## Facts

- The defendant made two statements to police alleging a street assault and theft of her purse or money.
- The statements were knowingly false.
- The false reports caused police to spend time investigating a non-existent crime.
- The reports risked subjecting unknown members of the public to suspicion and potential arrest based on the fabricated description.
- The defendant was indicted for the common-law misdemeanor of causing a “public mischief” through false allegations to police.
- At trial, she argued the indictment disclosed no offense known to law; the jury convicted after being instructed the conduct constituted the offense.

## Issues

1. Whether knowingly making false allegations to police that waste police time and expose others to suspicion and possible arrest constitutes the common-law misdemeanor of causing a public mischief.
2. Whether an indictment charging “public mischief” alleges an offense known to law.

## Decision

- The Court of Criminal Appeal affirmed the conviction.
- The court held that causing a public mischief is a recognized common-law misdemeanor.
- The court concluded the defendant’s false allegations fell within that offense because they diverted police resources and endangered innocent persons by placing them at risk of suspicion and arrest.
- The court rejected the argument that upholding the conviction would amount to creating a new crime, treating the offense as part of existing common law.

## Legal Principles

- A common-law misdemeanor exists for conduct tending to prejudice the community (“public mischief”).
- Knowingly making false reports to police may constitute public mischief when it induces police to waste time and exposes others to suspicion or potential arrest.
- An indictment is legally sufficient where it charges an established common-law misdemeanor and alleges public consequences beyond a private lie.

## Conclusion

The appellate court sustained a conviction for public mischief where the defendant knowingly fabricated crimes to police, causing misdirection of law-enforcement resources and placing innocent persons at risk of suspicion and arrest, and it treated the offense as an established part of the common law rather than a new judicial creation.


Rex v. Manley, 1 K.B. 529 (Ct. Crim. App. 1933)