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Alaska Statutes

Alaska Stat. § 12.45.020 (2026)

Conviction on testimony of accomplice and corroboration

✓ current as of July 2026
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Sec. 12.45.020. Conviction on testimony of accomplice and corroboration.
A conviction shall not be had on the testimony of an accomplice unless it is corroborated by other evidence that tends to connect the defendant with the commission of the crime; and the corroboration is not sufficient if it merely shows the commission of the crime or the circumstances of the commission.


Notes of Decisions
Cited in 39 cases (2 in the last 5 years), 1964–2024 · leading case: Kennedy v. Louisiana, 554 U.S. 407 (2008).
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Kennedy v. Louisiana, 554 U.S. 407 (2008). · cites it 2× “Code 12-21-222 (1986); Alaska Stat. § 12.45.020 (1984); Ark.Code Ann.”
Anthony v. State, 521 P.2d 486 (Alaska 1974). · cites it 6× “The remaining portion of instruction 10, after quoting AS 12.45.020, [25] stated: The provision of Alaska law which is quoted means that the corroborating evidence required to be given before conviction can be had, must, in itself, and independent of all accomplice testimony,…”
Evans v. State, 550 P.2d 830 (Alaska 1976). · cites it 3× “At the close of evidence Evans moved for a judgment of acquittal on three grounds: entrapment as a matter of law; that Grant was an accomplice whose testimony lacked the corroboration required by AS 12.45.020; and the insufficiency of the prosecution’s evidence.”
Jackson v. State, 695 P.2d 227 (Alaska Ct. App. 1985). · cites it 6× “[4] *233 We must separately consider Jackson's claim that Eacker's testimony was not sufficiently corroborated to satisfy AS 12.45.020. [5] If the corroborating evidence against Jackson was insufficient, retrial of this case would not be permissible.”
Brown v. State, 693 P.2d 324 (Alaska Ct. App. 1984). · cites it 4× “In arguing that the evidence at trial was insufficient, Morris and Brown rely on AS 12.45.020, which provides: A conviction shall not be had on the testimony of an accomplice unless it is corroborated by other evidence which tends to connect the defendant with the commission of…”
M.H. v. State, 382 P.3d 1201 (Alaska Ct. App. 2016). · cites it 4× “⅛ argument that the State failed to ‘present adequate evidence to corrobórate the testimony of his accomplice AS 12.45.020 states that a conviction can not rest on the testimony of an accomplice unless the accomplice’s testimony “is corroborated by other evidence that tends to…”
Merrill v. State, 423 P.2d 686 (Alaska 1967). · cites it 3× “Appellants assert that AS 12.45.020 is applicable to evidence produced before a grand jury.”
Pulakis v. State, 476 P.2d 474 (Alaska 1970). · cites it 2× “8 Oxenberg elucidates the AS 12.45.020 language, “tends to connect.”
Thomas v. State, 391 P.2d 18 (Alaska 1964). · cites it 2× “8 The third issue raised by the defendant is that his motion for judgment of acquittal should have been granted because as a matter of law the testimony of an alleged accomplice, Harold Harvey, was not corroborated as required by AS 12.45.020. This statute declares that a…”
State v. Jones, 466 Md. 142 (Md. 2019). “2016) (citing Alaska Stat. § 12.45.020 ); MacKool v. State, 231 S.”
Brown v. State, 378 A.2d 1104 (Md. 1977). “15, § 307; Alaska Stat. § 12.45.020 ; Ark. Stat. Ann.”
Dimmick v. State, 473 P.2d 616 (Alaska 1970). · cites it 2× “NOTES [1] AS 12.45.020 provides: Conviction on testimony of accomplice and corroboration.”
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