STATE of Tennessee v. DeWayne COLLIER AKA Patrick Collier, 411 S.W.3d 886

Supreme Court of Tennessee granted review to decide if a statutory rape victim’s testimony requires corroboration.
Defendant Collier, age 42, was convicted of aggravated statutory rape of a 14-year-old girl in 2008; victim testified about multiple sexual encounters; defense argued lack of corroboration of victim’s testimony if she is an accomplice.
Lower courts had treated a consenting minor victim in statutory rape as an accomplice whose testimony requires corroboration; the Court of Criminal Appeals affirmed the conviction.
Court reviewed whether the victim qualifies as an accomplice, potentially requiring corroboration, under the long line of Tennessee cases.
Court held that the testimony of a statutory rape victim does not require corroboration and affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a statutory rape victim must be corroborated	State argues corroboration is no longer required	Collier argues victim is an accomplice needing corroboration	Corroboration not required; testimony sufficient

Monts v. State, 379 S.W.2d 34 (Tenn. 1964) (general test for accomplice status; exception for children of tender years thou to be uncorroborated but later rule evolves)
Sherrill v. State, 321 S.W.2d 812 (Tenn. 1959) (accomplice rule; minors in sex offenses; corroboration required in early line)
Scott v. State, 338 S.W.2d 581 (Tenn. 1960) (minor victim of sex offense treated as accomplice, corroboration required)
Bough v. State, 152 S.W.3d 453 (Tenn. 2004) (reaffirmation of accomplice test; statutory rape context)
McKnight v. State, 900 S.W.2d 36 (Tenn. Crim. App. 1994) (consent not a defense; uncorroborated victim testimony for forcible/coercive offenses permissible)
Ballinger v. State, 93 S.W.3d 881 (Tenn. Crim. App. 2001) (accomplice corroboration discussions in statutory context)