James E. Arnold, Appellant v. United States, Appellee (D.C. 1976)

Summary

The court affirmed two rape convictions, holding that joinder was proper, the evidence was sufficient to submit both charges to the jury, and the trial court's refusal to give the jurisdiction's then-required corroboration instruction was harmless error. The court prospectively abolished the judicial requirement that a mature female rape victim's testimony be corroborated, while retaining credibility-focused instructions in future cases. Judges Fickling and Mack would have reversed for a new trial because the required instruction was denied, while Judge Nebeker concurred in the result but urged flexibility for immature victims.

Holding

Joinder and severance. The trial court did not abuse its discretion in trying the two rape counts together because the offenses were similar in character, the evidence as to each was simple and distinct, and the evidence was carefully separated through instructions.

Sufficiency of the evidence and judgment of acquittal. The motion for judgment of acquittal was properly denied because, viewing the evidence in the government's favor and giving full play to the jury's credibility determinations, a reasonable juror could find guilt beyond a reasonable doubt.

Refusal to give the corroboration instruction. The trial court erred by refusing to give the corroboration instruction required by then-controlling District of Columbia precedent, but the error was nonconstitutional and harmless because the record showed adequate corroboration and no reasonable likelihood of a different verdict.

Future use of a corroboration requirement in rape cases. The court prospectively abolished any required corroboration instruction and any requirement that corroborative evidence be shown to avoid a judgment of acquittal in future rape and lesser included sex-related cases involving mature female victims.

James E. Arnold, Appellant v. United States, Appellee

Summary

Holding

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