People v. Chico, 687 N.E.2d 1288 (NY 1997). · Go Syfert
People v. Chico, 687 N.E.2d 1288 (NY 1997). Cases Citing This Book View Copy Cite
129 citation events (108 in the last 25 years) across 12 distinct courts.
Strongest positive: Avincola v. Stinson (nysd, 1999-07-09)
Treatment trajectory · 1997 → 2026 · click a year to view as-of
1997 2011 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
examined Cited as authority (quoted) Avincola v. Stinson (3×)
S.D.N.Y. · 1999 · quote attribution · 3 verbatim quotes · confidence low
dmissions by a party of any fact material to the issue are always competent evidence against him, wherever, whenever, or to whomsoever made.
discussed Cited as authority (rule) People v. Francis (2×)
N.Y. App. Term. · 2026 · confidence medium
Moreover, the evidence was sufficient to show that defendant was the individual who walked upon the homeowner's driveway, based on defendant's written statement and the detective's testimony indicating that defendant had orally admitted to walking upon the homeowner's driveway, in conjunction with other evidence supporting defendant's guilt ( see CPL 60.50; People v Santiago , 22 NY3d 740, 748 [2014]; People v Chico , 90 NY2d 585, 589 [1997]).
discussed Cited as authority (rule) People v. Singh (2×)
Bronx Criminal Ct. · 2025 · confidence medium
See People v. Caban , 5 NY3d 143, 151 n.* (2005); People v. Chico , 90 NY2d 585, 589 (1997); see also People v. Suber , 19 NY3d 247, 250 (2012) (clarifying that the admission-[*3]corroboration requirement of C.P.L. § 60.50 "has no bearing on the adequacy of charging instruments that provide the bases for prosecutions").
examined Cited as authority (rule) People v. Kesoglides (3×)
N.Y. Crim. Ct. · 2025 · confidence medium
Defendant does not contest, moreover, that these statements constitute non-hearsay admissions. ( See People v Chico , 90 NY2d 585, 589 [1997]) (reiterating a party's admissions to any material facts are "always competent evidence against him wherever, whenever, or to whomever made") (citations omitted).
discussed Cited as authority (rule) MIC Gen. Ins. Corp. v. Cunningham
N.Y. Sup. Ct., New York Cty. · 2024 · confidence medium
Co. v Jaipersaud, 127 AD 3d 401, 401 [1st Dept 2015] [insurer demonstrated through the insured’s admission in a statement to insured’s investigator that the home was a three-family dwelling and not covered by the policy]). “[A]dmissions by a party of any fact material to the issue are always competent evidence against him, wherever, whenever, or to whomsoever made (People v Chico, 90 NY2d 585, 589 [1997] [citations omitted]).
discussed Cited as authority (rule) People v. Miller
N.Y. App. Div. · 2024 · confidence medium
Defendant's statements in which he expressed his intent to kill the victim if she ended their relationship were admissible as admissions by a party-opponent ( see People v Chico , 90 NY2d 585, 589 [1997]).
cited Cited as authority (rule) People v. Covlin
N.Y. App. Div. · 2022 · confidence medium
Defendant's statements to various people were admissible as party admissions ( see People v Chico , 90 NY2d 585, 589 [1997]).
cited Cited as authority (rule) People v. Covlin
N.Y. App. Div. · 2022 · confidence medium
Defendant's statements to various people were admissible as party admissions ( see People v Chico , 90 NY2d 585, 589 [1997]).
discussed Cited as authority (rule) People v. Stackhouse
N.Y. App. Div. · 2021 · confidence medium
Under CPL 60.50, "[a] person may not be convicted of any offense solely upon evidence of a confession or admission made by him [or her] without additional proof that the offense charged has been committed." All the statute requires is " 'some proof, of whatever weight, that a crime was committed by someone' " ( People v Chico , 90 NY2d 585, 589 [1997], quoting People v Daniels , 37 NY2d 624, 629 [1975]).
discussed Cited as authority (rule) People v. Beard
N.Y. App. Div. · 2020 · confidence medium
CPL 60.50 "does not mandate submission of independent evidence of every component of the crime charged . . . , but instead calls for 'some proof, of whatever weight, that a crime was committed by someone' " ( People v Chico , 90 NY2d 585, 589 [1997]).
cited Cited as authority (rule) People v. Melo
N.Y. App. Div. · 2020 · confidence medium
This evidence contained defendant's admissions to elements of the charged crimes ( see People v Chico , 90 NY2d 585, 589 [1997]).
