Minn. Stat. » CHAPTER 634. EVIDENCE; WITNESSES
Minnesota Statutes

Minn. Stat. § 634.04 (2026)

Uncorroborated Evidence Of Accomplice

✓ current as of May 2026
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A conviction cannot be had upon the testimony of an accomplice, unless it is corroborated by such other evidence as tends to convict the defendant of 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 169 cases (9 in the last 5 years), 1957–2026 · leading case: State v. Swanson, 707 N.W.2d 645 (Minn. 2006).
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State v. Swanson, 707 N.W.2d 645 (Minn. 2006). · cites it 10× “Minn.Stat. § 634.04 (2004). A district court has a duty to instruct a jury about the need for corroboration of an accomplice’s testimony.”
State v. Gail, 713 N.W.2d 851 (Minn. 2006). · cites it 12× “Under Minn.Stat. § 634.04 (2004), a criminal conviction may not be based "upon the testimony of an accomplice, unless it is corroborated by such other evidence as tends to convict the defendant of the commission of the offense.”
State v. Rodriguez, 754 N.W.2d 672 (Minn. 2008). · cites it 14× “Under Minn.Stat. § 634.04 (2006), "[a] conviction cannot be had upon the testimony of an accomplice, unless it is corroborated by such other evidence as tends to convict the defendant of the commission of the offense.”
State v. Henderson, 620 N.W.2d 688 (Minn. 2001). · cites it 9× “In sum, in each of the claimed erroneous evidentiary rulings, the district court did not abuse its discretion. Failure to Instruct on Accomplice Testimony A defendant may not be convicted based solely on the uncorroborated testimony of an accomplice.”
State v. Clark, 755 N.W.2d 241 (Minn. 2008). · cites it 10× “Minn.Stat. § 634.04 (2006) ("A conviction cannot be had upon the testimony of an accomplice, unless it is corroborated by such other evidence as tends to convict the defendant of the commission of the offense, and the corroboration is not sufficient if it merely shows the…”
State v. Jackson, 746 N.W.2d 894 (Minn. 2008). · cites it 16× “Under Minn.Stat. § 634.04 (2006), a defendant may not be convicted based "upon the testimony of an accomplice, unless it is corroborated by such other evidence as tends to convict the defendant of the commission of the offense.”
State v. Strommen, 648 N.W.2d 681 (Minn. 2002). · cites it 5× “Although we reverse based on the erroneous admission of evidence, to provide guidance on remand, we address Strom-men’s claims regarding the failure to give a jury instruction on accomplice testimony and prosecutorial misconduct. Regarding the omission of the jury instruction on…”
State v. Pippitt, 645 N.W.2d 87 (Minn. 2002). · cites it 8× “Pippitt maintains that his convictions must be reversed because Raymond is an accomplice and the state failed to corroborate Raymond’s testimony. “A conviction cannot be had upon the testimony of an accomplice, unless it is corroborated by such other evidence as tends to convict…”
State v. Smith, 932 N.W.2d 257 (Minn. 2019). · cites it 6× “First, he argues that his conviction was based on accomplice testimony that was insufficiently corroborated in violation of Minn. Stat. § 634.04 (2018). Second, he argues that the district court abused its discretion when it admitted evidence of three other-crimes incidents.”
State v. Shoop, 441 N.W.2d 475 (Minn. 1989). · cites it 8× “We first note that the accomplice corroboration requirement derives not from the constitution but from legislation, specifically, Minn.Stat. § 634.04 (1988), which provides as follows: A conviction cannot be had upon the testimony of an accomplice, unless it is corroborated by…”
State v. Barrientos-quintana, 787 N.W.2d 603 (Minn. 2010). · cites it 9× “We hold that the district court's error in failing to give the accomplice instruction required under Minn.Stat. § 634.04 did not affect Barrientos-Quintana's substantial rights because there is not a reasonable likelihood that the error had a significant effect on the jury's…”
Kennedy v. Louisiana, 554 U.S. 407 (2008). · cites it 2× “§ 24-4-8 (1995); Idaho Code § 19-2117 (Lexis 1979); Minn.Stat. § 634.04 (1983); Mont.Code Ann.”
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