Is an out-of-court statement by an accomplice not subject to a corroboration requirement?
California, United States of America
The following excerpt is from People v. Aloe, G056882 (Cal. App. 2020):
accomplice's statements with caution and to require corroboration]; People v. Sully (1991) 53 Cal.3d 1195, 1230 [accomplice's excited utterance was not subject to corroboration requirement].) This is because "[t]he usual problem with accomplice testimonythat it is consciously self-interested and calculatedis not present in an out-of-court statement that is itself sufficiently reliable to be allowed in evidence." (Ibid.)
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