cited Cited as authority (rule) People v. Hernandez
N.Y. App. Div. · 2020 · confidence medium
That statute is satisfied by the production of "some proof, of whatever weight, that a crime was committed by someone" ( People v Chico , 90 NY2d 585, 589 [1997]).
cited Cited as authority (rule) Higgins v. Colvin
E.D.N.Y · 2020 · confidence medium
People v. Chico, 90 N.Y.2d 585, 589 (1997) (internal quotations and citations omitted).
discussed Cited as authority (rule) People v. Bedard (Nadia)
N.Y. App. Term. · 2019 · confidence medium
The corroboration need not even amount to "additional proof . . . connect[ing] the defendant with the crime" ( People v Lipsky , 57 NY2d 560, 571 [1982]), and, as such, the evidence threshold to satisfy the statute has been characterized as "low" ( People v Chico , 90 NY2d 585, 591 [1991]).
discussed Cited as authority (rule) People v. Brinkley
N.Y. App. Div. · 2019 · confidence medium
Contrary to defendant's argument that the exhibits contain inadmissible hearsay, "[p]lainly, defendant's own statements could be received in evidence as party admissions" ( People v Caban , 5 NY3d 143 , 151 n [2005]; see People v Grant , 17 NY3d 613, 622 [2011]; People v Chico , 90 NY2d 585, 589 [1997]).
discussed Cited as authority (rule) People v. Portis (Antone)
N.Y. App. Term. · 2018 · confidence medium
Defendant's statement during the call "Yeah I choked her," was admissible as an admission (<i>see People v Chico</i>, 90 NY2d 585, 589 [1997]; <a href="../2014/2014_04520.htm" target="_blank"><i>People v Moore</i>, 118 AD3d 916 </a>, 918 [2014], <i>lv denied </i> 24 NY3d 1086 [2014]), notwithstanding his subsequent statement "I didn't choke her, but I like grabbed her to slow her down." The subsequent statement raised an issue as to the weight of the evidence, not as to its admissibility (<a href="../2018/2018_03910.htm" target="_blank"><i>see People v McKenzie</i>, 161 AD3d 703 </a>, 704 [201…
discussed Cited as authority (rule) People v. Anaka
N.Y. App. Div. · 2017 · confidence medium
In addition, the complainant was properly permitted to testify as to what the defendant told her in a telephone conversation because those statements constituted statements against penal interest (see People v Chico, 90 NY2d 585, 589 [1997]; People v Moore, 118 AD3d 916 [2014]; People v Case, 113 AD3d 872 [2014]).
discussed Cited as authority (rule) People v. Jack
N.Y. App. Div. · 2017 · confidence medium
But it don’t show my face.” This part of the call was properly admitted as an admission (see People v Chico, 90 NY2d 585, 589 [1997]; see also People v Grant, 17 NY3d 613, 622 [2011]; People v O’Connor, 21 AD3d 1364, 1366 [2005]).
discussed Cited as authority (rule) The People v. Kevin Fisher
NY · 2017 · confidence medium
In People v Chico ( 90 NY2d 585, 588 [1997]), a case involving first-degree hindering prosecution, the Court held that “the People must prove that the underlying class A felony was committed,” but made clear that “the statute does not require proof that the assisted person was ever arrested or convicted.” Other than the class of the underlying felony and the fact that first-degree hindering prosecution has the added element that the defendant knew or believed that the assisted person engaged in the conduct constituting a class A felony, first- and second-degree hindering prosecution sh…
discussed Cited as authority (rule) People v. Sanchez (Ray)
N.Y. App. Term. · 2017 · confidence medium
While defendant's admissions to the complainant required corroboration ( see CPL 60.50; People v Chan , 36 Misc 3d 44 , 47 [App Term, 2d Dept, 2d, 11th, & 13th Jud Dists 2012] [the CPL 60.50 "corroboration requirement, applicable by statute to indictments (CPL 190.65 [1]), has been [*3] extended to require allegations of corroborative evidence in misdemeanor accusatory instruments"]), the evidentiary threshold for corroboration is "low" ( People v Chico , 90 NY2d 585, 591 [1997]), requiring only "some proof, of whatever weight, that a crime was committed by someone" ( People v Daniels , 37 NY2…
discussed Cited as authority (rule) People v. Parbhudial
N.Y. App. Div. · 2016 · confidence medium
Proof of the Ramgoolam' murder by defendant’s family members was a necessary element of the hindering prosecution in the first degree charge (see Penal Law § 205.65; People v Chico, 90 NY2d 585, 588 [1997]), as well as the alleged perjury and sworn false statement charges.
