755 N.W.2d 241 (2008)

STATE of Minnesota, Respondent,
v.
Larry Larue CLARK, Appellant.

No. A06-1476.

Supreme Court of Minnesota.

August 28, 2008.

*244 Lawrence Hammerling, Chief Appellate Public Defender, Gurdip Singh Atwal, Assistant State Public Defender, Office of the State Public Defender, Saint Paul, MN, for appellant.

Susan Gaertner, Ramsey County Attorney, Jeanne L. Schleh, Assistant Ramsey County Attorney, Saint Paul, MN, for respondent.

OPINION

PAUL H. ANDERSON, Justice.

A Ramsey County jury found Larry Larue Clark guilty of first-degree premeditated murder while aiding and abetting or being aided and abetted by another in violation of Minn.Stat. §§ 609.185(a)(1) and 609.05, subd. 1 (2006) for the 1970 shooting death of Saint Paul Police Officer James Sackett. The district court convicted Clark for this crime and sentenced him to life in prison. In this direct appeal Clark *245 raises five issues: (1) whether an assistant county attorney is authorized by law to frame an indictment before a grand jury; (2) whether the district court erred in failing to instruct the jury that certain witnesses were accomplices as a matter of law; (3) whether the evidence is sufficient to support the jury's verdicts; (4) whether the court erred when it instructed the jury that the State was not required to prove that Reed was Clark's conspirator or accomplice; and (5) whether it was error for the court to have admitted evidence of Clark's 1971 bank robbery conviction. We conclude that: (1) an assistant county attorney may attend a grand jury for purposes of framing the indictment and examining witnesses; (2) that the court's failure to give sua sponte an accomplice instruction was plain error requiring remand for a new trial; (3) the evidence may be sufficient to support the conviction if the accomplice's instruction is corroborated; (4) the jury instructions are not required to match the indictment; and (5) the evidence of other crimes is relevant and not overly prejudicial. Therefore, we reverse Clark's conviction and remand for a new trial.

In 1969, appellant, Larry Larue Clark, and his friend, Ronald Reed, were teenagers living in the Selby-Dale neighborhood of Saint Paul, Minnesota. Clark and Reed frequented the Inner City Youth League, along with other young people from the neighborhood. Reed emerged as the leader of a group of these young people. According to Joseph Garrett, the group's self-described "minister of information," the group used the name United Black Front. At their meetings, the group discussed black-empowerment and self-protection from the police. At this time, the tension between the police and these young people was high. In the months preceding the murder of Saint Paul police officer James Sackett, at least two of the neighborhood's young men had been shot by the police. These shootings further increased the tension between members of the United Black Front and the police. As a result, the rhetoric at the United Black Front's meetings became more inflammatory. At Clark's trial there was testimony that Reed and others in the group wanted authority from the Black Panther Party to organize a chapter in Saint Paul and that members of the group thought that if they got national attention by killing a police officer it would increase their chances of success. Witness testimony indicated that Reed was a strong advocate for killing a police officer and that Clark agreed with Reed. Several of the group's members carried guns, and Reed and Clark were seen together with a bolt-action rifle on a number of occasions.

Just after midnight on Friday, May 22, 1970, the Saint Paul police received an emergency telephone call requesting assistance for a woman in labor at 859 Hague Avenue in the Selby-Dale neighborhood. Officer Sackett and his partner, Officer Glen Kothe, responded to the call, parked their police car in front of 859 Hague, went to the front door, and knocked. When no one in the house came to the door, Kothe walked to the back door and knocked. Hearing a dog bark inside, Kothe started to warn Sackett about the dog, and, as he did so, he saw a bright flash, heard a loud bang, and heard a scream. Running to the front of the house, Kothe found Sackett lying on the ground, bleeding. Kothe realized that Sackett had been shot and radioed for assistance. At some point, a crowd, including Reed and other members of the United Black Front, gathered at the scene. Clark was not identified as having been present in the crowd. Sackett later died as a result of a gunshot wound to the chest.

