by Jacob Barrett and Dale Chappell

The general public’s familiarity with the government’s use of informants in criminal proceedings is largely confined to movies and TV documentaries. Yet, every year, the government negotiates tens of thousands of deals “off the record,” which are subject to few restrictions and have little to no oversight.

While informants are an important investigative tool for the government, the information they provide is infamously unreliable. Innocent people spend decades incarcerated for crimes they did not commit. Many have spent years on death row awaiting an opportunity to prove their innocence and secure their freedom. False informant testimony is a leading cause of wrongful convictions.

Rewarding informants for acting as a witness for the government may seem like common sense, but time and again, this technique has led to drastic consequences that call into question the very integrity of the justice system. Because of the plethora of wrongful convictions and government misconduct, there are calls to make the use of “incentivized witnesses” more transparent as well as create a process for meaningfully validating information offered by an informant — who, if we consider the circumstances, has every reason to game the system.

Overview of the Problem

Informants have existed from time immemorial. Conviction of the Innocent: Lessons From Psychological Research, a book of research edited by Brian Cutler, places their use back “to at least the fourth century BCE, where the Athenian government relied upon informants to expose treasonous plots.” Some scholars have made an argument that the prevalence of informant testimony in its modern context is distinctly related to the spread of mandatory minimum sentencing provisions.

In United States v. Ford, 99 U.S. 594 (1878), the so-called Whiskey Cases, the U.S. Supreme Court acknowledged a prosecutor’s inherent authority to enter into informal immunity agreements with accomplices in exchange for their cooperation, likening the exchange to the practice of “approvement” in English common law. Approvement referred to the situation where the “approver” indicted of treason or felony was arraigned and could confess the charge before a plea and implicate his accomplice. Approvement entitled the individual to “pardon ex debito justitiae.” On the other hand, if the accomplice was acquitted, the approver would be condemned. Even then, Sir Matthew Hale observed “that more mischief hath arisen to good men by these kind of approvements, upon false and malicious accusations of desperate villains.”

The government’s use of informants became a formal part of law enforcement during the Prohibition era in the 1920s, when the Bureau of Alcohol, Tobacco, and Firearms began using entrapment and informants to catch gun and alcohol smugglers, making snitching an integral part of the criminal justice system. Use of informants exploded in the 1970s after President Richard Nixon declared the “War on Drugs,” and the government employed the same techniques of entrapment and information to bust suspected drug offenders on a larger scale. President Ronald Reagan ramped up the War on Drugs, creating harsh “tough-on-crime” mandatory minimum sentences for drug offenders, which could be avoided only if the defendants cooperated with the government by snitching on their confederates. The government’s targets weren’t drug kingpins but low-level grunts who would flip and give law enforcement information on the higher ups in the organization. Faced with mandatory life sentences in prison, these low-level street dealers had no choice but to cooperate, even if it meant they had to make up stories. [See: CLN, Mar. 2019, p.1.]

What Is an Incentivized Witness?

An incentivized witness is someone who testifies on behalf of the government against another person or group in exchange for an expected benefit. This benefit may include favorable treatment in the person’s own criminal case, money, or other goods or consideration. This, however, does not include citizens who come forward on their own with information about a crime, even if for a reward. These people are known as “good Samaritans.” We are not talking about good Samaritans when it comes to incentivized witnesses.

The term “incentivized” means “a motivation or reason for doing something. Incentives offered to government witnesses include reduced sentences, cash, a chance to spare friends or family from criminal charges, or any other deal the government offers for the witness’ testimony.

The term “witness,” also referred to as an informant in this context, means someone who provides information or testimony in exchange for an incentive. Though not limited to criminal suspects, by far the most common government informant is the “jailhouse informant,” a person facing criminal charges or serving a prison sentence who wants a reduced sentence or charges dropped in exchange for his information against a fellow prisoner. The state of Washington, for example, defines “informant” as “any criminal suspect, whether or not they are detained or incarcerated, who provides information in exchange for a deal, promise, inducement, or benefit, or expectation thereof.” The labels “incentivized witness” and “informant” are used interchangeably.