cited Cited as authority (rule) Brown v. URS Midwest, Inc.
N.Y. App. Div. · 2015 · confidence medium
This statement was admissible against the defendant as an admission, since it tended to inculpate the defendant in connection with a material fact (see People v Chico, 90 NY2d 585, 589 [1997]).
cited Cited as authority (rule) People v. Pacquette
NY · 2015 · confidence medium
Finally, defendant’s flight from police officers evinced a consciousness of guilt (see People v Chico, 90 NY2d 585, 591 [1997]).
discussed Cited as authority (rule) People v. Azuman
N.Y. App. Term. · 2015 · confidence medium
We find that the accusatory instruments were facially sufficient to charge the offenses (see People v Fernandez, 20 NY3d 44, 51-52 [2012]); that defendant’s statement to the officer was properly admitted into evidence (People v Caban, 5 NY3d 143 , 151 and n [2005]; People v Chico, 90 NY2d 585, 589 [1997]; People v Nealy, 32 AD3d 400 , 402 [2006]); that, while hearsay, the passenger’s statement was properly admitted in the absence of an objection (People v Roman, 111 AD3d 417 , 417 [2013]; People v Morris, 14 Misc 3d 144[A] , 2007 NY Slip Op 50387[U] [App Term, 2d Dept, 2d & 11th Jud Dists …
discussed Cited as authority (rule) In re Naomi P.
N.Y.C. Fam. Ct. · 2015 · confidence medium
An admission of material facts by a party always constitutes competent evidence against him (People v Chico, 90 NY2d 585, 589 [1997]; People v Caban, 5 NY3d 143, 151 [2005]; People v Case, 113 AD3d 872, 873 [2014], Iv denied 23 NY3d 961 [2014]; People v Moore, 118 AD3d 916, 918 [2014], Iv denied 24 NY3d 1086 [2014]). 4 Respondent’s statements are sufficient to establish that he sexually abused Naomi when she was between age 9 and age IOV2 or 11, and his statements further serve as corroboration for the child’s out-of-court statements relating to that sexual abuse (Matter of Dave D. [Jean D…
discussed Cited as authority (rule) People v. Hampton
N.Y. App. Div. · 2014 · confidence medium
In any event, the record contains ample corroborative evidence that the crimes of which he was convicted were committed, and thus the statutory corroboration requirement was met (see People v Chico, 90 NY2d 585, 589-590 [1997]; Green, 43 AD3d at 1281; People v Rutledge, 286 AD2d 962, 962 [2001], lv denied 97 NY2d 687 [2001]).
discussed Cited as authority (rule) People v. Hampton
N.Y. App. Div. · 2014 · confidence medium
In any event, the record contains ample corroborative evidence that the crimes of which he was convicted were committed, and thus the statutory corroboration requirement was met (see People v Chico, 90 NY2d 585, 589-590 [1997]; Green, 43 AD3d at 1281; People v Rutledge, 286 AD2d 962, 962 [2001], lv denied 97 NY2d 687 [2001]).
discussed Cited as authority (rule) People v. Fisher
N.Y. App. Div. · 2014 · confidence medium
Indeed, as the Court of Appeals has noted, the hindering prosecution statute does not require proof that the assisted *429 person was ever arrested or convicted of the underlying felony (see People v Chico, 90 NY2d 585, 588 [1997]).
discussed Cited as authority (rule) People v. Moore
N.Y. App. Div. · 2014 · confidence medium
The first excerpt was admissible because it contained what could be interpreted as an admission by the defendant that he had killed the victim (see People v Chico, 90 NY2d 585, 589 [1997]; People v Case, 113 AD3d 872 [2014]; People v Peele, 73 AD3d 1219, 1221 [2010]).
discussed Cited as authority (rule) People v. Moore
N.Y. App. Div. · 2014 · confidence medium
The first excerpt was admissible because it contained what could be interpreted as an admission by the defendant that he had killed the victim (see People v Chico, 90 NY2d 585, 589 [1997]; People v Case, 113 AD3d 872 [2014]; People v Peele, 73 AD3d 1219, 1221 [2010]).
discussed Cited as authority (rule) People v. Case
N.Y. App. Div. · 2014 · confidence medium
Portions of five recordings were properly admitted into evidence since they contained admissions that the defendant had shot the complainant (see People v Caban, 5 NY3d 143, 151 [2005]; People v Chico, 90 NY2d 585, 589 [1997]; Reed v McCord, 160 NY 330, 341 [1899]).
discussed Cited as authority (rule) People v. Case
N.Y. App. Div. · 2014 · confidence medium
