State v. Jacobson
In State v. Jacobson, 74 Wn. App. 715, 876 P.2d 916 (1994), the Court of Appeals held that a charge of "false swearing does not require the statement to have been made in an official proceeding." Id. at 726.
In that case, where materiality was not at issue, the court held that an affidavit given in aid of a judicial proceeding comes within the definition of "official proceeding." RCW 9A.72.050.
Pearsall-Stipek argues that Jacobson stands for the proposition that the requirement of an "official proceeding" is the only distinction between perjury and false swearing. Id.