SHARON MARIE MASON v. STATE OF MARYLAND
Court of Special Appeals, Woodward, Filed Nov. 24, 2015,
Perjury – Video from trooper’s vehicle was sufficient independent corroboration to satisfy the “two-witness rule” required for a perjury conviction

The Court offers criticism of the two-witness rule, but declines to overturn it (leaving that for either the CoA for the legislature)

Perjury – Maryland allows a perjury conviction to stand based on the direct testimony of two witnesses, or the testimony of one witness combined with other independent corroborative evidence

Perjury – In a perjury case with one witness, the corroborating evidence must be:
– independent
– corroborative
– “at least as weighty as a second witness”

Perjury – The testimony of one witness and other independent corroborative evidence must be of such a nature so as to be of equal weight to that of at least a second witness, thus foreclosing any reasonable hypothesis other than the defendant’s guilt. Citing Brown.

Perjury – independent evidence is simply “evidence coming from a source other than that of the direct testimony”

Perjury – Corroborative evidence is sufficient if it tends to substantiate the material part of the principal witness’s testimony