Portions of five recordings were properly admitted into evidence since they contained admissions that the defendant had shot the complainant (see People v Caban, 5 NY3d 143, 151 [2005]; People v Chico, 90 NY2d 585, 589 [1997]; Reed v McCord, 160 NY 330, 341 [1899]).
discussed Cited as authority (rule) People v. McGee
NY · 2013 · confidence medium
That statute precludes a person from being convicted of a crime based solely on a confession unless it is corroborated “with[ ] additional proof that the offense charged has been committed.” The purpose of this requirement is to “avert the danger that a crime may have been confessed when no crime in any degree has been committed by anyone” (People v Chico, 90 NY2d 585, 590 [1997] [internal quotation marks and citation omitted]).
cited Cited as authority (rule) People v. Gonzales
N.Y. App. Div. · 2012 · confidence medium
CPL 60.50 requires only some proof that a crime was committed by someone (see People v Chico, 90 NY2d 585, 589 [1997]).
cited Cited as authority (rule) People v. Gonzales
N.Y. App. Div. · 2012 · confidence medium
CPL 60.50 requires only some proof that a crime was committed by someone (see People v Chico, 90 NY2d 585, 589 [1997]).
discussed Cited as authority (rule) People v. Chan
N.Y. App. Term. · 2012 · confidence medium
Even at a trial, the evidentiary threshold for corroboration is “low” (People v Chico, 90 NY2d 585, 591 [1997]), requiring only “some proof, of whatever weight, that a crime was committed by someone” (People v Daniels, 37 NY2d 624, 629 [1975]).
discussed Cited as authority (rule) People v. Morales
N.Y. City Crim. Ct. · 2012 · confidence medium
All that is required is “some proof, of whatever weight, that a crime was committed by someone.” (See People v Chico, 90 NY2d 585, 589 [1997].) Defendant asserts that since “the accusatory instrument is based entirely on [defendant’s] admissions,” the complaint is facially insufficient.
discussed Cited as authority (rule) People v. Molson
N.Y. App. Div. · 2011 · confidence medium
Thus, despite the general rule that an out-of-court statement by a criminal defendant is admissible against that defendant (see People v Chico, 90 NY2d 585, 589 [1997]; People v O’Connor, 21 AD3d 1364, 1366 [2005], lv denied 6 NY3d 757 [2005]), defendant simply recounted the statement of another, and thus the statement in question was inadmissible (see People v Smith, 172 NY 210, 236 [1902]).
discussed Cited as authority (rule) People v. Grant
NY · 2011 · confidence medium
Moreover, the Peralta rule is contrary to the well-established principle that “[a]dmissions by a party of any fact material to the issue are always competent evidence against him, wherever, whenever, or to whomsoever made” (People v Chico, 90 NY2d 585, 589 [1997] [internal quotation marks and citations omitted]; see also People v Casey, 95 NY2d 354, 362 [2000]).
discussed Cited as authority (rule) In re Macye Mc.
N.Y. App. Div. · 2011 · confidence medium
Here, the presentment agency failed to present sufficient evidence to establish that the appellant assisted a person who committed a class B or class C felony (cf. People v Chico, 90 NY2d 585, 588-591 [1997]; People v Clough, 43 AD2d 451, 453-454 [1974]).
discussed Cited as authority (rule) People v. Smielecki
N.Y. App. Div. · 2010 · confidence medium
The medical evidence of the child’s injuries provided sufficient assurance that defendant had not admitted to crimes where no crime had been committed (see People v Chico, 90 NY2d 585, 589-590 [1997]).
discussed Cited as authority (rule) People v. Brand
N.Y. App. Div. · 2010 · confidence medium
The further contention of defendant that his statements to the police were not sufficiently corroborated at trial is without merit (see People v Booden, 69 NY2d 185, 187-188 [1987]; see generally CPL 60.50; People v Chico, 90 NY2d 585, 589-590 [1997]; People v Daniels, 37 NY2d 624, 629 [1975]).
discussed Cited as authority (rule) People v. Solomon
N.Y. App. Div. · 2010 · confidence medium
Contrary to the contention of defendant, he did not remain silent in response to the victim’s accusations, but he instead made inculpatory statements that were properly admitted in evidence “as legally admissible hearsay against [defendant]” (People v Chico, 90 NY2d 585, 589 [1997]). “[A]dmissions by a party of any fact material to the issue are always competent evidence against him [or her], wherever, whenever, or to whomsoever made” (id. [internal quotation marks omitted]; see People v Webb, 60 AD3d 1291, 1292 [2009], lv denied 12 NY3d 930 [2009]; People v O’Connor, 21 AD3d 1364,…