The testimony offered by informants about what a criminal defendant said or admitted to is called a “secondary confession,” which is defined as “evidence provided by someone other than the suspect and purported to be direct information from the suspect.” This secondary confession is the product the informant sells and for which the government barters. [See: CLN, Mar. 2019, p.1.]

Types of Incentivized Witnesses

Informants come in all shapes andsizes and are referred to by a variety of names — “snitch,” “jailhouse snitch,” “professional snitch,” “accomplice informant,” and “calumniator” — that come from their place in the grand scheme of proceedings.

The “jailhouse snitch” is the prototypical informant who informs law enforcement or jail staff about what another prisoner has supposedly said or done, usually the result of an overheard conversation or at the snitch’s prodding. This type of informant is often involved in many wrongful convictions.

The “professional snitch” makes a living out of putting people behind bars by selling information to law enforcement. Some professional snitches have actually helped encourage and facilitate crimes and made millions of dollars from the government testifying against the defendants they built up and then brought down.

The “accomplice informant” is the codefendant of the person the informant is offering information against in an effort to get his or her own charges dropped or sentence reduced. These informants are commonly used by law enforcement to ensnare others in the scheme, especially the bigger fish.

Interestingly, the Department of Justice (“DOJ”) does not consider accomplice informants as “confidential informants” to which rules governing protection and payments apply. Instead, the government considers these informants “cooperating defendants/witnesses” who have an expectation of a reward for their services.

While an accomplice’s primary motivation to cooperate with the government may be to shorten his stay in jail, it is important to recognize that other factors may influence his decision as well. An informant may testify against a confederate due to fear, a desire for revenge, or the need for self-protection (that is, a concern that if he does not testify against a co-defendant, the co-defendant may testify against him).

The “calumniator” has similar traits of other types of informants but is distinguished by the desire to shift as much blame as possible onto someone else in order to escape liability. It is not uncommon for the calumniator to place blame on an innocent person, which has resulted in many wrongful convictions. [See: CLN, Mar. 2019, p.1.]

Conditions and Agreements

The financial and personal benefits incentive witnesses receive can be substantial. Rewards can range from extra food or privileges in prison to immunity from charges, including murder. In some notorious cases, witnesses have even received drugs and conjugal visits. See, e.g., United States v. Boyd, 833 F. Supp. 1277 (N.D. Ill. 1993). The U.S. Supreme Court has ruled that prosecutors have nearly unregulated authority to provide incentives to informants in order to obtain information.

By offering incentives to informants, the government is, in effect, “buying” information. However, while federal anti-bribery laws state, “whoever … directly or indirectly, gives, offers, or promises anything of value” for a person’s testimony may be punished by a fine or prison term, the government’s purchase of testimony does not fall into that provision’s scope.

In United States v. Singleton, 144 F.3d 1343 (10th Cir. 1998) (“Singleton I”), a panel of the U.S. Court of Appeals for the Tenth Circuit initially ruled that the government’s “payment” to an informant for his testimony violated the federal anti-bribery statute. However, the court granted a rehearing and, sitting en banc, reversed the ruling in Singleton I finding that the term “whoever” under the statute does not apply to the government. United States v. Singleton, 165 F.3d 1297 (10th Cir. 1999) (en banc), cert. denied, 119 S. Ct. 2371 (1999) (“Singleton II”).

With the exception that the incentive cannot be contingent on the outcome of the informants’ help, there are few checks on the power of the government to offer incentives to informants. In other words, the prosecutor cannot say, “I will let you out of jail only if your testimony helps to convict this guy.”