In the ensuing investigation, the police determined that no one at the 859 Hague *246 address had placed the emergency call or was involved in the shooting. They also concluded that the shot that killed Officer Sackett came from a southwesterly direction. A search of the surrounding area, however, produced no evidence of the shooting. Although no weapon or shell casing was found in the area, the police determined that the shot that killed Sackett probably came from a single-shot, bolt-action rifle. The police also determined that the emergency call that preceded the shooting was made from a telephone booth one block away at the corner of Selby Avenue and Victoria Street. No fingerprints or other useable evidence were found on or in the booth. At the time of the shooting, Clark lived at 882 Hague, which was approximately 102 yards west of 859 Hague on the south side of the street. The house at 859 Hague is located on the north side of the street.

Through voice-print analysis, the police were eventually able to identify Constance Trimble as the person who made the May 22nd telephone call. Trimble was Reed's girlfriend and the mother of his child. Trimble was arrested in October 1970 and, after a 1972 jury trial, she was acquitted of Sackett's murder. At her trial, Trimble testified that she had been told the telephone call was being made as a ruse to set up Gerald Starling for a drug bust in retaliation for Starling having allegedly threatened Trimble's family. Trimble refused, both during and after her trial, to identify the person who asked her to make the call. As a result, she was held in contempt of court and remained in jail for a period of time after her acquittal.

Further investigation revealed that just after midnight two nights before the shooting, Saint Paul police went to 867 Hague as a result of a similar medical emergency call. On that occasion, officers arriving at the 867 Hague address parked at the rear of the house, and, when there was no response to the officers' knocking, the call was written off as unfounded.

In October 1970, Reed and Clark, along with Horace Myles, were involved in an attempted armed bank robbery in Omaha, Nebraska. An off-duty police officer, working as a security guard at the bank, was shot by Myles when the officer tried to thwart the robbery. Reed and Clark also fired weapons during the robbery attempt. Clark was arrested for the attempted robbery 10 days later. Reed was arrested roughly two weeks after Clark at an acquaintance's apartment in Minneapolis. The police found Reed lying on a bed, with a handgun under the bed within his reach. In Reed's pants pocket the police found a note suggesting that Reed was planning to hijack an airplane and a to-do list for the hijacking. Reed hoped to use the hijacking as a means to gain the release of Trimble, Clark, and Gary Hogan, a friend of Reed's who was in jail on unrelated charges. The note demanded publicity for the Black Panther Party and $50,000 in gold. A search of the apartment produced a handgun, a flare, a sawed-off shotgun, and a duffel bag holding walkie-talkies. In 1971, Reed and Clark were convicted of the attempted bank robbery in Omaha. State v. Reed, 188 Neb. 815, 199 N.W.2d 707 (1972); State v. Clark, 189 Neb. 109, 201 N.W.2d 205 (1972). But neither Reed, Clark, nor anyone else was arrested in connection with Sackett's murder, and the investigation stalled.

In 1994, a television reporter interviewed Trimble about Officer Sackett's murder. Trimble refused to disclose who had asked her to make the false emergency telephone call. In 1995, the Saint Paul police contacted Trimble, at which time she admitted that Reed was with her when she made the call, but she refused to provide *247 any further information. In 2004, at her request, Trimble met with the police and disclosed for the first time that Reed had asked her to make the call and had given her a script to read. She told the police that Reed drove the two of them, along with their baby, to the telephone booth. She also stated that after the call was made, Reed drove them directly from the booth to Clark's house to get some marijuana.

Following this subsequent investigation, a grand jury was convened to determine whether there was probable cause to indict Reed and Clark. Two witnesses who ultimately testified at Clark's trial also testified before the grand jury. In 2005, Reed and Clark were indicted for aiding and abetting each other (count 1) and for conspiring with each other (count 2) to kill Officer Sackett. A warrant upon indictment was issued for Clark's arrest, and Clark was taken into custody two days after the indictment. As noted earlier, Reed was tried first and was found guilty on both counts. We affirmed Reed's conviction on direct appeal. See State v. Reed, 737 N.W.2d 572, 590 (Minn.2007).

