People v. Sweet, 67 N.Y.2d 263 (1986)
A witness who has pleaded guilty to criminal facilitation in connection with the defendant’s crime is considered an accomplice as a matter of law, and their testimony requires corroboration, even if they attempt to disavow guilt at the defendant’s trial.
Summary
Louis Sweet was convicted of robbery and weapon possession based on the testimony of Terri Jo Graves, who had pleaded guilty to criminal facilitation for her role in the crime. At Sweet’s trial, Graves claimed she was an unknowing participant. The trial court submitted Graves’ accomplice status to the jury, and the Appellate Division affirmed. The Court of Appeals reversed, holding that Graves was an accomplice as a matter of law because her prior guilty plea established her participation in the crime, regardless of her trial testimony. The court emphasized the need for corroboration of accomplice testimony to protect defendants from potentially fabricated evidence.
Facts
Terri Jo Graves introduced Horace Young to Louis Sweet at a bar and asked Young for a ride home. Graves sat in the front, and Sweet sat in the back. Upon arriving at Sweet’s residence, Sweet allegedly struck Young with a bottle, robbed him, and drove away with Graves in Young’s car. Graves was arrested and initially charged with robbery. She subsequently testified against Sweet before the Grand Jury. Graves then pleaded guilty to the misdemeanor of criminal facilitation in exchange for testifying against Sweet.
Procedural History
Sweet was convicted of robbery and weapon possession. He argued that Graves should have been deemed an accomplice as a matter of law, requiring corroboration of her testimony. The trial court submitted the issue of Graves’ accomplice status to the jury. The Appellate Division affirmed the conviction, citing People v. Basch. The New York Court of Appeals reversed the Appellate Division’s order, remitting the case for a new trial.
Issue(s)
- Whether a witness who has pleaded guilty to criminal facilitation for their involvement in a crime can create a question of fact regarding their accomplice status at the defendant’s trial by disavowing complicity.
Holding
- No, because Graves’ guilty plea to facilitation established her participation in the crime as a matter of law, and her subsequent attempt to disavow guilt at trial does not negate this established fact.
Court’s Reasoning
The Court of Appeals reasoned that under CPL 60.22(2), an accomplice is a witness who