What is the current state of the law on the corroboration rule?

MultiRegion, United States of America

The following excerpt is from U.S. v. Irving, 432 F.3d 401 (2nd Cir. 2005):

Our most recent pronouncement on the corroboration rule, in United States v. Bryce, 208 F.3d 346 (2000), emphasized that "the modern corroboration rule requires only that there be `substantial independent evidence which would tend to establish the trustworthiness of the statement.'" Id. at 354 (quoting Opper v. United States, 348 U.S. 84, 93, 75 S.Ct. 158, 99 L.Ed. 101 (1954)). Moreover, some statements do not require corroborationwe explained that if "the defendant's statements, given their nature and context, can support a finding of guilt beyond a reasonable doubt, no further evidence is needed." Id. at 355 (emphasis added). The majority opinion concludes that defendant's journal is neither self-corroborating nor "sufficiently corroborated `to justify a jury inference of [its] truth.'" (quoting Opper, 348 U.S. at 93, 75 S.Ct. 158).

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