People v. Kimble
Facts
After two victims were murdered in their home and the husband's stereo store was burglarized the same night, police linked defendant to both scenes through eyewitness identification, fingerprints in the victims' house, stolen store property, and the victims' store keys found in defendant's residence. After his arrest and Miranda advisement, defendant told police he had bought the stereo equipment months earlier from a stranger and had never been in any house in the victims' neighborhood. At trial, the prosecution had already presented evidence indicating the equipment was stolen that night and that defendant's fingerprints were found inside the victims' home. Over objection, the trial court admitted defendant's recorded statement.
Issue
May the prosecution introduce a defendant's false exculpatory statement as evidence of consciousness of guilt when the statement's falsity is shown by other prosecution evidence rather than by inconsistency with the defendant's own trial testimony? The case also asked whether the initial nighttime search warrant was valid and whether certain penalty-phase errors required reversal.
Rule
A defendant's deliberately false statement to police about matters within the defendant's own knowledge, relating to guilt or innocence, is admissible to show consciousness of guilt if the statement's falsity may reasonably be inferred from the evidence. The falsity need not be established by the defendant's own trial testimony; it may be shown through other reliable evidence, and disputes over whether the statement was false generally go to weight, not admissibility.
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Should the trial court admit Nolan's statement that he had never been inside the store?