Clark went to trial on April 10, 2006. At Clark's trial, Donald Walker testified that he frequented the Inner City Youth League in the late 1960s and early 1970s. He also attended "so-called Black Panther Party meetings" at a neighborhood church, at which Reed and Clark would make intense, motivational statements of hatred toward white people, the government, and the police. Walker did not recall any times when the discussions turned to plans of violence or to killing police officers, but he did testify that he "transported" a single-shot, bolt-action rifle for Reed and Clark on at least two occasions when he gave them a ride. At times, Walker's trial testimony conflicted with his grand jury testimony regarding the number of "Black Panther Party meetings" he attended and the number of times he gave Reed and Clark a ride when they were carrying a rifle.

Anthony Foster also testified that he attended the United Black Front meetings. Foster stated that at the meetings Reed talked about killing a police officer to attract national attention in order to get permission to start a Black Panther chapter in Saint Paul. He further testified that Reed, Arthur Harper, and Arling Reese came to his apartment a few days after Officer Sackett was shot and that Reed would not respond to his attempts to discuss the shooting. The defense asserted that Foster's testimony may not have been entirely accurate, as both Reese's trial testimony and records introduced at trial indicate that Reese was incarcerated in Moorhead, Minnesota, from April through August 1970, and, therefore, Reese could not have been present at Foster's apartment a few days after the shooting.

Trimble's account of events differed in some respects from her statements to investigators, her testimony at her trial, her testimony to the grand jury, and her testimony at Reed's and Clark's trials. At Clark's trial, she testified that Reed drove her directly to Clark's house after she placed the false emergency telephone call, that Clark was waiting outside the back door of his house when they arrived, and that she and Reed remained there for five to seven minutes before driving home. At her own trial, Trimble testified that she went to buy cigarettes after making the call and that Reed was home asleep when she returned. At both Reed's and Clark's trials, she testified that neither Reed nor Clark left Clark's house while she was there. During her grand jury testimony, however, Trimble testified as follows:

*248 Q: [A]fter you met up with Larry Clark who was standing in the back of his house, where did you go?

A: I went into the house ... I went into the restroom.

. . . .

Q: Could [Clark and Reed] have left?

A: They could have, you know. Now that I think about it, they could have, you know.

Trimble did not provide any explanation for the inconsistencies in her statements.

Joseph Garrett, the "minister of information" for the United Black Front, also testified at Clark's trial. Garrett testified that Reed and others at the United Black Front meetings advocated protecting themselves from the police "by any means necessary." Garrett further testified that he, together with Clark and others, agreed with that proposition. According to Garrett, members of the United Black Front "tended to be armed." He testified that he had access to several bolt-action, 30-caliber rifles that he had stolen and later sold, but, as far as he knows, none of the stolen rifles went to anyone else in the group. Garrett testified that Reed had approached him a few weeks before Sackett's murder about being involved in "bring[ing] down the first pig." Garrett understood this to mean killing a police officer. He testified that Reed knew of Garrett's combat experience in Vietnam and expert marksmanship. He also testified that he did not answer Reed at the time and never spoke with Reed about it after that.

Garrett also testified that a week before the Sackett shooting he felt he was being harassed by the police during a traffic stop and told the officers involved to "watch the rooftops." There was testimony from other witnesses that the officers took the comment to mean "beware of snipers." At least two police officers saw Garrett in the crowd that gathered after the shooting. The officers placed him in a squad car and asked about his "watch the rooftops" remark. Garrett said the rooftop comment was made in anger and that he knew nothing about the shooting. Garrett testified, however, that he also told the police about out-of-state Black Panther sympathizers in an effort to "throw [the police] off track." According to Garrett, after he got out of the squad car, the "sergeant in arms" of the United Black Front, Kelly Day, who also was in the crowd, told Garrett to keep his mouth closed.

