In Re Christopher B.

In a proceeding on a subsequent petition alleging that the court’s ward committed residential burglary and vandalism, the sole evidence implicating the minor was the uncorroborated testimony of an accomplice. The juvenile court denied the defense motion to dismiss the case due to insufficient evidence, on authority of In re Mitchell P. (1978) 22 Cal.3d 946 [ 151 Cal.Rptr. 330 , 587 P.2d 1144 ] (Mitchell P.). The Mitchell P. court held that Penal Code section 1111, prohibiting a conviction upon the testimony of an accomplice unless the testimony is corroborated by other evidence tending to connect the defendant with the commission of the offense, does not apply to juvenile court proceedings (Mitchell P, supra, at p. 949). We affirm the jurisdictional order, as we must. (Auto Equity Sales, Inc. v. Superior Court (1962) 57 Cal.2d 450, 455 [ 20 Cal.Rptr. 321 , 369 P.2d 937 ].) Nevertheless, as we explain, with the passage of nearly 30 years and attendant significant changes in juvenile law, the rule of Mitchell P. is well positioned for reassessment.

I. BACKGROUND

Michelle Crawford returned home from work around 5:30 p.m. on December 14, 2006. She noticed that a piece of…