. Bleriot Lamarre joined as secretary-treasurer after receiving a large portion of shares without any consideration. The company grew swiftly, with loans secured by stock pledges being repaid by 1942.
Investigations into national defense contracts prompted Senate hearings where Lamarre testified about Meyers’ involvement with Aviation Electric. He claimed Meyers had no financial interest post-1942, that a Cadillac was purchased for corporate use, and apartment redecoration costs were personal gifts from him to Meyers.
The indictment charged Lamarre with perjury for stating these claims falsely. Meyers was accused of inducing these falsehoods. Despite contesting the interpretation of Lamarre’s testimony, the trial court found Meyers guilty on all counts.
Procedural History
- Lamarre and Meyers were indicted jointly for perjury-related violations following Lamarre’s testimony before a Senate subcommittee.
- Lamarre pleaded guilty to perjury charges on December 19, 1947.
- Meyers pleaded not guilty and was tried by jury in the United States District Court for the District of Columbia.
- The prosecution presented evidence including Lamarre’s Senate testimony transcript and oral evidence from William Rogers.
- Meyers’ motion for acquittal at the close of government’s evidence was denied.
- The jury convicted Meyers on all counts of suborning perjury.
- Meyers appealed to the United States Court of Appeals for procedural and evidentiary issues.
I.R.A.C. Format
Issue
- Whether Meyers was properly convicted of suborning perjury based on misrepresentations about his financial interest in Aviation Electric Corporation from 1940-1947, personal versus corporate use of a Cadillac automobile, and apartment redecoration costs as gifts.
Rule of Law
- A conviction for subornation of perjury requires proof that false statements were knowingly made by the alleged perjuror and procured by another party.
- The best evidence rule prefers original documentation over testimonial recollection where applicable.
- Oral testimony about proceedings may be admitted alongside documentary evidence such as transcripts.
Reasoning and Analysis
The appellate court assessed whether Lamarre’s statements amounted to perjury and if Meyers had induced them. It scrutinized Lamarre’s comprehensive Senate committee testimony detailed in both Rogers’ accounts and stenographic transcripts. The court evaluated whether Lamarre’s trial admissions corroborated his initial falsehoods concerning Meyers’ financial connections and transactions.
The court determined that Lamarre’s claims about Meyers’ lack of interest post-1942 were materially untrue since evidence indicated continued financial ties through loans and pledged securities. It also found credible Lamarre’s trial confession that he was directed by Meyers to provide misleading testimony regarding corporate resources used personally like automobiles and furnishings.
Conclusion
The United States Court of Appeals upheld the district court’s decision convicting Meyers on all counts for suborning perjury. Despite acknowledging procedural complexities during trial, it concluded there was ample evidence supporting each charge against him.
Dissenting Opinions
Judge Prettyman dissented, arguing that presenting Mr. Rogers’ testimonial summary before introducing stenographic transcripts caused prejudicial unfairness against Meyers. He advocated for stricter adherence to evidentiary rules emphasizing best evidence principles by prioritizing documentary records over subjective interpretations in court trials.
Key Takeaways
- A conviction for subornation of perjury requires proof that false statements were knowingly made and procured by another party.
- Oral testimony alongside documentary evidence can establish the truthfulness or falsity of statements made under oath.
- The appellate court found sufficient proof supporting Meyers’ conviction on all counts for suborning perjury.
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