Any “promise, reward, or inducement” to a government witness is considered exculpatory evidence that must be disclosed. In Giglio v. United States, 405 U.S. 150 (1972), the U.S. Supreme Court ruled that by doing so, a defendant is afforded an opportunity to test the credibility of the government’s witness by way of cross-examination, which satisfies due process under the Constitution.

Prosecutors have found ways to circumvent Giglio protections by making promises that are vague or open-ended because they are not considered “promises” under Giglio. For example, the government’s assurances to an informant that it will “make sure he’s taken care of” in exchange for his help is not deemed a promise requiring disclosure under Giglio. These vague, wink-and-a-nod incentives have led many critics to point out that defendants are then subject to the false and unsubstantiated testimony of informants who are operating under a cloak of protection from the government.

But there are limits to how much the government can get away with regarding Giglio. In Massiah v. United States, 377 U.S. 201 (1964), the U.S. Supreme Court held that incriminating statements secured and electronically transmitted to federal agents, at their behest, by a confederate of the defendant, who was under investigation and free on bail, violates the Sixth Amendment right to counsel. However, an informant may act on his own to obtain evidence against a defendant and share it with the government, which they could then compensate him for later.

In Hoffa v. United States, 385 U.S. 293 (1966), the U.S. Supreme Court upheld testimony that was purchased by the government because the defendant was protected by “the establishment safeguards of the American legal system.”

Disclosure of the prosecution’s witnesses is not required unless a case goes to trial. In United States v. Ruiz, 536 U.S. 622 (2002), the U.S. Supreme Court ruled that the Constitution doesn’t require the government to disclose informant information prior to entering into a plea agreement with a defendant. Justice Breyer noted that requiring disclosure of informant evidence would improperly force the government to engage in substantial trial preparation prior to plea bargaining. [See: CLN, Mar. 2019, p.1.]

Justification for Using
Incentivized Witnesses

There are two primary reasons for why prosecutors enter into a cooperation agreement with a witness in a criminal case. First, the witness’ testimony may strengthen a weak case against a more culpable or dangerous confederate. Second, such cooperation may allow the prosecutor to solve a different, more serious crime.

The government claims that informant information is critical to enforcement of laws because many crimes, such as “consensual crimes” (e.g., drugs, fencing, bookmaking), crimes with fearful victims (e.g., extortion, blackmail), and crimes whose success depends on member secrecy (e.g., public corruption, organized crime) are difficult to prove without securing the cooperation of a member of the criminal conspiracy.

This “cooperation system” benefits both the informant and the prosecutor: the informant gets some leniency or benefit, and the prosecutor gets information that will aid in the prosecution of other defendants. Prosecutors argue that the effectiveness of the criminal justice system is dependent on the use of informants, because many crimes would go undiscovered and/or unprosecuted without the information that only they can provide. [See: CLN, Mar. 2019, p.1.]

Criticism of Incentivized Witnesses

Critics point out that with a carrot dangling before them, an informant can manipulate their version of the facts precisely because they know which facts are verifiable and which are not. The lies of the incentivized witness are difficult to detect, and the jury may infer from the details provided by the witness that the facts are indeed true.

Just as an offer of leniency provides a powerful incentive to cooperate, it also provides a powerful incentive to lie. There are legitimate criticisms for allowing informants to continue to commit crimes with full immunity while cooperating with the government as incentivized witnesses. In the infamous case of James “Whitey” Bulger, FBI handlers responsible for overseeing Bulger purposely turned a blind eye to his criminal activity, which allegedly included multiple murders while he was cooperating. The FBI used Bulger as an informant while he was committing the same crimes he was providing information on others for.

Another notorious informant was James Malloy, a killer who prosecutors set free in exchange for information he supposedly had in some unsolved cases. After prosecutors let Malloy go free as payment for this information, he killed a 15-year-old boy in 2012 just after his release. Unfortunately, the information Malloy provided was worthless.