Arthur Harper testified that he, Day, Reed, and Clark often socialized at Day's apartment, located at 844 Dayton Avenue. The apartment was less than two blocks from where Officer Sackett was shot. According to Harper, Reed often made statements, with which Clark agreed, that the police were the oppressors and needed to be taught a lesson. Harper further testified that he was with Reese when he saw Reed and Clark leave Day's apartment at about 11:30 p.m. the night of Sackett's murder and that, at the time, Reed appeared to be carrying a bolt-action rifle. As noted earlier, it appears Reese was in jail at that time. Harper also testified that he heard a gunshot 15 to 20 minutes later and that a few minutes later he walked south on Selby, in the direction the police cars were heading. Harper further testified that he joined Day, who was standing in front of the Inner City Youth League, and they were joined by Reed sometime later.

The State also presented evidence regarding bombings that occurred around the time of Officer Sackett's shooting. Sergeant Russell Bovee testified that Gary Hogan was convicted for the August 1970 bombing of Dayton's department store in downtown Saint Paul. According to Bovee, the bombing involved two bombs: the *249 first, smaller one to draw a police response and the second, bigger one to kill the responding police officers. Sergeant Paul Paulos testified that on September 12, 1970, he searched a garage rented by Day. In the garage, Paulos found a car containing 12 cases of dynamite.

Neither Clark nor Reed testified at Clark's trial. Clark called 21 witnesses to testify for the defense. In large part, the testimony elicited from the defense's witnesses included statements regarding (1) the monetary and penal incentives given to some of the State's witnesses; (2) the lack of evidence linking Clark to the crime scene; (3) the criminal activities of other members of the United Black Front and of people involved in the Inner City Youth League; (4) alternative perpetrators; (5) bullet trajectories; and (6) the social history of the era and the Black Panther Party.

At trial, the district court, over the defense's objection, allowed evidence of Clark's and Reed's 1971 bank robbery convictions to prove intent and motive to shoot a police officer. The court gave a limiting instruction to the jury about the use of this other crimes evidence both immediately before the jury heard the testimony about the convictions and at the end of Clark's trial. Clark also objected to the court's jury instruction on conspiracy. Clark argued that the jury should be instructed that the State must prove he conspired with Reed to shoot a police officer because that was how the indictment read, rather than having to prove simply that he conspired with an unknown person to shoot an officer.

The jury found Clark guilty on both counts of the indictment. The district court then convicted him of aiding and abetting and sentenced him to life in prison. Clark argues on this direct appeal that (1) an assistant county attorney is not authorized by law to frame an indictment before the grand jury; (2) the district court erred in failing to instruct the jury that certain witnesses were accomplices as a matter of law; (3) the evidence is insufficient to support the jury's verdicts; (4) the court erred when it instructed the jury that the State was not required to prove that Reed was Clark's conspirator or accomplice; and (5) it was error for the court to have admitted evidence of Clark's 1971 bank robbery conviction.

I.

We first address Clark's argument that his conviction should be reversed and the indictment should be dismissed under Minn.Stat. § 628.63 (2006). Clark argues that the statute provides that only an elected county attorney may appear before a grand jury and frame the indictment. According to Clark, because the elected Ramsey County Attorney did not appear and frame the indictment in his case, the assistant county attorneys who attended the grand jury meeting and framed the indictment in the County Attorney's absence were not authorized to do so.

Whether Minnesota law permits an assistant county attorney to attend the grand jury meeting and frame the indictment requires us to construe a number of statutes, which we do de novo. Broehm v. Mayo Clinic Rochester, 690 N.W.2d 721, 732 (Minn.2005). The object of statutory interpretation is to determine and effectuate legislative intent. State v. Zeimet, 696 N.W.2d 791, 793 (Minn.2005). We construe statutes to avoid absurd results. Am. Family Ins. Group v. Schroedl, 616 N.W.2d 273, 278 (Minn.2000). "Statutes relating to the same subject are presumed to be imbued with the same spirit and to have been passed with deliberation and full knowledge of all existing legislation on the subject and regarded by the lawmakers as being parts of a connected whole." Kaljuste *250 v. Hennepin County Sanatorium Comm'n, 240 Minn. 407, 414, 61 N.W.2d 757, 762 (1953). We also construe statutes as a whole and "must interpret each section in light of the surrounding sections to avoid conflicting interpretations." Am. Family Ins. Group, 616 N.W.2d. at 277.