discussed Cited as authority (rule) People v. Walker
N.Y. City Crim. Ct. · 2008 · confidence medium
A cardinal rule of evidence in our law is that “[a] person may not be convicted of any offense solely upon evidence of a confession or admission made by him without additional proof that the offense charged has been committed.” (CPL 60.50.) As the Court of Appeals explained in People v Chico ( 90 NY2d 585, 589-590 [1997]): “This statutory corroboration requirement does not mandate submission of independent evidence of every component of the crime charged (see, People v Booden, 69 NY2d 185, 187 ; People v Murray, 40 NY2d 327, 334 , cert denied 430 US 948 ), but instead calls for ‘some p…
discussed Cited as authority (rule) People v. Alexander
N.Y. App. Div. · 2008 · confidence medium
“Without the underlying felony . . . , the defendant could still have committed a lesser homicide offense,” and thus the rationale for requiring corroboration, which is to avoid the danger that a defendant confessed to a crime when no crime has actually been committed, no longer exists (People v Chico, 90 NY2d 585, 590 [1997]; see generally People v Davis, 46 NY2d 780, 781 [1978]).
discussed Cited as authority (rule) People v. Hogle
N.Y. City Crim. Ct. · 2007 · confidence medium
This statutory requirement of corroboration, however, “does not mandate submission of independent evidence of every component of the crime charged, but instead calls for some proof, of whatever weight, that a crime was committed by someone” (People v Chico, 90 NY2d 585, 589 [1997] [citations omitted]).
discussed Cited as authority (rule) People v. Green
N.Y. App. Div. · 2007 · confidence medium
In any event, although we agree with defendant that the court erred in failing to instruct the jury with respect to the corroboration of his own statement, the record establishes that there is the requisite corroborative evidence that the crimes of which he was convicted were committed (see People v Chico, 90 NY2d 585, 589-590 [1997]), and thus reversal on that ground is not required (see People v Rutledge, 286 AD2d 962 [2001], lv denied 97 NY2d 687 [2001]).
discussed Cited as authority (rule) People v. Harewood
N.Y. App. Div. · 2006 · confidence medium
We also reject his contention that his statements to the police were not sufficiently corroborated (see generally CPL 60.50; People v Chico, 90 NY2d 585, 589-590 [1997]; People v Daniels, 37 NY2d 624, 629 [1975]).
discussed Cited as authority (rule) People v. O'Connor
N.Y. App. Div. · 2005 · confidence medium
Contrary to defendant’s contention, the testimony of the witness concerning admissions made by defendant to him was “properly introduced into evidence as legally admissible hearsay against [defendant]. [A]dmissions by a party of any fact material to the issue are always competent evidence against him, wherever, whenever, or to whomsoever made” (People v Chico, 90 NY2d 585, 589 [1997] [internal quotation marks omitted]; see People v Crisler, 303 AD2d 948, 949 [2003], lv denied 100 NY2d 593 [2003]).
discussed Cited as authority (rule) People v. Caban
NY · 2005 · confidence medium
Order affirmed. * Plainly, defendant’s own statements could be received in evidence as party admissions (see People v Chico, 90 NY2d 585, 589 [1997]; Reed v McCord, 160 NY 330, 341 [1899] [“admissions by a party of any fact material to the issue are always competent evidence against him, wherever, whenever or to whomsoever made”]; Prince, Kichardson on Evidence § 8-201, at 510 [Farrell 11th ed] [defining an admission as “an act or declaration of a party . . . which constitutes evidence against the party at trial”]).
Retrieving the full opinion text from the archive…
The People of the State of New York, Respondent,
v.
Yvette Chico, Appellant
New York Court of Appeals.
Oct 28, 1997.
687 N.E.2d 1288
POINTS OF COUNSEL, Olga L. Torres, New York City, and Richard M. Greenberg for appellant., Robert T. Johnson, District Attorney of Bronx County, Bronx (Craig A. Steinberg, Peter D. Coddington and Stuart P. Levy of counsel), for respondent.
Levine.
Cited by 105 opinions  |  Published
1 passages pin-cited by 1 case
Pinpoint authority: bottom 57%
Citer courts: S.D. New York (3)

