People v. Daniels, 37 N.Y.2d 624 (1975)

The corroboration requirement for accomplice testimony is satisfied when there is evidence that tends to connect the defendant with the commission of the crime, assuring the jury that the accomplice is telling the truth.

Summary

Ray Daniels, Alvin Cooper, and Harriet Evans were convicted of drug possession based on accomplice testimony. The New York Court of Appeals affirmed, holding that the accomplice’s testimony was sufficiently corroborated by the presence of the defendants in close proximity to a large quantity of drugs and drug paraphernalia found in plain view in Daniels’ apartment. This evidence, combined with the statutory presumption of possession for those in close proximity to drugs in open view, provided enough of a connection to the crime to satisfy the corroboration requirement for accomplice testimony.

Facts

Sergeant Robert Race placed Ray Daniels’ apartment under surveillance. John Bryant was seen leaving the apartment. Donald James entered the apartment after conversing with an occupant. Daniels and James then left the apartment and were arrested. Bryant was apprehended getting off the elevator. Alvin Cooper opened the apartment door. Harriet Evans was found in bed inside the apartment. Police found 1331 glassine envelopes containing heroin, plastic bags with white powder and gelatin capsules, a scale, and cellophane tape on the kitchen table.

Procedural History

Daniels, Cooper, and Evans were convicted of criminal possession of a dangerous drug and criminally using drug paraphernalia after a jury trial. A codefendant, John Bryant, was acquitted. The Appellate Division affirmed the convictions. This appeal followed to the New York Court of Appeals.

Issue(s)

Whether the testimony of an accomplice, Donald James, was sufficiently corroborated to support the convictions of Daniels, Cooper, and Evans for drug possession.

Holding

Yes, because the presence of the defendants in close proximity to the drugs and drug paraphernalia in Daniels’ apartment tended to connect them to the commission of the crime, thereby corroborating the accomplice’s testimony.

Court’s Reasoning

The court emphasized that the purpose of the accomplice corroboration rule (CPL 60.22) is to ensure the accomplice is telling the truth, given their potential lack of reliability and motive to implicate others for leniency. The court stated that the corroborative evidence must “tend to connect the defendant with the commission of [the] offense.” It doesn’t need to prove guilt beyond a moral certainty, but it must reasonably satisfy the jury that the accomplice is truthful. In this case, the court found ample corroboration in the fact that the contraband was found in Daniels’ apartment, and Cooper and Evans were present inside. Citing Penal Law § 220.25(2), the court noted the statutory presumption that every person “in close proximity” to drugs in open view knowingly possesses them. The court reasoned, “When narcotics are found in open view in a room on private premises, every person ‘in close proximity’ to the drugs at the time of discovery is presumed by statute to have knowingly possessed them.” While rebuttable, this presumption, coupled with the large quantity of drugs, provided a sufficient connection between the defendants and the crime to corroborate the accomplice’s testimony that they were involved in the drug business. The court concluded that the policy behind the corroboration requirement was satisfied by the additional proof, which supported the accomplice’s testimony.