Minnesota Statute § 628.63 requires that "the county attorney shall attend [the grand jury] for the purpose of framing indictments or examining witnesses...." "`Shall' is mandatory." Minn.Stat. § 645.44, subd. 16 (2006). Similarly, Minnesota Statute § 388.051 (2006) provides: "The county attorney shall ... attend before the grand jury, give them legal advice, and examine witnesses in their presence." Minnesota Statute § 388.10 (2006), however, authorizes a county attorney to appoint "one or more attorneys for assistance in the performance of [his or her] duties" who "shall have the same duties and be subject to the same liabilities as the county attorney."

Minnesota Statute § 628.63 was first enacted by the territorial legislature. Knowing that section 628.63 provided for the county attorney's presence before the grand jury for the purposes of framing the indictment and examining witnesses, the state legislature subsequently enacted Minn.Stat. § 388.051 in 1860, mandating that the county attorney shall "attend before the Grand Jury of such county upon the special request of said jury, and examine witnesses in their presence; he shall give them advice in any legal matter before them...." Minnesota Statute § 388.10 was enacted in 1921. We presume the legislature knew the duties prescribed to the "county attorney" in sections 628.63 and 388.051 when it later enacted Minn.Stat. § 388.10 authorizing the appointment of assistant county attorneys to perform the county attorney's duties. See Kaljuste, 240 Minn. at 414, 61 N.W.2d at 762. Therefore, reading all three statutes as parts of a connected whole, we conclude that the legislature intended to permit assistant county attorneys to perform certain duties of the county attorneys, including attending grand jury meetings for the purposes of framing indictments and examining witnesses.

To support his arguments, Clark relies on State v. Frink, 296 Minn. 57, 206 N.W.2d 664 (1973), but we conclude that this reliance is misplaced. In Frink, we analyzed Minn.Stat. § 388.10 as applied to the Minnesota Privacy of Communications Act, Minn.Stat. § 626A.05, subd. 1 (2006), which was enacted after section 388.10. In part, our holding was based on our conclusion that the more specific statute, section 626A.05, prevailed over the more general section 388.10. We held that only the county attorney—and not an assistant county attorney—may apply for a wiretap warrant under Minn.Stat. § 626A.05, subd. 1. See Frink, 296 Minn. at 66, 206 N.W.2d at 669. Section 626A.05, subd. 1, provides, in relevant part, "The attorney general or a county attorney of any county may make application as provided in section 626A.06, to a judge of the district court, of the Court of Appeals, or of the Supreme Court for a warrant...." Minn.Stat. § 626A.05, subd. 1. The narrow issue we addressed in Frink is distinguishable from the issue presented here. The case before us, unlike Frink, involves three statutes addressing the same general topic-the duties of county attorneys. Of the three statutes, Minn.Stat. § 388.10, authorizing the county attorney to appoint assistant county attorneys to perform the county attorney's duties, was the last to be enacted. Another significant distinction between this case and Frink is that the statute at issue in Frink, the Minnesota Privacy of Communications Act, a criminal statute, was enacted *251 pursuant to the provisions of Title III of the Omnibus Crime Control and Safe Streets Act of 1958. 18 U.S.C. §§ 2510-2520 (2006). This federal legislation limited the authority to apply for wiretap warrants to "principal prosecuting attorney[s]." Id. § 2516. Frink involved an assistant county attorney who applied for a wiretap warrant without the knowledge or consent of the county attorney. Frink, 296 Minn. at 66, 206 N.W.2d at 669. Reading the Minnesota statute in light of the federal legislation led us to the conclusion that to allow, on the facts presented, an assistant county attorney to apply for a wiretap warrant would put the Minnesota statute in conflict with federal law. That is not the situation presented here. Thus, we conclude that our decision in Frink does not support Clark's argument that assistant county attorneys are not authorized to attend grand jury meetings for the purpose of framing an indictment, giving legal advice, and examining witnesses.

