New York Consolidated Laws

N.Y. Penal Law § 210.45 (2026)

Making a punishable false written statement

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§ 210.45 Making a punishable false written statement.
  A person is guilty of making a punishable false written statement when
he knowingly makes a false statement, which he does not believe to be
true, in a written instrument bearing a legally authorized form notice
to the effect that false statements made therein are punishable.
  Making a punishable false written statement is a class A misdemeanor.

Notes of Decisions

Cited in 81 cases (7 in the last 5 years), 1985–2025 · leading case: The People v. Dennis J. Sincerbeaux, 57 N.E.3d 1076 (NY 2016).

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The People v. Dennis J. Sincerbeaux, 57 N.E.3d 1076 (NY 2016). · cites it 3× “452 (see People 2 Penal Law § 210.45 provides that "[a] person is guilty of making a punishable false written statement when he knowingly makes a false statement, which he does not believe to be true, in a written instrument bearing a legally authorized form notice to the effect…”

Jackler v. Byrne, 658 F.3d 225 (2d Cir. 2011). · cites it 2× “above, the MPD Complaint Form signed by Jones warned that any false statement made on such a form would expose him to criminal liability under N.Y. Penal Law § 210.45 , which provides that "[a] person is guilty of making a punishable false written statement when he knowingly…”

People v. McCulloch, 226 A.D.2d 848 (N.Y. App. Div. 1996). · cites it 2× “Here, the application was supported by affidavits by William Vanness, a police investigator, and a signed statement containing a Penal Law § 210.45 notice from Christopher Mackrodt.”

People v. Phillipe, 142 Misc. 2d 574 (N.Y. City Crim. Ct. 1989). · cites it 2× “00), the child could not be prosecuted for a violation of Penal Law §210.45 (making a false written statement).”

People v. Pierre, 140 Misc. 2d 623 (N.Y. City Crim. Ct. 1988). · cites it 3× “” Clearly, the supporting deposition that the complaining witness signed here falls within the purview of Penal Law § 210.45. *627 The inherent problem with the verification method utilized by the People for the complainant in this case, however, is that neither she nor any…”

People v. Cohen, 687 N.E.2d 1313 (NY 1997). “Mackrodt gave his statement with notice that any falsity would subject him to criminal sanctions under Penal Law § 210.45. Mackrodt related that, when visiting the home of codefendant David McCulloch and in the presence of defendant and codefendant Francis Anderson, he was…”

Ong v. Park Manor (Middletown Park) Rehab. & Healthcare Ctr., 51 F. Supp. 3d 319 (S.D.N.Y. 2014). “at unnumbered 82-84, 224-25 (index pages for the second and fourth sections of exhibits) (citing N.Y. Penal Law § 210.45 ).) However, that provision cannot form the basis of a civil claim, nor can it form the basis of a § 1983 or related claim given that those statutes apply…”

Vale v. Eidens, 290 A.D.2d 612 (N.Y. App. Div. 2002). “00 [4]), particularly information derived from the applicant’s character references, who are advised that all information provided by them “will be strictly confidential” and who sign the character reference form knowing that the making of any false statement would subject them…”

People v. Morbelli, 144 Misc. 2d 482 (N.Y. City Crim. Ct. 1989). · cites it 2× “Defendant bases his claim on (1) the absence of an attestation; (2) the supporting deposition’s use of the male gender to describe the female complainant; and (3) the assertion that the document may not have been subscribed in New York State thus invalidating the effect of the…”

Antaki v. Mateo, 100 A.D.3d 579 (N.Y. App. Div. 2012). “Here, in support of that branch of their cross motion which was for summary judgment, the appellants submitted evidence which included statements by eyewitnesses, verified pursuant to Penal Law § 210.45, which were the equivalent of statements made under oath (see People v…”

In re Charlene D., 214 A.D.2d 561 (N.Y. App. Div. 1995). · cites it 2× “Indeed, the deposition signed by the complainant herein expressly recites that "The making of False Statements in this Instrument is Punishable as a Class A Misdemeanor Pursuant to Section 210.45 of The Penal Law”.”

People v. Cance, 155 A.D.2d 764 (N.Y. App. Div. 1989). “The affidavit setting forth personal observations was made against the witnesses’ penal interest and contained a warning against a false statement (see, Penal Law §210.45); it supported issuance of the search warrant without extrinsic evidence of the informant’s reliability…”

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