Also known as: materiality rules · materiality
Written by attorneys · grounded in primary & secondary sources — see below
A doctrinal requirement that a false statement possess the capacity to influence some phase or detail of a judicial proceeding. The prosecution must both allege and prove this element in a perjury case. Where the element would be absent even if the defendant completed every intended act under the circumstances she believed to exist, attempt liability is foreclosed.
Marcus Mitchell asked a witness to swear that a deed had been delivered on a date when no delivery occurred. The date had no bearing on any issue before the court. Because the statement would lack materiality even if the witness had testified exactly as Mitchell planned, the attempt charge cannot stand.
Miguel Mendoza submitted loan documents containing inflated property values to HUD. The trial judge refused to let the jury decide whether the values could have affected agency decisions. The Supreme Court held that materiality under the statute is an element for the jury to determine.
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Matthew Martinez sought internal agency memos in a selective-prosecution claim. The government resisted, arguing the memos were not material to the defense. The court examined whether the documents could support a claim that similarly situated persons were not prosecuted.
Meridian Motors alleged a pattern of mail fraud in its RICO suit against a supplier. The court required proof that each predicate act contained a material misrepresentation capable of influencing the recipient. Acts lacking that capacity were dismissed from the pattern.
A reporter at Millennium Media traded on advance knowledge of a column that would move stock prices. The court assessed whether the nonpublic column content was material by asking whether a reasonable investor would have viewed it as altering the total mix of information.
A state statute granted an ice-plant monopoly to an existing firm. The dissent argued that the distinction between new entrants and incumbents was not material to any legitimate public purpose and therefore could not justify the restraint under the Fourteenth Amendment.
A statement is material if it has the potential to influence or affect in any way some phase or detail of the judicial proceeding. The prosecution must allege and prove this element.
Yes. If the statement would lack materiality even if the defendant completed every intended act under the believed circumstances, attempt liability is foreclosed because no crime would have been committed.
The jury must decide whether the false statement was material because materiality is an element of the offense.
…of the evidence to have determined the outcome. Accordingly, the appropriate test for prejudice finds its roots in the test for materiality of exculpatory information not disclosed to the defense by the prosecution, United States v. Agurs, 427 U.S., at 104, 112-113, 96 S.Ct., at 2397, 2401-2402, and in the test for materiality…