Lane v. State

James Lane (defendant) and three of his friends, Patricia R., Kris Shank, and Anna Eason, participated in the robbery of 71-year-old Hillard Doss at Doss’s house in Texas. The robbery was Lane’s idea. Lane told his friends that Doss was known to carry large amounts of cash, and all three friends agreed to Lane’s plan to commit the robbery. Lane drove his friends to Doss’s home. After arriving, Lane and Patricia stayed in the car, while Shank and Eason left to carry out the robbery. Shank and Eason returned to the car without having robbed Doss, but Lane encouraged them to go through with the robbery. Shank and Eason went back to Doss’s house, committed the robbery, and fled the scene with Lane and Patricia. Afterward, Lane, Shank, and Eason divided up the money they had stolen from Doss. Lane was arrested for aggravated robbery of an elderly person. At Lane’s trial, testimony from Patricia, Shank, and Eason was introduced against Lane. Under Texas law, a criminal defendant could not be convicted if the only evidence against him was uncorroborated accomplice testimony. The trial court instructed the jury that Eason and Shank were accomplices to the crime, but refused to instruct the jury that Patricia was also an accomplice, thereby allowing Patricia’s non-accomplice testimony to corroborate the testimony of Shank and Eason. Lane was convicted. Lane appealed to the Court of Appeals of Texas, arguing that the trial court erred when it refused to instruct the jury that Patricia was an accomplice.