Idaho Code

Idaho Code § 19-2117 (2026)

Testimony of accomplice — Corroboration. 

✓ current as of May 2026
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Testimony of accomplice — Corroboration. 

A conviction cannot be had on the testimony of an accomplice, unless he is corroborated by other evidence, which in itself, and without the aid of the testimony of the accomplice, tends to connect the defendant with the commission of the offense; and the corroboration is not sufficient, if it merely shows the commission of the offense, or the circumstances thereof.

Notes of Decisions
Cited in 62 cases (5 in the last 5 years), 1950–2026 · leading case: State v. Pierce, 685 P.2d 837 (Idaho Ct. App. 1984).
State v. Pierce, 685 P.2d 837 (Idaho Ct. App. 1984). · cites it 12× “Idaho Code § 19-2117 provides that a defendant cannot be convicted upon the uncorroborated testimony of an accomplice.”
State v. Emmons, 495 P.2d 11 (Idaho 1972). · cites it 46× “The principal issue is whether the district court erred in not finding that the state's main witness was an accomplice as that term is utilized in I.C. § 19-2117. [2] The district court allowed the jury to consider the issue as a factual question and the jury resolved it against…”
State v. Mark Lankford, 399 P.3d 804 (Idaho 2017). · cites it 4× “Thomas’ credibility as a witness was essential to Lankford’s conviction.”
State v. Scroggins, 716 P.2d 1152 (Idaho 1986). · cites it 8× “I.C. § 19-2117 provides: A conviction cannot be had on the testimony of an accomplice, unless he is corroborated by other evidence, which in itself, and without the aid of the testimony of the accomplice, tends to connect the defendant with the commission of the offense; and the…”
State v. Capone, 426 P.3d 469 (Idaho 2018). · cites it 8× “" I.C. § 19-2117. Accomplice is defined by Idaho Criminal Jury Instruction 313 as: a person who intends to promote or assist in the commission of a crime and who either directly commits the acts constituting the crime or who, before or during its commission, aids, assists,…”
State v. Brooks, 655 P.2d 99 (Idaho Ct. App. 1982). · cites it 12× “An accomplice can neither corroborate himself nor another accomplice to sustain a conviction within the requirements of I.C. § 19-2117. State v. Rose, 75 Idaho 59, 64 , 267 P.”
State v. Murphy, 499 P.2d 548 (Idaho 1972). · cites it 35× “Second, the defendant submitted that the only evidence presented by the prosecution *550 consisted of the uncorroborated testimony of accomplices, upon which a conviction cannot be had under I.C. § 19-2117. [2] The trial court denied the defendant's motion for dismissal or for…”
State v. Jones, 873 P.2d 122 (Idaho 1994). · cites it 8× “Idaho Code § 19-2117 states that: A conviction cannot be had on the testimony of an accomplice, unless he is corroborated by other evidence, which in itself, and without the aid of the testimony of the accomplice, tends to connect the defendant with the commission of the…”
Kennedy v. Louisiana, 554 U.S. 407 (2008). · cites it 2× “§ 24-4-8 (1995); Idaho Code § 19-2117 (Lexis 1979); Minn.Stat.”
State v. Campbell, 757 P.2d 230 (Idaho Ct. App. 1988). · cites it 12× “The requirement of corroboration of testimony from an accomplice is found in I.C. § 19-2117: A conviction cannot be had on the testimony of an accomplice, unless he is corroborated by other evidence, which in itself, and without the aid of the testimony of the accomplice, tends…”
State v. Lankford, 535 P.3d 172 (Idaho 2023). · cites it 6× “Lankford’s theory is layered and rests on a contorted application of the law of the case doctrine and the corroboration requirement of Idaho Code section 19-2117. Essentially, Lankford argues that since the State offered basically the “same evidence that was before this Court in…”
State v. Swenor, 528 P.2d 671 (Idaho 1974). · cites it 12× “I.C. § 19-2117. [1] She contends the trial court should have granted her motion for a judgment of acquittal (I.”
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