People v. Ramos

(for reversal). Joel Ramos was con*546victed of welfare fraud1 and perjury2 for filing a false application for aid to dependent children (ADC) assistance.3 Ramos was sentenced to prison terms of two to four years for the welfare fraud and ten to fifteen years for the perjury.

*547Ramos asserts two grounds for reversing his perjury conviction. First, that the Social Welfare Act4 does not authorize administration of an oath —an element of perjury — to adc applicants. Second, that the requisite oath was not administered.

We hold that because administration of an oath is an element of perjury, and an oath…