Nevada Revised Statutes

Nev. Rev. Stat. § 175.291 (2026)

Testimony of accomplice must be corroborated; sufficiency of corroboration; accomplice defined

✓ current as of July 2026

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NRS 175.291 Testimony of accomplice must be corroborated; sufficiency of corroboration; accomplice defined.

1. A conviction shall not be had on the testimony of an accomplice unless the accomplice 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 shall not be sufficient if it merely shows the commission of the offense or the circumstances thereof.

2. An accomplice is hereby defined as one who is liable to prosecution, for the identical offense charged against the defendant on trial in the cause in which the testimony of the accomplice is given.

(Added to NRS by 1967, 1429)

Notes of Decisions

Cited in 82 cases (7 in the last 5 years), 1969–2024 · leading case: LaPena v. State, 544 P.2d 1187 (Nev. 1976).

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LaPena v. State, 544 P.2d 1187 (Nev. 1976). · cites it 24× “Sheriff, supra, and not "testimony" of an accomplice within NRS 175.291. The witnesses who testified corroborating Weakland's testimony do not appear to have been motivated by self-serving purposes.”

Austin v. State, 491 P.2d 724 (Nev. 1971). · cites it 25× “NRS 175.291 provides: "1. A conviction shall not 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…”

Kennedy v. Louisiana, 554 U.S. 407 (2008). · cites it 2× “§ 46-16-213 (1985); Nev. Rev.Stat. § 175.291 (1985); N.D. Cent.”

Rowland v. State, 39 P.3d 114 (Nev. 2002). · cites it 4× “Second, Rowland argues that the district court failed to recognize that LaPeire was not charged with murder as Rowland and Smith were, and thus was not “liable to prosecution, for the identical offense[s] charged against the defendants] ’ ’ as required by NRS 175.291. Finally,…”

Lopez v. State, 769 P.2d 1276 (Nev. 1989). · cites it 3× “It necessarily follows that NRS 175.291 has no application to the instant case.”

Greene v. State, 931 P.2d 54 (Nev. 1997). · cites it 2× “Based upon this premise, Winfrey argues that Barker should not have been allowed to testify without the advice of an attorney or a grant of immunity. Because of these alleged constitutional violations, Winfrey asserts that Barker's testimony should have been stricken from the…”

Meegan v. State, 968 P.2d 292 (Nev. 1999). · cites it 6× “Meegan argues that his wife, Lillian Meegan, was an accomplice whose testimony was not sufficiently corroborated by other evidence and, therefore, this court must reverse Meegan's conviction pursuant to NRS 175.291(1). According to NRS 175.291(2), an accomplice is "one who is…”

Cutler v. State, 566 P.2d 809 (Nev. 1977). · cites it 3× “NRS 175.291 (2). 2 Upon a trial of the case the jury is the judge of the credibility of the witnesses, and the question of whether or not the witness was in fact an accomplice can be submitted to the jury upon proper instructions.”

Gallego v. State, 711 P.2d 856 (Nev. 1985). · cites it 2× “Under Nevada law, NRS 175.291, 3 the evidence against Gallego must be analyzed independent of Charlene’s testimony in order to ascertain whether sufficient evidence otherwise exists tending to connect Gallego to the commission of the crimes.”

Franklin v. State, 577 P.2d 860 (Nev. 1978). · cites it 2× “" NRS 175.291(1). As presented at the original preliminary hearing, the State's case against Mrs.”

Moore v. State, 417 P.3d 356 (Nev. 2018). · cites it 2× “Moore asserts that the evidence was material because the State needed Saldana's testimony to corroborate the other witnesses' testimony pursuant to NRS 175.291 (requiring corroboration for accomplice testimony).”

Globensky v. State, 605 P.2d 215 (Nev. 1980). · cites it 6× “NRS 175.291(1). An accomplice is defined as "one who is liable to prosecution, for the identical offense charged against the defendant on trial in the cause in which the testimony of the accomplice is given.”

Show all 82 citing cases →

— Nev. Rev. Stat. § 175.291(1) — 25 cases

Austin v. State, 491 P.2d 724 (Nev. 1971). “NRS 175.291 provides: "1. A conviction shall not 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…”

Franklin v. State, 577 P.2d 860 (Nev. 1978). “" NRS 175.291(1). As presented at the original preliminary hearing, the State's case against Mrs.”

Bushnell v. State, 599 P.2d 1038 (Nev. 1979).

Meegan v. State, 968 P.2d 292 (Nev. 1999). “Meegan argues that his wife, Lillian Meegan, was an accomplice whose testimony was not sufficiently corroborated by other evidence and, therefore, this court must reverse Meegan's conviction pursuant to NRS 175.291(1). According to NRS 175.291(2), an accomplice is "one who is…”

LaPena v. State, 544 P.2d 1187 (Nev. 1976). “Sheriff, supra, and not "testimony" of an accomplice within NRS 175.291. The witnesses who testified corroborating Weakland's testimony do not appear to have been motivated by self-serving purposes.”

— Nev. Rev. Stat. § 175.291(2) — 23 cases

Greene v. State, 931 P.2d 54 (Nev. 1997). “Based upon this premise, Winfrey argues that Barker should not have been allowed to testify without the advice of an attorney or a grant of immunity. Because of these alleged constitutional violations, Winfrey asserts that Barker's testimony should have been stricken from the…”

Evans v. State, 944 P.2d 253 (Nev. 1997).

Lopez v. State, 769 P.2d 1276 (Nev. 1989). “It necessarily follows that NRS 175.291 has no application to the instant case.”

Moore v. State, 417 P.3d 356 (Nev. 2018). “Moore asserts that the evidence was material because the State needed Saldana's testimony to corroborate the other witnesses' testimony pursuant to NRS 175.291 (requiring corroboration for accomplice testimony).”

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