Accomplice Testimony

Name: People v. Jones
Case #: B279694
Opinion Date: 08/21/2018
  • Categories: Accomplice Testimony, Appeals, Areas Constitutional Law, Evidence, Insufficiency/Sufficiency of, Right to Jury Trial, Trial Proceedings, Waiver, Waiver of Right

Summary

Murder conviction reversed where defendant's waiver of jury trial after bare two-question inquiry was not knowing and voluntary. Jones was convicted of second degree murder and child abuse following the death of her four-month-old daughter. On appeal she argued her…

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Name: People v. Rodriguez and Barajas
Case #: S239713
Opinion Date: 05/17/2018
  • Categories: Accomplice Testimony, Cruel and Unusual Punishment, Evidence, Minor Found Unfit, Sentencing

Summary

Appellant Barajas's convictions for murder and related charges must be reversed because the only evidence connecting him to the crimes was uncorroborated accomplice testimony. Rodriguez and Barajas were convicted of first degree murder and other offenses based on evidence that…

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Name: People v. Almeda
Case #: C077141
Opinion Date: 01/12/2017
  • Categories: Accomplice Testimony, Accomplices, Admitting/Excluding, Areas Constitutional Law, Confessions, Confront/Cross-exam, Crimes, Evidence, Government Agent Elicits, Hearsay, Interrogations & Confessions, Redaction (Bruton error)

Summary

Admission of cellmate's testimony relating defendant's incriminating statements did not violate his Sixth Amendment right to counsel because the cellmate was not acting under the government's direction. Villa and Almeda were charged with first degree murder for shooting a man…

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Name: People v. Smith
Case #: D069445
Opinion Date: 06/09/2017
  • Categories: Accomplice Testimony, Areas Constitutional Law, Confront/Cross-exam, Evidence, General Principles, Hearsay, Jury Instructions

Summary

Murder conviction reversed where trial court erroneously instructed the jury that any testimony from an accomplice requires corroboration before the jury may accept it as true. Smith and Mitchell were convicted of murdering a woman during a burglary. On their…

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Name: People v. Mohamed
Case #: B262627
Opinion Date: 05/03/2016
  • Categories: Accomplice Testimony, Enhancements, Evidence, General Principles, Jury Instructions, Sentencing

Summary

Doctor charged with involuntary manslaughter for patient's death not entitled to instruction that his medical assistant was an accomplice. Mohamed gave a patient too many opioids to keep her sedated during a liposuction procedure and she died. His assistant, who…

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Name: People v. Gonzalez
Case #: B255375
Opinion Date: 03/30/2016
  • Categories: Accomplice Testimony, Admitting/Excluding, Areas Constitutional Law, Confront/Cross-exam, Crimes, Evidence, Hearsay, Lesser-Included Offenses

Summary

Witness' statements to officer shortly after he witnessed a fatal shooting were admissible under the spontaneous statements exception to the hearsay rule. When officer Vasquez arrived at the scene of a robbery-murder about 12 minutes after it occurred, he encountered…

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Name: Arteaga v. Superior Court (Santa Clara County)
Case #: H040702
Opinion Date: 01/27/2015
  • Categories: Accomplice Testimony, Evidence, Grand Jury, Pleadings

Summary

Uncorroborated accomplice testimony can be sufficient to support the finding of probable cause necessary for a grand jury indictment. A grand jury indicted Arteaga on street gang and drug offenses. Arteaga moved to dismiss the indictment because the only evidence…

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Name: People v. Arceo
Case #: B218758
Opinion Date: 04/13/2011
  • Categories: Accomplice Testimony, Areas Constitutional Law, Confront/Cross-exam, Evidence, Hearsay

Summary

The Confrontation Clause is inapplicable to out-of-court non-testimonial statements of codefendants. A codefendant's hearsay statement is admissible if it falls within an accepted exception or is supported by a guarantee of trustworthiness. Admission of statements with sufficient indicia to fall…

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