While prosecutors have broad power to give witnesses payments in exchange for their testimony, criminal defendants, however, do not have that luxury. For example, the Illinois Supreme Court suspended a criminal defense attorney for 18 months for paying a witness $50 to testify truthfully. In re Kien, 372 N.E.2d 376 (Ill. 1977). Prosecutors, though, are not held to the same standard, as made clear in the Tenth Circuit’s decision in Singleton II and by every other circuit since that ruling. [See: CLN, Mar. 2019, p.1.]

Corrupt Cops and Prosecutors

The problems caused by lying informants are compounded when police and prosecutors cover up their informant’s lies to protect convictions or to cover up their own corrupt activities in securing the conviction in the first place.

In 2014, prosecutors in the Orange County District Attorney’s Office in California (“OCDA”) were caught lying about and covering up a jailhouse informant program in which prosecutors would place informants near certain defendants in the jail to gather confessions and other incriminating evidence. The incident became known as the “snitch scandal” and has continued to plague the OCDA.

OCDA prosecutor Tony Rackauckas dropped murder charges three times in 2014 after he was accused of hiding his jailhouse snitch’s information from defendants. Superior Court Judge Thomas Goethals ordered Rackauckas to disclose his list of jailhouse informants in an attempted murder case. Rackauckas dismissed the charges in that case and several others to avoid disclosure.

In 2015, Goethals tossed the entire OCDA office off a case — all 250 prosecutors — when they refused to turnover jailhouse informant evidence in the case of mass-murderer Scott Dekraai. The Orange County Sheriff’s Department (“OCSD”) denied it had a jailhouse snitch program in its jails, even after documents revealed by defense attorneys clearly showed that it did. Assistant Public Defender Scott Sanders uncovered that secret informants operated for at least 25 years. Goethals concluded that OCSD and OCDA intentionally lied and willfully withheld exculpatory information in criminal cases. [See: CLN, Mar. 2019, p.1.]

Not only are the incentives for jailhouse snitches to manufacture false testimony powerful, but also, the difficulty of doing so is minimal. To generate a credible confession, jailhouse snitches only need to learn basic details about a fellow prisoner’s case. Snitches need to speak with complicit friends and relatives who are able to monitor case proceedings and details from outside of jail. Additionally, given the pervasiveness of the internet, snitches can easily fabricate secondary confessions based upon extensive and detailed case specifics.

According to court documents, Senior Assistant OCDA Ebrahim Baytieh, who allegedly withheld evidence in a murder case and caused it to unravel, also hid evidence and informants more times than had already been known. Paul Gentle Smith was convicted in 2010 of stabbing his roommate to death in 1988. The case against Smith relied on testimony from jailhouse snitch Art Palacios. Baytieh had actually used two more snitches — Paul Martin and Jeff Platt — but their existence was withheld from the defense for nine years. OCDA Todd Spitzer requested Smith’s conviction be overturned because deputies refused to testify at a hearing into misconduct with Baytieh’s jailhouse informants.

Though it’s been about eight years since the Orange County snitch scandal broke, it continues to impact important cases. According to one lawsuit filed by the ACLU against the OCDA and OCSD, at least 140 cases were tainted.

Stephen “The Rifleman” Flemmi became an FBI informant in the 1970s and remained one until he was indicted with fellow mobster James “Whitey” Bulger. Flemmi cut a deal with the government that spared him the death penalty for his role in murders in Massachusetts, Florida, and Oklahoma. The longtime FBI informant described the slayings while testifying against his partners in crime, Bulger, and a corrupt FBI agent, John C. Connolly Jr. Connolly, who was sentenced to a 40-year sentence for helping Flemmi and Bulger orchestrate a murder to prevent them from being implicated in the slaying of three other men, was granted conditional medical release by the BOP in February 2021. Prosecutors did not oppose Connolly’s release after doctors said he was suffering from cancer and diabetes and would likely die within a year. They did, however, oppose a similar request for the release of Flemmi.