For all the foregoing reasons, we hold that the fact that an assistant county attorney attended the grand jury meeting and framed the indictment against Clark does not render Clark's indictment and conviction legally deficient such that the indictment must be dismissed and the conviction overturned.

II.

Clark next claims that his conviction should be reversed and that he should receive a new trial because Trimble was an accomplice whose testimony at trial was not corroborated. At his trial, Clark did not request an accomplice instruction nor did he object to the admission of Trimble's testimony on those grounds.

Under Minnesota law, a criminal conviction cannot be based on the uncorroborated testimony of an accomplice. Minn.Stat. § 634.04 (2006) ("A conviction cannot be had upon the testimony of an accomplice, unless it is corroborated by such other evidence as tends to convict the defendant of the commission of the offense, and the corroboration is not sufficient if it merely shows the commission of the offense or the circumstances thereof."). This statutory rule reflects an inherent distrust of testimony from accomplices, who "may testify against another in the hope of or upon a promise of immunity or clemency or to satisfy other self-serving or malicious motives." State v. Shoop, 441 N.W.2d 475, 479 (Minn.1989); accord State v. Sorg, 275 Minn. 1, 5, 144 N.W.2d 783, 786 (1966). The statute contemplates that the issue of whether an accomplice's testimony has been sufficiently corroborated is a question of fact to be determined by the jury. See Shoop, 441 N.W.2d at 479. Accordingly, we have held that "[a]s a rule, trial courts have a duty to instruct juries on accomplice testimony in any criminal case in which it is reasonable to consider any witness against the defendant to be an accomplice." State v. Strommen, 648 N.W.2d 681, 689 (Minn.2002); accord Shoop, 441 N.W.2d at 479. A witness is considered an accomplice if "[she] could have been indicted and convicted for the crime with which the accused is charged." State v. Lee, 683 N.W.2d 309, 314 (Minn. 2004).

Failure to Give Accomplice Instruction

We first consider whether the district court erred in failing to instruct the jury on accomplice testimony. Because Clark failed to either ask for or object to the absence of such an instruction, our review of this issue is governed by the plain error analysis. See State v. Reed, 737 N.W.2d 572, 584 (Minn.2007). Therefore, we must determine whether the court committed an error, whether the error was plain, and whether the error affected *252 Clark's substantial rights. Id. at 583. If each of these requirements is satisfied, we must then consider whether reversal of Clark's conviction is necessary to ensure fairness and the integrity of the judicial process. Id.

In 1972, a jury acquitted Trimble of first-degree murder in the shooting death of Officer Sackett. Thus, Trimble could not, consistent with the Double Jeopardy Clause of the Constitution, again be indicted and tried for that crime. But as we recognized in State v. Reed, conspiracy to commit first-degree murder is not a lesser-included offense of first-degree murder. 737 N.W.2d at 583. Accordingly, we recognized that Trimble "could theoretically be charged with conspiracy to commit murder, the same crime of which Reed has been convicted," and that she therefore "could reasonably be considered an accomplice." Id. Like Reed, Clark was also convicted of conspiracy to murder Officer Sackett. Thus, as in Reed, a jury could reasonably conclude that Trimble is an accomplice in this case.

Under the plain error analysis, we generally consider an error to be "plain" if it "contravenes case law, a rule, or a standard of conduct." State v. Ramey, 721 N.W.2d 294, 302 (Minn.2006). As noted above, we have unambiguously held that "trial courts have a duty to instruct juries on accomplice testimony in any criminal case in which it is reasonable to consider any witness against the defendant to be an accomplice." Strommen, 648 N.W.2d at 689. Because it was reasonable for a jury to consider Trimble to be an accomplice, we conclude that the district court committed an error that was plain by failing to instruct the jury on accomplice testimony.

