State v. Williams, 60 So. 3d 1189

Defendant was charged by bill of information with false swearing for purposes of violating public health or safety under La.R.S. 14:126.1 after an incident at a Zwolle Kwik Stop where a Wildlife and Fisheries agent allegedly restrained him at gunpoint.
Defendant initially telephoned a complaint and later sent a written, signed form stating the facts were true; the form did not purport to be an sworn affidavit.
The information charged a violation of 14:126.1, but defendant moved to quash arguing the statute is vague because it does not require an oath.
The Third Circuit quashed the prosecution, but the Supreme Court granted review and reversed, remanding for further consideration of remaining issues.
The Court held that 14:126.1 does not require the false statement to be made under oath and that the statute must be read in light of its broader statutory context and the plain text of 1960 enactment.
The Court emphasized the legislative history and statutory construction principle that words should be given their plain meaning, with the title not controlling the interpretation when the text is unambiguous.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does 14:126.1 require an oath or equivalent affirmation?	Williams argues statute requires oath via related sworn provisions.	Williams argues the title misleads and the text should be read with 14:125/14:126 to require oath.	No oath required; statute does not mandate oath or affirmation.
Is 14:126.1 vague or misdescriptive due to its title?	Williams contends title misleads about oath requirement.	Williams contends ambiguity, urging interpretation with related provisions.	Title may be disregarded; text controls and is not fatally vague.
Should 14:126.1 be read in pari materia with the sworn-speech provisions of 14:123-14:126?	Williams advocates reading in tandem with sworn-speech scheme to require oath.	Williams contends the 1960 enactment stands alone; not tied to oath requirement.	14:126.1 does not require oath; however, the broader context supports plain reading of text.
Are there constitutional or equal-protection concerns due to historical context or criminal penalties?	Disparate application and heightened penalties raise concerns.	Statute plainly defines false statements to protect public welfare; no due process issue.	Court does not base decision on equal-protection concerns; focuses on statutory interpretation.

State v. Marshall, 424 So.2d 423 (La.App. 2nd Cir. 1983) (statutory context of 14:126.1 and oath-like requirements; legislative history cited)
State v. Williams, 38 So.3d 1180 (La.App. 3rd Cir. 2010) (read 14:126.1 in pari materia with sworn-speech provisions)
State v. Legendre, 362 So.2d 570 (La.1978) (limits on indictment defenses when element cannot be satisfied)
Cat’s Meow v. City of New Orleans, 720 So.2d 1186 (La.1998) (different interpretive weight given to the title of a statute)
Theriot v. Midland Risk Ins. Co., 694 So.2d 184 (La.1997) (read statutes related to same subject matter in context)
Connecticut Nat. Bank v. Germain, 503 U.S. 249 (1992) (textual plain-meaning canon: interpret statutes by their words)
State v. Modere, 352 So.2d 666 (La.1977) (title not controlling when text unambiguous)
State v. Gutweiler, 979 So.2d 469 (La. 2008) (interpretation of related statutes in pari materia)