Critics argue if prosecutors and police are willing to lie about informants, how can their informant be believed?

Informants Interfering
With Free Speech

Unknown to his fellow insurrectionists at the U.S. Capitol on January 6, 2021, Enrique Tarrio, the chairman of the Proud Boys, one of the country’s most notorious far-right nationalist groups, has a history of being a cooperating snitch.

Court records reveal Tarrio helped authorities go after more than a dozen defendants a decade ago, according to a former prosecutor and a transcript of a 2014 federal court proceeding obtained by Reuters. The former prosecutor, Vanessa Singh Johannes, said Tarrio “cooperated with local and federal law enforcement, to aid in the prosecution of those running other, separate criminal enterprises.”

Tarrio climbed the ranks of the Proud Boys to become one of its top Grand Poobahs, claiming the election of President Biden was fraudulent. Tarrio apparently was no stranger himself to committing fraud. He has a criminal history reaching back nearly 20 years. Between 2004 and 2012, he has been investigated and prosecuted for crimes including fraud in connection with a scheme to sell loads of diabetes test kits, an illegal gambling business, a marijuana grow lab, an operation that sold anabolic steroids, an immigrant smuggling ring, and stealing a $50,000 motorcycle.

Suffering from selective amnesia, Tarrio denies he ever worked undercover or cooperated with law enforcement. “I don’t recall any of this,” Tarrio told Reuters. However, in July 2014, Jeffrey Feiler, his attorney at the time, went to court to ask a federal judge to reduce Tarrio’s sentence, arguing that he had cooperated “in a significant way” in two other federal cases, leading to the prosecution of 13 people. “Frankly, in all the years, which is now more than 30 that I’ve been doing this,” Feiler said at the hearing, “I’ve never had a client as prolific in terms of cooperating in any respect.”

After his stint as an informant, Tarrio is now under scrutiny for his role in encouraging the Proud Boys to attend a “Stop the Steal” rally in Washington that led to the January 6 insurrection. It is unknown if he will act as an informant for an insurrection he reportedly helped instigate.

In July 2020, the New York Police Department (“NYPD”) sent a paid informant to befriend, surveil, and ultimately drive Jeremy Trapp, a Black Lives Matter (“BLM”) activist, to sabotage a police van. The informant picked up Trapp and drove him to an unattended NYPD van. Trapp allegedly cut the brake lines while the informant acted as a “look out.” The informant then drove Trapp to City Hall where police were waiting to arrest him on charges of reckless endangerment and criminal mischief.

Of course, Trapp never would have been arrested and the police van never would have been sabotaged had the paid informant not driven Trapp there in the first place. However, by allowing informants to facilitate crimes, the police can then use those incidents to claim protesters are violent or “gang” related — especially if the protests involve criticism of the police themselves.

In 2020, court records revealed an informant, identified by the pseudonym “John Smith” was paid $1,000 plus expenses in the month he helped the FBI infiltrate the local Las Vegas “Boogaloo Bois” group, a right­wing group. Andrew Lynam, Stephen Parshall, and William Loomis were accused of plotting to incite violence at a BLM protest and to set off bombs at a Lake Mead power substation and a nearby U.S. ranger station. “Smith” said he went with the three to scout the sites and discuss the planned fire bombings.

In 2021, the Maricopa County District Attorney’s office (“MCDA”) admitted they used at least two paid informants to infiltrate, take photographs, and trail protesters gathered on the one-year anniversary of George Floyd’s death. Phoenix cops charged 17 people at an October 2020 protest with “gang activity” based primarily on the word of informant Riley Behrens, one of the defendants in the case.

MCDA has since admitted its case against protesters accused of being a criminal street gang was “deeply flawed.” The case became marred by revelations of the MCDA allowing misleading testimony to a grand jury, prosecutors with potential conflicts, and an unreliable informant. Advocates and their attorneys contend it’s an example of political prosecution and that the case illustrates the office’s practice of systemic racism. Phoenix police tried to use “street gang” charges against protestors caught by Behrens, which would carry greater punishment.