The third prong of the plain error analysis requires us to consider whether an error affected the defendant's substantial rights. "[A]n error affects substantial rights when there is a `reasonable likelihood' that the absence of the error would have had a `significant effect' on the jury's verdict." Reed, 737 N.W.2d at 585 (citation omitted). In Reed, we concluded that the failure to give the accomplice instruction did not affect Reed's substantial rights because "the weight of [the non-accomplice witnesses'] collective testimony was sufficient to corroborate [Trimble's] testimony." Id. But the State's evidence at Reed's trial was stronger than the State's evidence against Clark. Notably, at Reed's trial, Garrett, a trained sharpshooter, testified that Reed tried to recruit him for help in "bringing down the first pig"; Trimble testified that she and Reed made the false emergency telephone call; Foster testified that Reed's behavior shortly after the shooting was dejected and abnormal; and John Griffin testified that, in the early 1980s, Reed told him that "when [Reed] put a bead on that officer * * * he felt powerful," but "when he seen the bullet hitting him, he said he never felt more f[***]ed up in his life."^[1]Id. at 578-79, 585 (third alteration added). Without this evidence, the State's case against Clark was necessarily more dependent on Trimble's testimony; at the same time, the evidence available to corroborate her testimony was weaker. Therefore, we conclude that the district court's failure to instruct the jury on accomplice testimony affected Clark's substantial rights. We also conclude that reversal of Clark's conviction *253 is necessary in this case to ensure fairness and the integrity of the judicial process. Accordingly, we hold that the court committed plain error when it failed to give the accomplice jury instruction and that Clark's convictions must therefore be reversed on this basis.

Corroboration

The foregoing conclusion does not end our inquiry. The dissent links two of Clark's arguments—that Trimble's testimony is not corroborated and that the evidence presented is insufficient to sustain his convictions—and concludes that no reasonable jury could have found that Trimble's testimony was corroborated. Viewing the remaining evidence as being insufficient to sustain Clark's conviction, the dissent then concludes that we must reverse outright.^[2] Therefore, we proceed to determine whether a reasonable jury could conclude that Trimble's testimony was corroborated.

Because the accomplice testimony rule is based on the fear of self-serving dishonesty by accomplice witnesses, see Shoop, 441 N.W.2d at 479, we have long held that evidence is sufficient to corroborate an accomplice's testimony "when it is weighty enough to restore confidence in the truth of the accomplice's testimony," Sorg, 275 Minn. at 5, 144 N.W.2d at 786; accord State v. Scruggs, 421 N.W.2d 707, 713 (Minn.1988). This burden is met when the defendant is linked to the alleged crime by corroborating evidence that "in some substantial degree tends to affirm the truth of [the accomplice's] testimony and to point to the guilt of the defendant." State v. Rasmussen, 241 Minn. 310, 313, 63 N.W.2d 1, 3 (1954); accord Sorg, 275 Minn. at 5, 144 N.W.2d at 786; State v. Mathiasen, 267 Minn. 393, 398, 127 N.W.2d 534, 538 (1964). The precise "quantum of corroborative evidence needed necessarily depends on the circumstances of each case," but corroborative evidence does not need to be sufficient *254 to establish a prima facie case of the defendant's guilt or sustain a conviction. Scruggs, 421 N.W.2d at 713; accord State v. Pederson, 614 N.W.2d 724, 732 (Minn. 2000); Sorg, 275 Minn. at 5, 144 N.W.2d at 786; Mathiasen, 267 Minn. at 398, 127 N.W.2d at 538; Rasmussen, 241 Minn. at 313, 63 N.W.2d at 3.

