Second Degree Perjury Statute

In State v. Wilson, 83 Wash. 419, 145 P. 455 (1915), the Court construed the former second degree perjury statute as limited to statements made in extrajudicial proceedings. The Wilson court reasoned that absent some limitation, the second degree perjury statute (similar to the current false swearing statute) would serve no purpose, as both it and the first-degree perjury statute could be applied to the same "state of facts." Id. at 423. The court rejected an argument that the second degree perjury statute could still be applied to immaterial statements made in judicial proceedings, noting that it is no defense "for perjury in the first degree that the defendant did not know the materiality of his false statement, if it was indeed material and might have affected such proceeding." Id. at 425.