OPINION OF THE COURT

Levine, J.

Defendant appeals, pursuant to permission granted by a Justice of the Appellate Division, from an order of that Court (233 AD2d 245) affirming defendant’s conviction, after a non-jury trial, of two counts of hindering prosecution in the first degree (see, Penal Law § 205.65). At issue is the legal sufficiency of the evidence presented by the prosecution to sustain the conviction and, more specifically, whether statements made by defendant and relied upon by the trial court were sufficiently corroborated under CPL 60.50.

At trial, the prosecution introduced the testimony of two police detectives concerning statements made by defendant that in the summer of 1989, after a dispute over crack sales, her common-law husband, Marcus Rivera, and his confederates conceived of a plan to kill Roberto Corperone. Defendant related that she observed Rivera and the others stalk Corperone until, finding him in front of a building on Jerome Avenue in the Bronx, the group opened fire and, as the victim fled, Rivera shot and killed him. This statement, transcribed by one of the officers but never signed by defendant, was admitted into evidence at trial. In addition, the detectives testified that defendant twice agreed to help them apprehend Rivera by taking them to where he was staying in Philadelphia. On both occasions, when the detectives and defendant arrived in Philadelphia, Rivera was not at the expected location. Following each failed attempt to locate Rivera, defendant admitted to the police that she had thwarted their effort to apprehend him by warning Rivera in advance, after experiencing a change of heart.

The officers further testified that defendant agreed to go with the detectives to locate Rivera a third time but, this time, the detectives went to Philadelphia without defendant’s knowledge prior to the agreed upon date and were successful in[*588] surprising Rivera, finding him seated in his parked vehicle near the apartment building where he reportedly was staying. On that occasion, Rivera threatened the officers with a gun, attempted to run them down and then fled, escaping arrest. The police later apprehended him on an FBI fugitive warrant.