In determining whether an accomplice's testimony is corroborated, "[t]he defendant's entire conduct may be looked to for corroborating circumstances." Scruggs, 421 N.W.2d at 713. "Circumstantial evidence may be sufficient to corroborate the testimony of an accomplice." Rasmussen, 241 Minn. at 313, 63 N.W.2d at 3; accord Scruggs, 421 N.W.2d at 713. Relevant facts that may be used to corroborate an accomplice's testimony and link the defendant to the crime include:

participation in the preparation for the criminal act; opportunity and motive; proximity of the defendant to the place where the crime was committed under unusual circumstances; association with persons involved in the crime in such a way as to suggest joint participation; possession of an instrument or instruments probably used to commit the offense; and unexplained affluence or possession of the fruits of criminal conduct.

Sorg, 275 Minn. at 5, 144 N.W.2d at 786; accord Scruggs, 421 N.W.2d at 713.

During Clark's trial, the State introduced evidence that Reed and Clark were close friends and were both members of the United Black Front, that Clark was present at meetings where Reed advocated killing a police officer as part of an attempt to bring a Black Panther chapter to Saint Paul, that Clark expressed agreement with these statements, and that both Reed and Clark made statements of hatred toward the government and the police in an "intense" and "pumped up" atmosphere. Additionally, the State introduced evidence that on multiple occasions before the shooting, Reed and Clark had been seen in possession of a single-shot, bolt-action rifle like the one used to kill Officer Sackett. The evidence also showed that Clark's house was located only 102 feet from the place where Officer Sackett was killed and was in the direction from which the fatal shot was fired. At approximately 11:30 p.m.—one-half hour before the shooting—Reed was seen carrying a rifle and walking with Clark toward Clark's house. Voice-print analysis established that Trimble placed the emergency call that led to the shooting from a public telephone located approximately one block from the crime scene. Finally, the State introduced evidence of a bank robbery in which both Reed and Clark participated and during which a off-duty police officer was shot.

This evidence points to Clark's guilt by suggesting that Reed and Clark shared a motive for killing Officer Sackett, placing the two men in proximity to the crime scene under unusual circumstances,^[3] placing them in possession of a weapon consistent *255 with the one used in the commission of the crime, and indicating an association between them such as to suggest their joint participation in criminal activity. Additionally, the voice-print analysis affirmed the truth of Trimble's testimony by confirming that she made the false emergency call from the telephone booth located one block from the crime scene.

The dissent's conclusion that Trimble's testimony was uncorroborated "as a matter of law" is based on the fact that specific statements during Trimble's testimony were not corroborated by outside evidence. For example, despite conceding that "the voice print analysis evidence seems to corroborate Trimble's testimony that she made the false emergency call," the dissent states that "[the voice-print analysis] does not directly or circumstantially corroborate her claim that Reed asked her to make the call or any of her other testimony." The dissent also notes in two places that the evidence in this case does not corroborate Trimble's testimony "that there was no rifle in the car, that she and Reed drove to Clark's house after she made the phone call, and that Clark was standing outside his back door when they arrived." But by focusing so narrowly on whether the evidence corroborated specific statements during Trimble's testimony, we believe that the dissent departs from the principles that have guided our analysis of accomplice-testimony corroboration since we decided Rasmussen, 241 Minn. at 313, 63 N.W.2d at 3, over 50 years ago. The dissent's narrow focus would also reverse our longstanding rule by requiring the introduction of independent evidence to prove every aspect of the accomplice's testimony that is probative of the defendant's guilt.

Finally, we address the dissent's assertion that we have "retreated on our longstanding requirement that in order for evidence to corroborate an accomplice's testimony it must have both some tendency to affirm the truth of the accomplice's testimony and at the same time point to the defendant's guilt." We disagree with the dissent's view of our precedent as requiring that a single piece of corroborating evidence satisfy both corroboration requirements. Rather, we read our precedent as requiring that the evidence as a whole must both affirm the truth of the accomplice's testimony and point to the defendant's guilt.^[4]

*256 Consistent with the basic rule that corroborating evidence need only be sufficient to restore confidence in the truthfulness of the accomplice's testimony, we have repeatedly stated that the quantum of corroboration needed varies with the unique circumstances of each case. See Pederson, 614 N.W.2d at 732; Scruggs,