2003
United
States v. Gibson, 58 MJ 1 (the test for
determining
whether a witness is an accomplice is whether a witness could be
convicted of
the same crime).
2002
United
States v. Bigelow, 57 MJ 64 (while the better
practice is
to caution members against placing too much reliance upon the testimony
of an
accomplice, there is no absolute bar to a conviction based on the
testimony of
an accomplice, even though there is no cautionary instruction).
2000
United
States v. Williams, 52 MJ 218 (old Manual rule, which
required
corroboration when an accomplice’s testimony was self-contradictory,
uncertain,
or improbable, and which raised evidentiary sufficiency concerns, did
not carry
over to RCM 918(c), the Discussion to which notes only that any
accomplice
testimony “should be considered with great caution”).