section 12-21-222 satisfy the corroboration requirement (Alabama) · Go Syfert
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section 12-21-222 satisfy the corroboration requirement in Alabama

8 Alabama opinions name it 2 courts 1982–2016 0 in the last five years

The cases below were cited by Alabama courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Woodberry v. Stategreen
alacrimapp · 1986 · cited in 3 Alabama opinions naming this issue, 1997–2011
2 sentences

2011See, e.g., Ex parte T.B., 698 So.2d 127, 129 (Ala.1997) (“Because the clear language of § 12-21-222 limits its corroboration requirement to felony convictions, all other adjudications, including youthful offender adjudications, are excluded from its effect.”); Woodberry v. State, 497 So.2d 587 (Ala.Crim.App.1986) (“We are unwilling to impose the requirement of corroboration in a delinquency adjudication in view of the fact that such additional proof is neither required by statute nor by rule of the Supreme Court”) Thus, even if B.H. had presented this argument in a timely fashion, it would not

1997But see Vincent v. State, 349 So.2d 1145 (Ala.1977) (in which this Court refused to extend that requirement to juvenile transfer hearings); Armstrong v. State, 294 Ala. 100 , 312 So.2d 620 (1975) (in which this Court refused to extend that requirement to probation revocation hearings); and Woodberry v. State, 497 So.2d 587, 589 (Ala.Crim.App.1986) (in which the Court of Criminal Appeals refused to impose that requirement in a delinquency adjudication, “in view of the fact that such additional proof [was required neither] by statute nor by rule of the Supreme Court”).

23
Ex Parte Holladaygreen
ala · 1985 · cited in 2 Alabama opinions naming this issue, 1997–1997
2 sentences

1997See Ex parte Holladay, 466 So.2d 956, 960-61 (Ala.1985) (holding that "[w]here a statute enumerates certain things on which it is to operate ..., the statute must be construed as excluding from its effect all things not expressly mentioned").

1997See Ex parte Holladay, 466 So.2d 956, 960-61 (Ala.1985) (holding that “[w]here a statute enumerates certain things on which it is to operate ..., the statute must be construed as excluding from its effect all things not expressly mentioned”).

22
Kuenzel v. Stategreen
alacrimapp · 1990 · cited in 1 Alabama opinions naming this issue, 2016–2016
1 sentence

2016In our opinion, this testimony, while certainly not overwhelming, was sufficient to corroborate Venn’s testimony and to satisfy the requirements of § 12-21-222.” Kuenzel v. State, 577 So.2d 474, 514 (Ala.Crim.App.1990), aff'd, 577 So.2d 531 (Ala.1991).

11
Baker v. Stategreen
alacrimapp · 2004 · cited in 1 Alabama opinions naming this issue, 2015–2015
1 sentence

2015See, e.g., Ex parte Batey, 958 So.2d 339, 343 (Ala.2006) (“Alabama courts have repeatedly held that an argument about the adequacy of the State’s evidence is not jurisdictionál and is therefore barred by Rule 32.2.”); and Baker v. State, 907 So.2d 465, 467 (Ala.Crim.App.2004) (“A challenge to the sufficiency of the evidence is not jurisdictional.”).

11
Batey v. Stategreen
ala · 2006 · cited in 1 Alabama opinions naming this issue, 2015–2015
1 sentence

2015See, e.g., Ex parte Batey, 958 So.2d 339, 343 (Ala.2006) (“Alabama courts have repeatedly held that an argument about the adequacy of the State’s evidence is not jurisdictionál and is therefore barred by Rule 32.2.”); and Baker v. State, 907 So.2d 465, 467 (Ala.Crim.App.2004) (“A challenge to the sufficiency of the evidence is not jurisdictional.”).

11
Ex Parte TBgreen
ala · 1997 · cited in 1 Alabama opinions naming this issue, 2011–2011
1 sentence

2011See, e.g., Ex parte T.B., 698 So.2d 127, 129 (Ala.1997) (“Because the clear language of § 12-21-222 limits its corroboration requirement to felony convictions, all other adjudications, including youthful offender adjudications, are excluded from its effect.”); Woodberry v. State, 497 So.2d 587 (Ala.Crim.App.1986) (“We are unwilling to impose the requirement of corroboration in a delinquency adjudication in view of the fact that such additional proof is neither required by statute nor by rule of the Supreme Court”) Thus, even if B.H. had presented this argument in a timely fashion, it would not

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Vincent v. Stategreen
ala · 1977 · cited in 2 Alabama opinions naming this issue, 1997–1997
2 sentences

1997But see Vincent v. State, 349 So.2d 1145 (Ala.1977) (in which this Court refused to extend that requirement to juvenile transfer hearings); Armstrong v. State, 294 Ala. 100 , 312 So.2d 620 (1975) (in which this Court refused to extend that requirement to probation revocation hearings); and Woodberry v. State, 497 So.2d 587, 589 (Ala.Crim.App.1986) (in which the Court of Criminal Appeals refused to impose that requirement in a delinquency adjudication, "in view of the fact that such additional proof [was required neither] by statute nor by rule of the Supreme Court").

