People v. Tobias

In People v. Tobias (2001) 25 Cal. 4th 327, the Supreme Court held that a minor participant in acts of incest could not be guilty of that offense, and could not be viewed as an accomplice, by virtue of the " 'settled' " rule that " 'where a penal statute expressly outlaws conduct against minors, a minor who is a victim of the proscribed conduct is not an accomplice and the jury need not be instructed that the minor's testimony requires corroboration.' " ( Id. at p. 334.)