People v. Ramos

Joel Ramos was convicted by a jury of perjury predicated on false swearing1 and welfare fraud2 in connection with the filing of applications for assistance with the Michigan Department of Social Services.3 On conviction, the defendant was sentenced to concurrent prison terms of ten to fifteen and two to four years, respectively, on the false swearing and welfare fraud convictions.

Ramos challenges his false swearing conviction on the ground that his false application did not constitute false swearing because no "oath” was taken, and that the trial court erred in submitting the issue of…