State of West Virginia v. Roland Vance

Summary

The court affirmed Vance’s conviction and life sentence under the Habitual Criminal Act. It held that corroboration of accomplice testimony on material facts connecting the accused to the crime justified refusing a cautionary instruction, and that although two police identifications resulted from an unduly suggestive procedure, the error was harmless beyond a reasonable doubt because other identification evidence was substantial and uncontradicted. The court also declined to find the life sentence disproportionate because breaking and entering carries a potential for violence and danger to life as well as property, and found no error in the reasonable-doubt instructions.