Cited by

P. 31.01, meaning that we “examine all relevant factors to determine whether, beyond a reasonable doubt, the error did not have a significant impact on the verdict.”

at 260–65; –81 (Minn. 1989); Ezeka, d at 408–10; –13 (Minn. 2010).

An error is harmless when, “beyond a reasonable doubt, the error did not have a significant impact on the verdict.”

.” This statutory requirement “embodies the common law’s long-standing mistrust of the testimony of the accomplice,” for an accomplice “may testify against another in the hope of or upon a promise of immunity or clemency or to satisfy other self-serving or malicious motives.”

Under harmless error review, appellate courts “examine all relevant factors to determine whether, beyond a reasonable doubt, the error did not have a significant impact on the verdict.”

8 “An accomplice instruction ‘must be given in any criminal case in which any witness against the defendant might reasonably be considered an accomplice to the crime.’” ().

See Lee, d at 317; –81 (Minn. 1989) (stating that “a simple mechanical analysis of the record” is insufficient).

(affirming trial court’s admission of witness testimony that the witness observed defendant making a gesture “like a gun to the head” after being asked to confirm that he had shot someone ); 10 (affirming trial court’s admission of witness testimony that the witness observed defendant nodding his head when an accomplice said “I didn’t do it, [the defendant] did.”).

and the corroboration is not sufficient if it merely shows the commission of the offense or the circumsta nces thereof.” The district court must give an accomplice-testimony instruction “‘in any criminal case in which any witness against the defendant might reasonably be considered an accomplice to the crime.’” (quoting State v. Shoop , 6 ).

“An accomplice instruction ‘must be given in any criminal case in which any witness against the defendant might reasonably be considered an accomplice to the crime.’” Lee, d at 316 (d 475, 479 (Minn. 1989) ).

This rule recognizes that accomplice testimony is inherently suspect, because an accomplice “may testify against another in the hope of or upon a prom ise of immunity or clemency or to satisfy other self-serving or malicious motives,” State v. Shoop

The rule is de signed to protect against an accomplice who “may testify against another in the hope of or upon a promise of immunity or clemency or to satisfy other self-serving or malicious motives.”

When faced with an erroneous refusal to gi ve a particular jury instruction, the reviewing court must 6 “examine all relevant factors to determine whether, beyond a reasonable doubt, the error did not have a significant impact on the verdict.” State v. Shoop

This rule “reflects an inherent distrust of testimony from accomplices, who ‘may testify against another in the hope of or upon a promise of immunity or clemency or to satisfy other self-serving or malicious motives.’” Clark, d at 251 ().

Corroboration is required because of the inherent untrustworthiness of an accomplice, who “may testify against another in the hope of or upon a promise of immunity or clemency or to satisfy other self-serving or malicious motives.”

If “we conclude that the erroneous omission of the instruction might have prompted the jury, which is presumed to be reasonable, to reach a harsher verdict than it might have otherwise reached, [the] defendant must be awarded a new trial.”

When faced with an erroneous refusal to give jury instructions, the reviewing court must “examine all relevant factors to determine whether, beyond a reasonable doubt, the error did not have a significant impact on the verdict.”

(holding that, when a jury instruction is erroneously omitted, a reviewing court examines all relevant factors to determine whether, beyond a reasonable doubt, the error did not have a significant effect on the verdict).

Similarly admissible were the testimonies of witnesses who saw defendant nod his head immediately after defendant’s accomplice made the comment, “I didn't do it, [defendant] did.” State v. 15 Shoop

at 364 ; (-81 (Minn.1989)).

§ 634.04 and related case law); Barrientos-Quintana, d at 610 (stating that CRIMJIG 3.18 is “[t]he relevant instruction” to consider whether a witness against the defendant is an accomplice); (stating that an instruction similar to CRIMJIG 3.18 must be given when a witness might be considered an accomplice); (concluding that the court correctly *643 instructed the jury regarding accomplice testimony by using CRIMJIG 3.18).

*548 316 (Minn.2004); -81 (Minn.1989).

Because there is the risk that an accomplice “may testify against another in the hope of or upon a promise of immunity or clemency or to satisfy other self-serving or malicious motives,” corroborative evidence must be “weighty enough to restore confidence in the accomplice’s testimony, confirming its truth and pointing to the defendant’s guilt in some substantial way.” (quotation omitted).

The harmless-error inquiry requires an appellate court to “examine all relevant factors to determine whether, beyond a reasonable doubt, the error did not have a significant impact on the verdict.”

3 We have held that “trial courts have a duty to instruct juries on accomplice testimony in any criminal case in which it is reasonable to consider any witness against the defendant to be an accomplice.” ().

es that “[a] conviction cannot be had” unless the testimony of an accomplice “is corroborated by such other evidence as tends to convict the defendant of the commission of the offense.” The statute requires the district court to “submit to the jury the question of whether the corroborative evidence is trustworthy by an assessment of the credibility of the corroborative testimony.”

This statutory rule reflects an inherent distrust of testimony from accomplices, who “may testify against another in the hope of or upon a promise of immunity or clemency or to satisfy other self-serving or malicious motives.” accord State v. Sorg, 275 Minn. 1, 5