Michael Joseph Anderson v. Commonwealth of Virginia, 0052164

Michael Anderson, a jail inmate, filed a sworn criminal complaint to a magistrate accusing Deputy David Weeks of assault during a meal-tray exchange; a jail surveillance video recorded the interaction.
Weeks testified he lightly touched Anderson’s arm to remove it from the tray slot and denied closing the slot on Anderson’s arm; he reported the incident to a supervisor and later prepared a statement.
Lieutenants Richardson and Snell reviewed the video; Richardson concluded no assault occurred and directed that Anderson be taken to a magistrate; Snell observed Anderson had a complaint form when taken to the magistrate.
Anderson testified he felt the tray slot close on his wrist, causing pain, sought medical treatment, and later (12 days after) completed the sworn criminal complaint describing a “vicious” and “smashed” assault.
At trial the jury viewed the surveillance video, heard conflicting testimony about whether Anderson’s arm was injured by Weeks, and convicted Anderson of perjury for his sworn statements to the magistrate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Commonwealth proved Anderson made a false statement under oath	The video and testimony show Anderson’s complaint was false; jury may reject his account	Anderson believed his statements were true based on his perception and medical complaints	Court affirmed: jury could find the sworn statements false given the video and other testimony
Whether the false statement was willfully made	Commonwealth: jury properly inferred willfulness from contradictions and video	Anderson: he sincerely believed the events occurred as he described	Court affirmed: credibility resolved against Anderson; belief not reasonable given evidence
Whether the statements were material for perjury	Commonwealth: sworn allegation of assault could have led magistrate to issue a warrant	Anderson: specific terms like “viciously” and “smashed” were immaterial	Court affirmed: the complaint as a whole alleged an offense and was material to magistrate’s action
Whether the criminal complaint was properly authenticated	Commonwealth: circumstantial evidence (Snell’s testimony, Richardson’s copy, Anderson’s own identification) sufficed	Anderson: admitting the document lacked proper authentication because Snell didn’t directly handle it	Court affirmed: trial court did not abuse discretion; circumstances and Anderson’s identification authenticated it

Williams v. Commonwealth, 49 Va. App. 439 (en banc) (standard of viewing evidence on appeal)
Jackson v. Commonwealth, 267 Va. 666 (standard for reviewing sufficiency of evidence)
Jackson v. Virginia, 443 U.S. 307 (standard that sufficiency review asks whether any rational trier of fact could find guilt)
Spencer v. Commonwealth, 238 Va. 275 (review standard and affirming verdict unless plainly wrong)
Keffer v. Commonwealth, 12 Va. App. 545 (corroboration requirement in perjury prosecutions)
Donati v. Commonwealth, 37 Va. App. 575 (videotape as competent, authenticated evidence)
Holz v. Commonwealth, 220 Va. 876 (defendant’s belief that statements are true negates willfulness)
Flanagan v. Commonwealth, 58 Va. App. 681 (credibility determinations and rejection of self-serving testimony)
Ragland v. Commonwealth, 16 Va. App. 913 (authentication of writings and relevance/ materiality)
Brooks v. Commonwealth, 15 Va. App. 407 (photographs and videotapes as independent, silent witnesses)