18 Pa. Cons. Stat. § 4904

Section 4904(a)'s lack of a materiality requirement does not prevent unsworn falsification to authorities from being treated as a crime involving moral turpitude.

JURADO · filed 2006-07-01(a)

We find that the materiality of the false statements made is not controlling in this case.

Section 4904(a)(3) makes a conviction for submitting a false object with intent to mislead a public servant a crime involving moral turpitude.

Cisneros-Mayo v. Attorney General United States · filed 2021-05-25(a)(3)

For these reasons, we agree with the BIA that petitioner’s conviction under section 4904(a)(3) constitutes a CIMT.

Section 4904 protects against theft and fraud, an interest shared with federal mail fraud and false statement statutes when applying the bar on successive prosecutions.

Commonwealth v. Mascaro · filed 1978-11-22

The Federal Mail Fraud (18 U.S.C.A. § 1341) and False Statement (18 U.S.C.A. § 1001) statutes are designed to guard against theft and fraud. So too are the state statutes — Theft by Deception (18 Pa.C.S.A. § 3922), Deceptive Business Practices (18 Pa.C.S.A. § 4107), and Unsworn Falsifications to Authorities (18 Pa.C.S.A. § 4904).

Section 4904’s penalties do not apply in election cases; the Election Code’s specific penal provisions govern instead.

In Re Nomination Petition of Farnese · filed 2008-05-09

An un-sworn statement, signed subject to the penalties of perjury in the Crimes Code at 18 Pa.C.S. § 4904, is not a valid affidavit in an election case because the penalties of perjury at 18 Pa.C.S. § 4904 do not apply in an election case.

Section 4904 cannot be used to prosecute a false address on a Voter’s Certificate when the Election Code’s unlawful voting provision covers the same conduct.

Commonwealth v. Bidner · filed 1980-10-24

Since 18 Pa.C. S.A. § 4904 could also proscribe in a general way the same conduct, the two sections are in conflict. As we have already stated, the law will not permit prosecution under the general provisions of the Crimes Code when there are applicable special provisions available.

A financial disclosure statement that omits income can support a conviction under § 4904(a)(1) when the evidence supports a finding that the defendant signed it.

Commonwealth v. Cherpes · filed 1987-01-20(a)(1)

Cherpes filed a financial disclosure statement which failed to disclose certain income from his insurance business. ... Drawing all reasonable inferences in favor of the Commonwealth, we conclude that the jury properly determined that Cherpes violated the elements of § 4904(a)(1).

Section 4904 reaches a blank response to a required criminal-history question when the blank implies that the applicant has no arrests or convictions.

Commonwealth v. Hoffman · filed 1990-07-09

The fact that the word “none” is left to be inferred by the reader, rather than actually written by the applicant, should not put the applicant beyond the reach of the statute in light of the statute’s obvious purpose of encouraging truthfulness in the instances addressed. Defendant was, therefore, properly charged under section 4904.

Section 4904(a)(1) treats a person who supplies information and adopts its written transcription as making a written statement, even if someone else wrote it.

Commonwealth, Aplt. v. Williams, N. · filed 2025-02-19(a)(1)

Rather, Section 4904(a)(1) uses the broader verb “makes,” which encompasses defendant’s actions in supplying the contents of the statement and then adopting it as his own.

Signing a document containing statements the signer knows are false can satisfy § 4904(a)(1)’s written-statement requirement, regardless of who prepared the document.

Com. v. Santiago, A. · filed 2014-08-25(a)(1)

Since Appellant signed a document containing the lies he told to Detective Rivera, the record contains sufficient evidence that he provided a written false statement in violation of § 4904(a)(1).

Section 4904 requires the falsity to be in writing.

Commonwealth v. Shelly · filed 1997-11-18

For example, 18 Pa.C.S. § 4904 requires the falsity to be in writing; 18 Pa.C.S. § 4906 adds the intent to implicate another; and 18 Pa.C.S. § 5105(a)(5) involves aiding another person.

