Combs v. State

Summary

The Arkansas Supreme Court held that the accomplice's testimony was not sufficiently corroborated by independent evidence tending to connect Lynette Combs with her husband's murder. Because the State's remaining evidence established the crime but did not connect Combs to its commission, the court reversed the conviction and dismissed the charge.

Holdings

1. The State failed to present substantial independent evidence tending to connect Combs with the commission of the murder; evidence establishing the corpus delicti, blood in the station wagon, and Combs's association with Henry was insufficient corroboration.
2. The State may not satisfy the statutory corroboration requirement merely by persuading the jury that the accused gave false testimony.

Questions Presented

1. Whether the testimony of the accomplice, Hubert D. Henry, was sufficiently corroborated by independent evidence tending to connect Combs with the commission of the murder.
2. Whether the State could rely on evidence that Combs's testimony was false as corroboration of the accomplice's testimony.

Disposition

reversed