Code of Alabama
Ala. Code § 15-25-34 (2026)
Corroborative Evidence Prerequisite to Admission of Statement.
✓ official Alabama Legislature (ALISON) text, current July 2026
Before a statement may be admitted pursuant to this article on the grounds that the declarant is unavailable as a witness, the statement may be admitted only if there is corroborative evidence of the act.
(Acts 1989, No. 89-876, p. 1754, §4.5; Act 2022-201, §2.)
Notes of Decisions
Cited in 15
cases, 1994–2014 · leading case: C.L.Y. v. State, 928 So. 2d 1069 (Ala. 2005).
C.L.Y. v. State, 928 So. 2d 1069 (Ala. 2005). “We granted certiorari review to consider two issues: 1) whether an appellate court is limited to evidence presented before trial in determining whether out-of-court statements made by a child victim of sexual abuse are admissible under Ala.Code 1975, § 15-25-34, and 2) whether…”
Commonwealth v. Walter, 93 A.3d 442 (Pa. 2014). “, Ala. Code § 15-25-34 ; Miss.R.E. 803(25); 12 Oxla.”
Steele v. State, 911 So. 2d 21 (Ala. Crim. App. 2004). “Code 1975; the State failed to produce corroborative evidence of the statement, § 15-25-34, Ala.Code 1975; the trial court failed to make a finding that the child victim was unavailable to testify or to “support with findings and record any rulings pertaining to the child’s…”
C.L.Y. v. State, 928 So. 2d 1047 (Ala. Crim. App. 2003). “In this regard, § 15-25-34, Ala.Code 1975, provides: “Before a statement may be admitted pursuant to this article on the grounds that the child declarant is unavailable as a witness, such statement may be admitted only if there is corroborative evidence of the act.”
J.B.B. v. Alabama Dep't of Human Resources, 120 So. 3d 517 (Ala. Civ. App. 2013). “The father argues that the recorded interviews of the children at Prescott House were erroneously admitted because they failed to satisfy the corroboration requirement of § 15-25-34, Ala.Code 1975. That section, a part of “The Child Physical and Sexual Abuse Victim Protection…”
K.D.H. v. State, 849 So. 2d 983 (Ala. Crim. App. 2002). “The appellant also contends that the juvenile court erred in admitting evidence of the victim’s out-of-court statements because, he says, there was no “corroborative evidence” of the crimes as required by § 15-25-34.”
State v. A.R.C., 873 So. 2d 261 (Ala. Crim. App. 2003). “The trial court excluded the statements after finding that they were not sufficiently corroborated pursuant to § 15-25-34, Ala.Code 1975. The State then filed this mandamus petition.”
Ex Parte CLY, 928 So. 2d 1069 (Ala. 2005). “We granted certiorari review to consider two issues: 1) whether an appellate court is limited to evidence presented before trial in determining whether out-of-court statements made by a child victim of sexual abuse are admissible under Ala.Code 1975, § 15-25-34, and 2) whether…”
C.M. v. State, 889 So. 2d 57 (Ala. Crim. App. 2004). “’s statement, he did so on the grounds that he had not received the complete statement, and that the statement was not sufficiently corroborated as required by § 15-25-34, Ala.Code 1975. The appellant never argued to the juvenile court that A.”
K.D.H. v. State, 849 So. 2d 991 (Ala. 2002). “…So.2d 983 (Ala.Crim.App.2002), which rationalizes outright violations by the trial court of § 15-25-32, § 15-25-33, § 15-25-34, § 15-25-37, and § 15-25-38, Ala.Code 1975, conflicts with Wal-Mart Stores, Inc. v. Patterson, 816 So.2d 1, 6 (Ala.2001), and Omni Insurance Co. v.…”
Latimer v. State, 659 So. 2d 129 (Ala. Crim. App. 1994). “Although § 15-25-33 and § 15-25-34 do not explicitly state that they apply only to subsection (2), this is clearly the case, as § 15-25-33 deals with expert testimony supporting the unavailability of the child to testify, and § 15-25-34 deals with corroborative evidence as a…”
KDH v. State, 849 So. 2d 983 (Ala. Crim. App. 2002). “The appellant also contends that the juvenile court erred in admitting evidence of the victim's out-of-court statements because, he says, there was no "corroborative evidence" of the crimes as required by § 15-25-34.”
Ala. Code § 15-25-34(2): 2 cases
State v. A.R.C., 873 So. 2d 261 (Ala. Crim. App. 2003). “The trial court excluded the statements after finding that they were not sufficiently corroborated pursuant to § 15-25-34, Ala.Code 1975. The State then filed this mandamus petition.”
Ex Parte State, 873 So. 2d 261 (Ala. Crim. App. 2003).
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