Texas Dept. of Public Safety v. Caruana
This case arose when respondent was arrested by a state trooper for driving while intoxicated. At issue was whether a peace officer's arrest report must be excluded from evidence if not sworn as required by law. Because it was no less a criminal offense to make a false statement in a governmental record than it was to make one under oath, the court held that an officer's failure to swear to a report did not deprive it of the assurance of veracity or render it inadmissible. Consequently, the court reversed the court of appeals' judgment and remanded.