promise immunity in Minnesota

2017Corroboration is required because of the inherent untrustworthiness of an accomplice, who “may testify against another in the hope of or upon a promise of immunity or clemency or to satisfy other self-serving or malicious motives.” State v. Shoop, 441 N.W.2d 475, 479 (Minn. 1989).

2017See Shoop, 441 N.W.2d at 479 (recognizing that section 634.04 is the embodiment of “long-standing mistrust” of accomplice testimony, so mistrusted because of the risk that an accomplice “may testify against another in the hope of or upon a promise of immunity or clemency”).

2012We have explained that courts distrust accomplice testimony because the accomplice might have chosen to testify against the defendant “ ‘in the hope of or upon a promise of immunity or clemency or to satisfy other self-serving or malicious motives.’ ” State v. Clark, 755 N.W.2d 241, 251 (Minn.2008) (quoting Shoop, 441 N.W.2d at 479 ).

2010Because of the “very real possibility that the jury could reject corroborating evidence and convict on the testimony of the accomplice standing alone,” the court’s “duty to instruct on accomplice testimony remains regardless of whether counsel for the defendant requests the instruction.” Id. (citing Shoop, 441 N.W.2d at 481 .) The rule “reflects an inherent distrust of testimony from accomplices, who ‘may testify against another in the hope of or upon a promise of immunity or clemency or to satisfy other self-serving or malicious motives.’ ” State v. Clark, 755 N.W.2d 241, 251 (Minn.2008) (quo

2011Because there is the risk that an accomplice “may testify against another in the hope of or upon a promise of immunity or clemency or to satisfy other self-serving or malicious motives,” State v. Shoop, 441 N.W.2d 475, 479 (Minn.1989), corroborative evidence must be “weighty enough to restore confidence in the accomplice’s testimony, confirming its truth and pointing to the defendant’s guilt in some substantial way.” State v. Hooper, 620 N.W.2d 31, 39 (Minn.2000) (quotation omitted).

2001Therefore, “corroborative evidence supporting the testimony of an accomplice must be ‘weighty enough to restore confidence in the accomplice’s testimony, confirming its truth and pointing to the defendant’s guilt in some substantial way.’ ” State v. Hooper, 620 N.W.2d 31, 39 (Minn.2000) (quoting Norris, 428 N.W.2d at 66-67 ).

1983In Del Hayes & Sons, Inc. v. Mitchell, 304 Minn. 275, 283 , 230 N.W.2d 588, 593 (1975), we explained that: Promissory estoppel is the name applied to a contract implied in law where no contract exists in fact.

1983In Del Hayes & Sons, Inc. v. Mitchell, 304 Minn. 275, 283 , 230 N.W.2d 588, 593 (1975), we explained that: Promissory estoppel is the name applied to a contract implied in law where no contract exists in fact.

2008This statutory rule reflects an inherent distrust of testimony from accomplices, who “may testify against another in the hope of or upon a promise of immunity or clemency or to satisfy other self-serving or malicious motives.” State v. Shoop, 441 N.W.2d 475, 479 (Minn.1989); accord State v. Sorg, 275 Minn. 1, 5 , 144 N.W.2d 783, 786 (1966).

2008This statutory rule reflects an inherent distrust of testimony from accomplices, who “may testify against another in the hope of or upon a promise of immunity or clemency or to satisfy other self-serving or malicious motives.” State v. Shoop, 441 N.W.2d 475, 479 (Minn.1989); accord State v. Sorg, 275 Minn. 1, 5 , 144 N.W.2d 783, 786 (1966).

2007“Evidence that merely shows the commission of the crime or the circumstances thereof is not sufficient to corroborate accomplice testimony.” State v. Johnson, 616 N.W.2d 720, 727 (Minn.2000).