Bearden v. State
Annotate this CaseAfter a jury trial, Defendant was found guilty of second-degree murder, among other offenses. Defendant was received a sentence of life imprisonment for the murder conviction. On appeal, Defendant argued that the trial court erred by refusing to allow defense witness Angela Tyler to testify about Ray Allen Brown’s out-of-court statement and in prohibiting Defendant from questioning Brown about the purported statements he made to Tyler. The district court affirmed. Defendant appealed, arguing, inter alia, that the trial court erred (1) when it infringed upon the jury’s role by determining that Tyler's testimony was not credible, and (2) in evaluating the corroboration factor of the Chambers v. Mississippi analysis because it rejected Defendant’s own statement to detectives as adequate corroboration of Brown’s alleged confession. The Supreme Court quashed the district court’s decision, holding (1) the trial court improperly evaluated the credibility of Tyler’s testimony and erred when it excluded her testimony on that basis; and (2) a defendant’s own statement may be considered as corroboration of a witness’ testimony for the purpose of the corroboration factor of the Chambers analysis.
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