The Power of a Single Witness

This was an appeal out of York County.  Johnson proceeded to a bench trial on robbery and conspiracy charges, and the judge convicted him of these crimes based on the uncorroborated account of the robbery victim alone.

If it wasn’t clear before, it is clear now, according to the Superior Court, that “a solitary witness’s testimony may establish every element of a crime, assuming that it speaks to each element, directly and/or by rational inference.”  While generally this principle of law most frequently rears its head in sex-assault cases, the Superior Court said it was “not aware of any case law suggesting that the principle itself does not apply across the whole spectrum of criminal offenses.”

The Superior Court was careful to advise trial courts about how it should understood its holding, however.  It stated, “[O]ur holding should be understood to not affect, whatsoever, the weight a factfinder assigns to uncorroborated testimony of a solitary witness.  Such a circumstance should be a significant, but not a dispositive factor when assessing credibility.