Ryan Green, the MCDA training and post-conviction division chief, told local police that Behrens claimed “this group just got classified as a gang” and that “everybody that I just named got matching gang tattoos three weeks ago.” The MCDA admitted Behrens, a former police informant, had a “troubling history of lying to police.” Behrens told police there was a group of 30 to 40 people and 20 or 25 got tattoos that said “ACAB” (“All Cops Are Bastards”) in braille. “This interview with Behrens appears to be the genesis of the belief that a group of protesters were behaving as a criminal street gang,” Green wrote. None of it turned out to be true.

During grand jury testimony, Phoenix Sgt. Doug McBride said the so-called “gang” wore all black and carried umbrellas. Protesters across the country have worn the color black. It is also common for protesters to carry umbrellas to protect themselves from the sun, tear gas, and to obscure their identities to prevent retaliation by cops.

“The idea that this group was a ‘gang’ was not ‘invented’ by law enforcement as alleged by the defense,” Green wrote. “Rather, it was raised by one of the defendants, Riley Behrens.” Law enforcement just ran with the invention to seek tougher penalties against protesters.

The Police Department in Gilbert, a Phoenix suburb, shared the information with other law enforcement agencies that relied on Behrens’ false information in other protests across the U.S.

In Portland, Oregon, police also relied on an unnamed informant to help identify suspects in civil rights protests in 2021. Portland police declared a riot after demonstrators threw fireworks and set a fire at the Portland Police Association building. Officers arrested one person, 19-year-old Alma Raven-Guido. Court records later revealed an unnamed informant within the crowd allegedly identified Raven-Guido.

Critics fear that this type of informant police surveillance poses issues for free speech and also exposes protesters to false allegations and misidentification by informants who might hold hidden motives against protesters (e.g., informants like Tarrio). “I think it has a potential chilling impact on First Amendment speech,” said J. Ashlee Albies, a civil rights attorney in Portland.

Critics also point out that police don’t need to enlist informants for protests when they have admitted to having other methods at their disposal. For example, Portland police have relied on plainclothes FBI agents to infiltrate and monitor demonstrations in Portland rather than paid informants. In October 2021, prosecutors said FBI agents wearing plain clothes in a protest crowd watched a man use a metal baton to smash out the windows of the Oregon Historical Society, Portland State University, and other businesses.

Making a Living Off Snitching

Ever since Judas received 30 pieces of silver to turn in his friend Jesus, the power of the coin has continued to be a strong motivator for informants to provide information to authorities, even when it is false. Oftentimes, the only way informants stay on the payroll is turning over suspects, so they have an incentive to create crime. They’re working for money, not justice.

Some informants have turned themselves into millionaires on the government’s dime. In Florida, a 2016 investigation by the Sun Sentinel revealed one unnamed informant who worked as a snitch for 31 years was paid nearly $1.5 million for his efforts.

In 1984, Andrew Chambers was a high school dropout who began working as an informant for the DEA. Over a period of 16 years, he set up more than 300 people in over 100 state and federal cases and earned as much as $4 million.

While the DEA was paying him to be an informant, Chambers was also cheating the same government. He failed to pay more than $100,000 in taxes to the IRS on the income he made as an informant. At least three federal courts have called Chambers a liar, and his false testimony has resulted in dozens of convictions being reversed. While prosecutors describe him as a “flimflam” man, they continued to use him in prosecutions.

In 1995, a federal judge in Colorado dismissed charges against ten defendants after criticizing the government’s contingency fee arrangement with Chambers. He was paid based upon the number of drug dealers he set up and the amount of property the defendants forfeited.

