In the 1992 case of United States v. Sharon Dunnigan, the U.S. Supreme Court upheld a perjury conviction against Sharon Dunnigan, who had testified falsely during her own trial for drug trafficking charges. The central issue in this case was whether or not it is necessary to prove that perjured testimony materially affected the outcome of a proceeding before convicting someone of perjury under federal law (18 U.S.C §1623). In its decision, the court held that there is no need to demonstrate materiality when prosecuting someone for giving false statements under oath; instead, it's enough to show that they knowingly made false declarations about issues relevant to their trial proceedings. This ruling clarified and established an important legal standard regarding perjury convictions in federal courts.

In the dissenting opinion for United States v. Sharon Dunnigan, 1992, it was argued that the majority's decision to uphold a perjury conviction based on general testimony could potentially undermine defendants' constitutional rights. The dissent expressed concern over how broadly "materiality" had been defined in this case and suggested that such an interpretation might lead to potential abuses of power by prosecutors who could use perjury charges as a tool against uncooperative witnesses or defendants. They also pointed out that there is no clear standard for determining what constitutes material falsehoods and feared this lack of clarity may result in arbitrary enforcement of law. Furthermore, they disagreed with the majority’s view about jury instructions regarding materiality; arguing instead that juries should be given more precise guidance on how to evaluate whether false statements are materially significant enough to warrant a perjury charge.