Defendant raises two arguments on appeal. First, we address defendant’s contention that, as a matter of law, there is insufficient evidence to sustain the conviction. Defendant was indicted and convicted of hindering prosecution in the first degree, which is defined as "rendering] criminal assistance to a person who has committed a class A felony, knowing or believing that such person has engaged in conduct constituting a class A felony” (Penal Law § 205.65). Thus, there are three elements to the crime, each of which must be proven beyond a reasonable doubt (see, CPL 70.20): (1) rendering criminal assistance (as defined by Penal Law § 205.50); (2) the commission of a class A felony by the person assisted; and (3) the defendant’s knowledge or belief that the felon engaged in the aforesaid criminal conduct.

We agree with defendant’s contention that the People must prove that the underlying class A felony was committed. Although the statute does not require proof that the assisted person was ever arrested or convicted, it does require establishment of each element of the alleged underlying class A felony (see, People v Clough, 43 AD2d 451, 453-454). Indeed, the Penal Law directly links the degree of a defendant’s criminal culpability for hindering prosecution to the seriousness of the crime committed by the assisted person (see, Penal Law §§ 205.55 [hindering prosecution in the third degree — commission of "a felony”]; 205.60 [second degree — class B or C felony]; 205.65 [first degree — class A felony]).

Thus, to establish hindering prosecution in the first degree in this case, the People were not only required to prove that Rivera committed a homicide, but that Rivera committed a homicide that constitutes an A-level felony (see, Penal Law § 125.25). Nonetheless, we conclude that the People presented legally sufficient proof of each element of intentional murder, a class A felony (see, Penal Law § 125.25 [1]), as well as all of the other elements of hindering prosecution in the first degree.

The standard of appellate review for determining whether the evidence presented by the prosecution in a criminal trial is legally sufficient is "whether the evidence, viewed in the light most favorable to the People, could lead a rational trier of fact[*589] to conclude that the elements of the crime had been proven beyond a reasonable doubt” (People v Cabey, 85 NY2d 417, 420; see also, People v Rossey, 89 NY2d 970, 971; People v Norman, 85 NY2d 609, 620). Here, defendant’s detailed statement furnishes an eyewitness account of the intentional murder of Corperone and was properly introduced into evidence as legally admissible hearsay against her. " '[A]dmissions by a party of any fact material to the issue are always competent evidence against him, wherever, whenever, or to whomsoever made’ ” (Prince, Richardson on Evidence § 8-201, at 510 [Farrell 11th ed], quoting Reed v McCord, 160 NY 330; see also, CPL 60.45).

Defendant’s eyewitness description of the murder is, therefore, evidence against her of both the underlying felony and defendant’s subjective knowledge and belief that Rivera had committed murder. Moreover, the detectives’ testimony that defendant admitted that she had alerted Rivera of the plan to apprehend him, as well as their description of Rivera’s apparent clairvoyance in anticipating their arrival and ability to vanish on the occasions when defendant knew that the officers were about to make the arrest, support the conclusion that defendant warned Rivera (see, Penal Law § 205.50 [2] [listing the act of warning a felon of impending apprehension as one of the methods of rendering criminal assistance]). Viewing this evidence in the light most favorable to the People, the majority at the Appellate Division appropriately concluded that a rational trier of fact could determine that every element of the offense had been established beyond a reasonable doubt.

Alternatively, defendant argues that the People failed to furnish corroboration under CPL 60.50 of defendant’s statement that a class A felony had occurred. Again, we find this assertion unavailing.

CPL 60.50 provides:

"A person may not be convicted of any offense solely upon evidence of a confession or admission made by him without additional proof that the offense charged has been committed” (emphasis supplied).

