United States v. Wiley

Citation492 F.2d 547, 160 U.S. App. D.C. 281; 1973 U.S. App. 7557.

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Brief Fact Summary. No facts of the case are provided.

Synopsis of Rule of Law. A complainant’s testimony in a rape case must be corroborated by independent evidence that would permit the jury to conclude beyond a reasonable doubt that the victim’s account of the crime was not fabricated.

Issue. Was the complainant’s testimony in the rape case adequately corroborated by independent evidence to support the defendant’s conviction? What constitutes adequate corroboration of independent evidence in a rape case?

Held. No. Defendant’s conviction reversed. The testimony must be corroborated by independent evidence permitting the jury to conclude beyond a reasonable doubt that the victim’s account of the crime is truthful.

Concurrence. Judge Bazelon provided the concurring opinion. Under the common law, there is no requirement of corroboration with regard to testimony for sex offenses. There are many justifications offered for the requirement of corroboration in sex cases. Some are the difficulty in defending a rape charge, potential false charges, racism and discrimination against women. This Court chooses to retain a corroboration rule in order to guard against the possible dangers of fabrication by an alleged victim.

Discussion. The idea that the testimony of a single witness is inadequate to prove a crime has been around for years. In rape cases where the evidence is lacking, the dangers to the defendant outweigh the obstacles created for the prosecution. In order to provide a safeguard to the defendant in sex cases, the complainant’s testimony must be corroborated by independent evidence allowing the jury to conclude beyond a reasonable doubt that the victim’s account of the crime is believable.