People v. Robinson (1964)

In People v. Robinson (1964) 61 Cal.2d 373, a codefendant, Hickman, confessed to a crime charged against him and other defendants. The trial court "invited the jury to speculate upon whether or not Hickman was an accomplice, and implied that if they found him not an accomplice, they could convict the others on his uncorroborated testimony." The Supreme Court stated that Hickman's extrajudicial confession to the charged crime made Hickman an accomplice, as a matter of law. Therefore, the Supreme Court stated that the trial court should have so instructed the jury. "By telling the jury that corroboration of Hickman's testimony was required only if they found him to be an accomplice, the court impliedly and erroneously authorized the jury to find him not an accomplice, thereby making corroboration unnecessary." People v. Robinson, supra, 61 Cal.2d 373, 394. In People v. Robinson (1964) evidence established three men confronted the victim, one shooting him with a shotgun and killing him. The only evidence linking the defendant to the crime was his fingerprints found on a disabled car parked nearby with its license plate obscured, his evasive and conflicting replies to questions regarding his whereabouts at the time of the crime, and his denials to the police that he committed the crime. The court found the evidence either alone or in combination insufficient to corroborate the accomplice testimony. As to the fingerprints, there was no evidence as to when they were placed in the car. Furthermore, the prosecution presented evidence the defendant claimed he had recently used the car in which his prints were found. Thus, it was equally likely these prints had been placed on the car innocently. (Id. at p. 398.) The court concluded that at best, the fingerprints established the defendant had been in the car at some time prior to the car's discovery and therefore was insufficient to connect the defendant to the crime. (Id. at p. 399.) As to his conflicting statements regarding his whereabouts over the time period in question, there was only one conflict in his statement and the evidence at most demonstrated he may have been hiding something from the police. (People v. Robinson, supra, 61 Cal.2d at pp. 400-401.) However, there was no evidence to demonstrate this conflicting statement was made to hide his connection to the crime. (Ibid.) Finally, the court found the claimed "admission" was not an adoptive admission at all; rather, it was a denial as to any complicity. (Id. at pp. 401-402.) Consequently, there was insufficient corroboration of the accomplice testimony.