In Matter of Duffy v. Ward, 81 NY2d 127, 612 NE2d 1213, 596 NYS2d 746, the Court made clear that "a misdemeanor conviction for conduct outside the line of duty will be 'a crime involving a violation of the oath of office' under Public Officers Law 30 (1) (e) only if the violation is apparent from the Penal Law's definition of the crime" (81 NY2d at 134). Thus, the Court must look at the elements of the offense--not the facts of a particular case--to determine whether a misdemeanor conviction warrants summary dismissal. The Court further held that an oath of office violation attaches where the statutory elements of the misdemeanor demonstrate "knowing or intentional conduct indicative of a lack of moral integrity" (id. at 135). Hence, under the Duffy rule, more than a general criminal intent is necessary to constitute an "oath of office" crime. To fall within the ambit of Public Officers Law 30 (1) (e), the Court emphasized that the crime must: "Be one demonstrating a lack of moral integrity, it must be one involving willful deceit or a calculated disregard for honest dealings. More than intent or a criminal mens rea is needed for summary dismissal; there must be an intentional dishonesty or corruption of purpose inherent in the act prohibited by the Penal Law" (id.).