1997But see Vincent v. State, 349 So.2d 1145 (Ala.1977) (in which this Court refused to extend that requirement to juvenile transfer hearings); Armstrong v. State, 294 Ala. 100 , 312 So.2d 620 (1975) (in which this Court refused to extend that requirement to probation revocation hearings); and Woodberry v. State, 497 So.2d 587, 589 (Ala.Crim.App.1986) (in which the Court of Criminal Appeals refused to impose that requirement in a delinquency adjudication, “in view of the fact that such additional proof [was required neither] by statute nor by rule of the Supreme Court”).

22

Also cited on this issue (6)

CaseCitedYears
Armstrong v. State green
ala · 1975
2 sentences

1997But see Vincent v. State, 349 So.2d 1145 (Ala.1977) (in which this Court refused to extend that requirement to juvenile transfer hearings); Armstrong v. State, 294 Ala. 100 , 312 So.2d 620 (1975) (in which this Court refused to extend that requirement to probation revocation hearings); and Woodberry v. State, 497 So.2d 587, 589 (Ala.Crim.App.1986) (in which the Court of Criminal Appeals refused to impose that requirement in a delinquency adjudication, “in view of the fact that such additional proof [was required neither] by statute nor by rule of the Supreme Court”).

1997But see Vincent v. State, 349 So.2d 1145 (Ala.1977) (in which this Court refused to extend that requirement to juvenile transfer hearings); Armstrong v. State, 294 Ala. 100 , 312 So.2d 620 (1975) (in which this Court refused to extend that requirement to probation revocation hearings); and Woodberry v. State, 497 So.2d 587, 589 (Ala.Crim.App.1986) (in which the Court of Criminal Appeals refused to impose that requirement in a delinquency adjudication, “in view of the fact that such additional proof [was required neither] by statute nor by rule of the Supreme Court”).

21997–1997
Brown v. State neutral
alactapp · 1967
2 sentences

1993The testimony of the undercover agent did not require corroboration under Alabama Code Section 12-21-222 (1975). 'The undercover agent in this case was not an accomplice of the defendant: Brown v. State , 44 Ala. App. 135 , 203 So.2d 700 (1967).

1993The testimony of the undercover agent did not require corroboration under Alabama Code Section 12-21-222 (1975). 'The undercover agent in this case was not an accomplice of the defendant: Brown v. State , 44 Ala. App. 135 , 203 So.2d 700 (1967).

21982–1993
Ex Parte Kuenzel green
ala · 1991
1 sentence

2016In our opinion, this testimony, while certainly not overwhelming, was sufficient to corroborate Venn’s testimony and to satisfy the requirements of § 12-21-222.” Kuenzel v. State, 577 So.2d 474, 514 (Ala.Crim.App.1990), aff'd, 577 So.2d 531 (Ala.1991).

12016–2016
McCoy v. State green
alacrimapp · 1981
2 sentences

1998McCoy v. State , 397 So.2d 577 , 587 (Ala.Cr.App. 1981).

1998This is because the Double Jeopardy Clause of the Fifth Amendment to the United States Constitution would bar a retrial if the defendant is correct in arguing that the evidence was either insufficient to establish guilt, see Ex parte Roberts , 662 So.2d 229 (Ala. 1995), or insufficient to corroborate the accomplice testimony, see McCoy v. State , 397 So.2d 577 (Ala.Cr.App.), cert. denied, 397 So.2d 589 (Ala. 1981). 2 Proof of motive alone is not generally enough to satisfy the corroboration requirement of § 12-21-222 .

11998–1998
Ex Parte Attorney General green
ala · 1981
1 sentence

1998This is because the Double Jeopardy Clause of the Fifth Amendment to the United States Constitution would bar a retrial if the defendant is correct in arguing that the evidence was either insufficient to establish guilt, see Ex parte Roberts , 662 So.2d 229 (Ala. 1995), or insufficient to corroborate the accomplice testimony, see McCoy v. State , 397 So.2d 577 (Ala.Cr.App.), cert. denied, 397 So.2d 589 (Ala. 1981). 2 Proof of motive alone is not generally enough to satisfy the corroboration requirement of § 12-21-222 .

11998–1998
Ex Parte Roberts green
ala · 1995
1 sentence

1998This is because the Double Jeopardy Clause of the Fifth Amendment to the United States Constitution would bar a retrial if the defendant is correct in arguing that the evidence was either insufficient to establish guilt, see Ex parte Roberts , 662 So.2d 229 (Ala. 1995), or insufficient to corroborate the accomplice testimony, see McCoy v. State , 397 So.2d 577 (Ala.Cr.App.), cert. denied, 397 So.2d 589 (Ala. 1981). 2 Proof of motive alone is not generally enough to satisfy the corroboration requirement of § 12-21-222 .

11998–1998

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