People v. Workman

Defendant was convicted of the crime of perjury in the first degree for testifying falsely before a Grand Jury. The People established beyond a reasonable doubt that defendant had given false answers in a questionnaire which he had submitted to the Grand Jury.

The questionnaire had been prepared by the District Attorney and contained sixty-eight numbered answers. Before a charge of perjury is predicated upon the answers in such a questionnaire, the questions should be clear, simple, direct and unambiguous. They should be phrased so that a person of average intelligence may determine exactly…