Massachusetts General Laws

Mass. Gen. Laws ch. 233, § 20I (2026)

Necessity of corroborating testimony of, or evidence produced by, person granted immunity

✓ current as of July 2026

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Section 20I. No defendant in any criminal proceeding shall be convicted solely on the testimony of, or the evidence produced by, a person granted immunity under the provisions of section twenty E.

Notes of Decisions

Cited in 8 cases (3 in the last 5 years), 1977–2024 · leading case: Commonwealth v. Stewart, 377 N.E.2d 693 (Mass. 1978).

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Commonwealth v. Stewart, 377 N.E.2d 693 (Mass. 1978). “The defendant argues that, since a conviction cannot be based on the uncorroborated testimony of an accomplice to whom immunity has been granted, G. L. c. 233, § 20I; Commonwealth v. DeBrosky, 363 Mass.”

Commonwealth v. Vega, 866 N.E.2d 892 (Mass. 2007). “The Legislature has created evidentiary privileges for different mental health providers using varying wording, form, and placement.”

Commonwealth v. Doyle, 364 N.E.2d 1283 (Mass. App. Ct. 1977). “2 The applicable statute is G. L. c. 233, § 20I, inserted by St. 1970, c.”

Commonwealth v. Widener (Mass. App. Ct. 2017). “The defendant relies on G. L. c. 233, § 20I, inserted by St. 1970, c.”

Commonwealth v. Rodriguez, 104 N.E.3d 684 (Mass. App. Ct. 2018). “G. L. c. 233, § 20I, inserted by St. 1970, c.”

Commonwealth v. Troche (Mass. 2023). “30In any retrial, the judge should instruct the jury that immunized testimony cannot serve as the sole basis for a conviction, see G. L. c. 233, § 20I, and ensure that the jury "in assessing an immunized witness's testimony .”

Commonwealth v. Darren Hughes. (Mass. App. Ct. 2023). “G. L. c. 233, § 20I. At trial, the victim testified that she had responded to an advertisement on Backpage.”

Commonwealth v. Steven Martinez-Santana. (Mass. App. Ct. 2024). “Thus, we find the Commonwealth presented sufficient corroborating evidence to meet the requirements under G. L. c. 233, § 20I, and, therefore, the trial court did not err by 6 denying the defendant's motions for required finding of not guilty.”

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