State v. Jones

Summary

The court held that a criminal defendant is entitled to a special credibility instruction when an incarcerated informant testifies about the defendant's inculpatory statements, even if the statements were made outside prison. Because the witness was incarcerated when he sought leniency in exchange for information about the defendant's confession, the trial court improperly refused the requested instruction, and the error was not harmless given the absence of physical evidence, limited corroboration, and the importance of the witness's testimony. The judgment was reversed and the case was remanded for a new trial.