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Licata v. State

Citations: 661 P.2d 1306; 99 Nev. 331; 1983 Nev. LEXIS 444Docket: 13884

Court: Nevada Supreme Court; April 29, 1983; Nevada; State Supreme Court

Narrative Opinion Summary

In this case, the appellant was initially convicted of perjury for providing false statements during an insurance claim process following a burglary at his residence. The central issue involved the statutory interpretation of perjury under NRS 199.120, which necessitates that a false statement be made under oath in a legally mandated setting. At trial, the appellant argued that his false statement regarding the purchase of stolen items was not made under a legally required oath, and thus did not satisfy the statutory criteria for perjury. The court analyzed the statutory requirements and referenced similar jurisdictional rulings, ultimately agreeing with the appellant's argument. Consequently, the court reversed the perjury conviction, concluding that the statement in question did not meet the legal definition as it was not made under a legally required oath. The decision nullified the perjury charge without further examination of other issues raised in the appeal, resulting in the appellant's acquittal on this charge.

Legal Issues Addressed

Definition of Perjury under NRS 199.120

Application: The court determined that the perjury charge against Licata was improperly applied because his statement was not made under a legally required oath.

Reasoning: The court concluded that Licata's statement to the insurance company's attorney was not made under a legally required oath, thus failing to meet the statutory definition of perjury.

Requirements for a Valid Perjury Charge

Application: The court emphasized that a valid perjury conviction must involve a false statement made under oath in a setting where the law mandates such an oath.

Reasoning: The court cited similar rulings from various jurisdictions, affirming that a perjury conviction requires a statement made under oath by law.