Hawaii Revised Statutes
710. Offenses Against Public Administration
710-1067 Corroboration. §710-1067 Commentary:

§710-1067 Corroboration. In any prosecution under this part, except a prosecution based upon inconsistent statements pursuant to section 710-1065, falsity of a statement may not be established solely through contradiction by the testimony of a single witness. [L 1972, c 9, pt of §1]
COMMENTARY ON §710-1067
This section forbids convictions for perjury based solely upon the contradictory testimony of a single witness. Either some additional corroborating evidence or the contradictory testimony of an additional witness is needed for conviction.
The rationale for this rule is that the requirement is necessary as a safeguard to induce witnesses to testify freely.[1] Obtaining voluntary testimony in any proceeding would be difficult if the witness might be harassed upon the word of a disappointed litigant.[2] And if the witness were required to testify, it would seem that similar protection ought to be given the witness.
The policy question to be decided, then, is whether the overall protection and encouragement of persons who give statements (in the contexts specified by the offenses in this part) is worth foregoing occasionally the conviction of an apparent falsifier. The Code takes the position that it is. There is also an additional safeguard involved in protecting the innocent person. The protection rests upon the argument that since equally honest persons may well have different recollections of the same events, a conviction for a falsification offense ought not to rest upon the contradiction of two statements. Otherwise, an innocent person would be subject to prosecution every time another person, under oath, disputed the innocent person's recollection.[3]
This section would apply only to a relatively narrow class of cases which would not often be prosecuted. The section operates only where there is no evidence but the testimony of a single contradicting witness. Hence, one may view this section as a special gloss on the requirement of proof beyond a reasonable doubt, equivalent to stating that no case of a contradicting statement under oath, without more, can satisfy the general requirement of proof beyond a reasonable doubt in falsification cases.[4]
The Hawaii case law is that a person accused of perjury may be convicted only upon the testimony of two credible witnesses, or of one credible witness corroborated by other evidence sufficient to satisfy the trier of fact, beyond a reasonable doubt, as to the guilt of the accused.5 Here, the Code is essentially in accord with the Hawaii rule, but codifies it, lends it greater clarity, and extends it to all falsification offenses in this part.
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§710-1067 Commentary:
1. See United States v. Weiler, 323 U.S. 606 (1944).
2. Prop. Mich. Rev. Cr. Code §4920, comments at 402.
3. See Weiler, supra.
4. Prop. Mich. Rev. Cr. Code, comments at 403.
5. See Territory of Hawaii v. Shite, 43 Haw. 203 (1957).

Structure Hawaii Revised Statutes

Hawaii Revised Statutes

Title 37. Hawaii Penal Code

710. Offenses Against Public Administration

710-1000 Definitions of terms in this chapter.

710-1001 Forfeiture of property used as benefit or pecuniary benefit in the commission of an offense defined in this chapter. §710-1001 Commentary:

710-1010 Obstructing government operations. §710-1010 Commentary:

710-1010.5 Interference with reporting an emergency or crime.

710-1011 Refusing to aid a law enforcement officer. §710-1011 Commentary:

710-1012 Refusing to assist in fire control. §710-1012 Commentary:

710-1013 Compounding. §710-1013 Commentary:

710-1014 Rendering a false alarm. §710-1014 Commentary:

710-1014.5 Misuse of 911 emergency telephone service.

710-1015 False reporting to law-enforcement authorities. §710-1015 Commentary:

710-1016 Impersonating a public servant. §710-1016 Commentary:

710-1016.3 Obtaining a government-issued identification document under false pretenses in the first degree. (1) A person commits the offense of obtaining a government-issued identification document under false pretenses in the first degree if that pe...

710-1016.4 Obtaining a government-issued identification document under false pretenses in the second degree. (1) A person commits the offense of obtaining a government-issued identification document under false pretenses in the second degree if that...

710-1016.5 REPEALED. L 1987, c 130, §2.

710-1016.6 Impersonating a law enforcement officer in the first degree.

710-1016.7 Impersonating a law enforcement officer in the second degree.

710-1016.8 Presumptions.

710-1016.9 Defense.

710-1017 Tampering with a government record. §710-1017 Commentary:

710-1017.5 Sale or manufacture of deceptive identification document; penalties.

710-1018 Securing the proceeds of an offense. §710-1018 Commentary:

710-1019 Destroying or defacing official notices; penalty.

710-1020 Escape in the first degree.

710-1021 Escape in the second degree. § §710-1020 And 710-1021 Commentary:

710-1022 Promoting prison contraband in the first degree.

710-1023 Promoting prison contraband in the second degree. § §710-1022 And 710-1023 Commentary:

710-1024 Bail jumping in the first degree.

710-1025 Bail jumping in the second degree.

710-1026 Resisting arrest. §710-1026 Commentary:

710-1026.9 Resisting an order to stop a motor vehicle in the first degree.

710-1027 Resisting an order to stop a motor vehicle in the second degree.

710-1028 Hindering prosecution; definition of rendering assistance.

710-1029 Hindering prosecution in the first degree.

710-1030 Hindering prosecution in the second degree. § §710-1028 To 710-1030 Commentary:

710-1031 Intimidating a correctional worker.

710-1040 Bribery. §710-1040 Commentary:

710-1060 Perjury.

710-1061 False swearing in official matters.

710-1062 False swearing.

710-1063 Unsworn falsification to authorities. § §710-1060 To 710-1063 Commentary:

710-1064 Retraction. §710-1064 Commentary:

710-1065 Inconsistent statements. §710-1065 Commentary:

710-1066 No prosecution based on previous denial of guilt. §710-1066 Commentary:

710-1067 Corroboration. §710-1067 Commentary:

710-1068 Irregularities no defense. §710-1068 Commentary:

710-1069 Misrepresenting a notarized document in the first degree.

710-1069.5 Misrepresenting a notarized document in the second degree.

710-1070 Bribery of or by a witness. §710-1070 Commentary:

710-1071 Intimidating a witness.

710-1072 Tampering with a witness. §710-1072 Commentary:

710-1072.2 Retaliating against a witness.

710-1072.5 Obstruction of justice.

710-1073 Bribery of or by a juror.

710-1074 Intimidating a juror.

710-1075 Jury tampering. § §710-1073 To 710-1075 Commentary:

710-1075.5 Retaliating against a juror.

710-1076 Tampering with physical evidence. §710-1076 Commentary:

710-1077 Criminal contempt of court. §710-1077 Commentary:

710-1078 Disrespect of a house of the legislature.