Cited by

7 But “the absence of corroboration in an individual case may well call for a holding that there is insufficient evidence upon which a jury could find the defendant guilty beyond a reasonable doubt.” (quotation omitted).

In support of his argument

See, (“Despite the minor inconsistencies in the state’ s case and the relative inconclusiveness of the supporting evidence, we defer to the jury’s right to believe the complainant and disbelieve the defendant and hold that the evidence was sufficient to sustain the verdicts of guilt beyond a reasonable doubt.”); (affirming conviction, in part, because “the victim’s testimony was positive and not contradicted, and was strongly corroborated by other evidence”); -66 (Minn. App. 1986) (affirming con

Finally, Carranza cites State v. Ani, in which the supreme court stated that lack of corroboration “may well call for a holding that there is insufficient evidence.” d 699, 700 (Minn. 1977) (quotation omitted).

-93 (Minn. 1993) (holding that testimony of alleged victim of child abuse was insufficient because there was expert testimony that the child had been exposed to highly suggestive material); (reversing conviction that was based solely on uncorroborated testimony of victim); (affirming conviction but recognizing that in some cases, lack of corroboration may lead to conclusion that evidence of guilt is insufficient).

k of corroboration [of K.I.’s statements] and lack of other evidence create such doubt about Diaz’s guilt that his conviction must be reversed.” In making this argument, Diaz acknowledges that “the testimony of a victim of criminal sexual conduct generally need not be corroborated.” But Diaz asserts that this case is an exception to that general rule

Third, d 699 (Minn. 1977) (per curiam), a criminal-sexual-conduct case in which the supreme court affirmed the conviction.

see also State v. Huss , -93 (Minn. 1993).3 3 Appellant cites to a nonprecedential decision of this court for the proposition that a prosecutor may not tell a jury that its burden of proof is necessarily satisfied by one witness’s credibility.

Nevertheless, Coe claims that the evidence is insufficient based on State v. Ani , 0 (Minn. 1977), in which the Minnesota Supreme Court contemplated the possibility that an absence of corroboration might render a victim’s testimony insufficient to establish guilt.

–93 (Minn. 1993) (reversing criminal-sexual-conduct conviction when the only direct evidence was a young child’s “particularly troublesome” testimony and the child was exposed to a “highly suggestive” book and tape about sexual abuse that may have caused her to imagine the abuse); see also 4 (“[T]he absence of corroboration in an individual case may well call for a holding that there is insufficient evidence upon which a jury could find the defendant guilty beyond a reasonable doubt.” (quotation

may well call for a holding that there is insufficient evidence upon which a jury could find the defendant guilty beyond a reasonable doubt.” (discussing Minn. Stat. § 609.347, subd.

In support, Phillips cites two supreme court opinions

Swift argues that this case is an exception to that general rule, which states that while corroboration of a victim’s testimony is not required, an individual case “may well call for a holding that there is insufficient evidence upon which a jury could find the defendant guilty beyond a reasonable doubt.” But in Ani, the court determined corroboration was not

for the principle that corroboration of testimony may be required in some instances to uphold a criminal conviction.

State v. Foreman , (quotation omitted ); see also State v. Ani , (“ [T]he absence of corroboration in an individual case .

1 (20 08); (upholding constitutionality of the statute).

Like the principal case that Suggs relies upon, State v. Ani , corroboration is unnecessary where the victim’s testimony was “not contradicted” and “corroborated by other evidence.” Significantly, Suggs corroborated S.L.’s testimony.

But “the absence of corroboration in an individual case may well call for a holding that there is insufficient evidence upon which a jury could find the defendant guilty beyond a reasonable doubt.” (quotation omitted).

s regarding the sexual assault before and during trial, “his testimony [is] suspect enough that corroboration was required.” Banks relies on State v. Ani, in which the supreme court stated that “the absence of corroboration in an individual case may well call for a holding that there is insufficient evidence upon which a jury could find the defendant guilty beyond a reasonable doubt.” (quotation and alterations omitted).

(stating that there may be cases in which the testimony of the complainant is such that a reversal by this court may be necessary absent corroboration).

may well call for a holding that there is insufficient evidence upon which a jury could find the defendant guilty beyond a reasonable doubt.” (quoting Note, The Rape Corroboration Requirement, 81 Yale L.J.

may well call for a holding that there is insufficient evidence upon which a jury could find the defendant guilty beyond a reasonable doubt.” (quoting Note, The Rape Corroboration Requirement, 81 Yale L.J.

Although we have recognized that “ ‘the absence of corroboration in an individual case’ ” may require a holding that the evidence at trial was insufficient to sustain the conviction, on the facts before us, we conclude that this is not such a case.