Section 4904(b) requires proof beyond a reasonable doubt that the person did not believe the written statement to be true; a negligent or confused answer alone does not establish that element.

Com. v. Bachner, R. · filed 2020-09-14(b)

Appellant may have been negligent in answering – or failing to research how best to answer – ATF Form Question 11.c. and PSP Form Question 32, but there is insufficient evidence to support a finding beyond a reasonable doubt that Appellant believed his written false statements to be untrue.

Section 4904(b) permits a finding of knowing falsification when a person signs a false firearm purchase form despite knowing of a prior conviction, even if the person claims confusion about the form.

Com. v. Heim, J. · filed 2023-08-09(b)

Next, even assuming that Heim glossed over the terms on the firearm application or, separately, was actually unaware of the lengths of his prior offenses’ sentences, the affixing of his signature at the end of the document constitutes a complete understanding that he has read the form in its entirety and submitted accurate information.

Section 4904(b) requires a written false statement on a form bearing a legally authorized warning that false statements are punishable, made by a person who does not believe the statement is true.

Com. v. Sasse, O. · filed 2020-01-15(b)

To support a conviction for unsworn falsification to authorities, the Commonwealth must establish that a defendant “ma[de] a written false statement which he does not believe to be true, on or pursuant to a form bearing notice, authorized by law, to the effect that false statements made therein are punishable.” 18 Pa.C.S.A. § 4904(b). ... Such evidence is sufficient to establish that Sasse intended to provide false information and that he “knew the answer[s] to be false.”

Section 4904(a)(1) requires a written false statement that the speaker does not believe to be true, made with intent to mislead a public servant performing an official function; knowledge and intent may be inferred from the circumstances.

Commonwealth v. Herd · filed 2007-01-08(a)(1)

A person is guilty of unsworn falsification to authorities if, with intent to mislead a public servant in performing his official function, she makes any written false statement which she does not believe to be true. 18 Pa.C.S. §4904(a)(l). ... Once this court determined that appellant’s written and oral statements to the police were false, in the absence of any testimony suggesting that appellant was incapable by mental disease or defect of knowing that her statements were not true, this court reasonably inferred that appellant’s false reports had been made knowingly and intentionally. Therefore, this court concludes that the evidence was sufficient to sustain the verdict as to both counts.

Section 4904(a)(1) requires a knowingly false written statement made with intent to mislead; an answer given through mistake does not satisfy those elements.

Commonwealth v. Kennedy · filed 2001-12-31(a)(1)

Accordingly, we hold that the jury ignored the unrefuted account that Appellant’s act of filling out Form SP 4-127 (2-98) was the product of a mistake and not the knowing and intentional act of one seeking to deceive.

Section 4904(b) requires a prima facie showing that the person did not believe the written statement to be true; an unclear question on a firearms form, without evidence that the defendant knew his answer was false, did not establish that showing.

Commonwealth v. Turner · filed 2004-12-23(b)

Absent any evidence that the Dubois Regional Medical Center fits within the firearms application’s definition of “mental institution,” the Commonwealth cannot establish that the defendant knew his commitment to the Dubois Regional Medical Center would require him to *24answer “yes” to question 12f on the firearms application. Thus, the Commonwealth cannot establish that the defendant knowingly and intentionally provided a false statement when he answered “no” to question 12f on the firearms application. The Commonwealth did not, therefore, establish its prima facie case.

Section 4904 requires knowingly false information given with intent to mislead a public official in performing official duties.

R.H.S. v. Allegheny County Department of Human Services · filed 2007-11-15

More specifically, it is a crime to provide knowingly false information with the intent to mislead a public official in the performance of his duties. 18 Pa.C.S. § 4904. ... Here, even assuming Tarasí had a duty to investigate Plaintiffs commitment, Plaintiff failed to plead Tarasí acted with the intent to mislead the PSP or make false statements which he knew to be untrue or lacking authenticity.

Section 4904 does not make an earlier claim of inability to pay court costs false merely because the person can pay them later.