This statutory corroboration requirement does not mandate submission of independent evidence of every component of the crime charged (see, People v Booden, 69 NY2d 185, 187; People v Murray, 40 NY2d 327, 334, cert denied 430 US 948), but instead calls for "some proof, of whatever weight, that a crime was committed by someone” (People v Daniels, 37 NY2d 624,[*590] 629; see also, People v Booden, supra, at 187; People v Lipsky, 57 NY2d 560, 571, rearg denied 58 NY2d 824; People v Cuozzo, 292 NY 85, 92). The purpose of the statute is to avert " 'the danger that a crime may have been confessed when no crime in any degree has been committed by anyone’ ” (People v Cuozzo, supra, at 92 [emphasis supplied]; see also, People v Booden, supra, at 187; People v Lytton, 257 NY 310, 314).

Contrary to the People’s position, confession corroboration of the existence of the underlying felony in a hindering prosecution case is necessary. Here, but for the occurrence of some underlying felony, no hindering prosecution crime whatsoever would have been committed (cf., People v Lytton, supra, at 314). Were we to adopt the People’s position, it is possible that a defendant who had merely imagined a murder, yet believed that one had occurred and took steps to protect the supposed killer, could be convicted of hindering prosecution based on her purely fanciful statements and futile actions where no such crime had ever been committed. It is. instructive that each degree of hindering prosecution involves some type of underlying felony (see, Penal Law §§ 205.65, 205.60, 205.55). Hence, without the existence of an underlying felony committed by someone, there would be no crime, of any degree, irrespective of defendant’s belief and aid of the person that defendant thought to be the perpetrator.

This conclusion is not inconsistent with our cases holding that no corroboration of the underlying felony is required in a felony murder prosecution based largely on a confession (see, e.g., People v Davis, 46 NY2d 780, 781; People v Daley, 47 NY2d 916, 917, rearg denied 48 NY2d 882; People v Murray, supra, at 333; see also, People v Lytton, supra, at 315). In a felony murder prosecution, the underlying felony is used as a substitute for establishment of the mental element of the crime of murder — the defendant’s malicious criminal intent (see, People v Lytton, supra, at 315). In general, CPL 60.50 does not require corroboration of the mental element of the crime charged (see, People v Lipsky, supra, at 571; People v Murray, supra, at 333; see also, People v Lytton, supra, at 314). As stated by Chief Judge Cardozo, the underlying felony does not "chang[e] the identity of the crime [but] merely characterizes] the degree of culpability to be imputed to the killer” (People v Lytton, supra, at 315). Without the underlying felony in a felony murder prosecution, the defendant could still have committed a lesser homicide offense. Thus, the rationale for not requiring corroboration of the underlying felony in felony murder prosecutions[*591] is not applicable in the instant case. Here, the absence of corroboration of the underlying felony does not merely affect the degree of the crime. Rather, without corroboration of the underlying felony, there would be no proof, save the defendant’s statement, that any crime had been committed at all.

While CPL 60.50 requires some independent evidence of the existence of the underlying felony beyond the defendant’s confession, that burden was satisfied here, given the low threshold required by the statute (see, People v Booden, supra, at 187; People v Lipsky, supra, at 571; People v Daniels, supra, at 629). The prosecution witnesses at trial were the investigating officers of the Corperone homicide. They testified, without objection, that Roberto Corperone had in fact been murdered in 1989, that Marcus Rivera was the immediate suspect in that homicide and that a fugitive warrant was issued for his arrest. The detectives further testified that Rivera was eventually apprehended in Philadelphia, extradited back to New York and indicted in the Bronx. Finally, one of the detectives described Rivera’s violent response and flight when he was discovered in his car in Philadelphia. If nothing else, the foregoing independent evidence of Rivera’s consciousness of guilt provides the essential corroboration necessary here (see, People v Lipsky, supra, at 571 ["proof of motive or flight, may 'be held to constitute the essential additional proof ”, quoting People v Reade, 13 NY2d 42, 46]).

Accordingly, the order of the Appellate Division should be affirmed.

Chief Judge Kaye and Judges Titone, Bellacosa, Smith, Ciparick and Wesley concur.

Order affirmed.