J.R. Jae v. Warden Harper · filed 2017-08-14

A present ability to pay costs and fees does not necessarily mean that Appellant made false statements in his petition for in forma pauperis status.

Section 4904(b)’s false-statement element can be satisfied by a “No” answer to the domestic-violence question on ATF Form 4473 when the applicant’s prior simple-assault victim was his live-in girlfriend.

Com. v. Coll, K., Jr. · filed 2017-11-02(b)

Here, the Commonwealth charged Coll with violating both sections 6111(g)(4) and 4904(b) because he responded “No” to Question 11.i on ATF Form 4473, which asked: “Have you ever been convicted in any court of a misdemeanor crime of domestic violence?” ... Because there was evidence Coll lived with his girlfriend, who was the victim of the simple assault, a jury could conclude that Coll was a person “similarly situated” to a spouse of the victim. Therefore, the Commonwealth presented sufficient evidence from which a jury could find that his response on ATF Form 4473 was materially false. Thus, we conclude that the evidence was sufficient to support both convictions.

Section 4904(b) covers knowingly false written answers on a form bearing notice that false statements are punishable; such answers on a firearms transaction form supported a conviction.

Com. v. Washington, W. · filed 2019-09-13(b)

Washington was convicted of unsworn falsification to authorities. A person commits the offense of unsworn falsification to authorities “if he makes a written false statement which he does not believe to be true, on or pursuant to a form bearing notice, authorized by law, to the effect that false statements made therein are punishable.” 18 Pa.C.S.A. § 4904(b). ... This evidence was sufficient to support Washington’s conviction for unsworn falsification to authorities.

Section 4904 supports an unsworn-falsification conviction when a person falsely answers a firearm-purchase form and the jury can infer the required knowledge from the circumstances.

Com. v. Seibert, Jr., S. · filed 2024-01-03(b)

Because Seibert’s prior convictions rendered him ineligible to purchase a firearm and the jury could have inferred the requisite mens rea “from acts or conduct or from the attendant circumstance,” Horlick, 296 A.3d at 63, the evidence was sufficient to convict him of sale or transfer of firearms and unsworn falsification to authorities.

A conviction under § 4904(a) can rest on circumstantial evidence that a defendant intentionally assisted an accomplice in submitting falsified documents to PennDOT.

Com. v. Chaves, L. · filed 2025-08-18(a)

Taken together with Mr. Lucio’s denial that he was the masked individual and testimony regarding Appellant’s involvement in procuring the fraudulent ID, there was sufficient circumstantial evidence for the jury to find that Appellant worked with an unknown accomplice with the intent to submit falsified documents to PennDOT and actively participated in the commission of that offense. See Murphy, supra. As such, the totality of the evidence, viewed in the light most favorable to the Commonwealth as the verdict winner, was sufficient to sustain Appellant’s conviction for unsworn falsification to authorities. See 18 Pa.C.S.A. § 4904(a).

Section 4904 does not create a private civil cause of action for people affected by a false statement intended to mislead a public servant.

Miller, L. v. Daly, J. · filed 2025-12-30

Our review of the language of Section 4904 indicates that it does not expressly create a private right of action for those affected by the making of a false statement intended to mislead a public servant.

Section 4904 is a criminal statute that does not give a private person standing to bring a civil claim for false statements to police.

ROYAL v. MACY'S CORPORATION · filed 2022-09-06

In that Section 4904 is a criminal statute, Royal does not have standing to bring this claim.

Section 4904(a)(1) does not merge with the false reports offense under § 4906(b)(2) for sentencing because each offense has elements the other lacks.

Com. v. Kruskie, S. · filed 2024-07-11(a)(1)

Here, each offense contains elements that the other does not, and the offenses cannot merge for sentencing purposes.

Section 4904 protects the public at large, so an alleged violation does not establish negligence per se.

ROSS v. ROSS · filed 2024-08-02

Accordingly, an alleged violation of 18 Pa. C.S. § 4904 fails to establish negligence per se.