Prisoners can get in on the lucrative business of snitching also. Mexican Mafia members Raymond “Puppet” Cuevas and Jose “Bouncer” Paredes, a pair of jailhouse snitches, were paid $335,000, cartons of Marlboro cigarettes, fastfood, Xbox consoles, and other incentives over a four-year period in exchange for working dozens of cases for law enforcement in Orange County, Riverside County, San Bernardino County, Long Beach, and Los Angeles County.

In 2017, Candy Myers was swept up in a Tennessee drug bust in which Tina Prater, 47, later admitted she framed Myers and at least 20 other people while working as a confidential informant for Chief Charlie Wilder of the Tracy City Police Department. Prater recruited imposters to act as other people on recorded audio of purported drug deals and turned the tapes over to Wilder. As a consequence, innocent people like Myers were framed for crimes that never occurred. Prater had signed an agreement to work as a confidential informant for Wilder. As part of the deal, Prater would hand over the tape recorder along with the pills she claimed to have bought, and Wilder paid her $30–$40 per transaction.

In 2020, the New York City Council wanted to introduce a bill that would make it a finable offense to park in a bike lane, bus lane, or crosswalk, and awarded anyone who snitched on illegal parking a quarter of the fine. The NYC Department of Environmental Protection also allows people to snitch on a truck or bus if it sits idling. Snitches can file a complaint and then get 25% of the penalty: that comes to $87.50 of the $350 fine. In 2020, the city fielded 2,000 complaints and paid $175,000 in “rewards.”

In Texas, Republicans introduced SB 8, which allows anyone to become an “abortion snitch” by filing a lawsuit for $10,000 against a person they suspect is going to either provide an abortion or help a person obtain an abortion past six weeks’ gestation.

An audit released by the Department of Justice (“DOJ”) revealed that between 2010 and 2015, the DEA boasted more than “18,000 active confidential sources assigned to its domestic offices, with over 9,000 of those sources receiving approximately $237 million in payments for information or services they provided.” By comparison, the FBI is said to maintain a roster of some 15,000 informants.

The audit also describes tens of millions of dollars paid to hundreds of sources whose status was “deactivated” by the DEA, meaning their relationship to law enforcement was meant to be cut off because they had an arrest warrant or had committed a crime. In one case, a source who was deactivated for providing false testimony in trials and depositions was reactivated by senior DEA officials, earning more than $400,000 over five years before being terminated again for providing false statements to a prosecutor.

The audits also revealed many of the informants were government employees double dipping as “tipsters” and received an average of $56,000. They included 33 Amtrak employees who collected a total of $1.4 million. They provided information that Amtrak says the DEA could have demanded for free.

The government has no problem paying for bad information. For example, the FBI paid over a million dollars to Emad Salem for his testimony in a terrorism trial regarding a plot to bomb the United Nations – in which he admitted he lied about his exploits.

Police and Informants
Framing Suspects

One of the first people enrolled in the FBI witness protection program, Joseph “the Animal” Barboza, was an informant who avoided prosecution by falsely fingering four other men who were convicted for his crimes.

Many jurisdictions permit drug dealers to continue selling drugs in exchange for cooperation. According to one study in 2011, the crimes committed by FBI informants alone totaled over 5,600.

Darryl Moore was a prolific snitch with a history as a hit man, drug pusher, robber, rapist, junkie, parole violator, and perjurer whose own mother took the stand as a defense witness after he testified for the prosecution. Knowing all that, Illinois DA Richard M. Daley entered into a pact with the devil. In exchange for Moore’s testimony concerning an alleged contract murder, he would be paid cash; weapons and drug charges pending against him would be dropped; he would be immunized from prosecution for a contract murder he admitted taking part in; and he would be turned loose on the streets of Chicago. In exchange for that sweet deal, Moore left the prison a free man and promptly dragged an 11-year-old girl into an alley and brutally raped her. [See: CLN, Mar. 2019, p.1.]

Sam Adam, an attorney for one of the defendants Moore testified against, bluntly stated: “Richard Daley is, in my opinion, as guilty, morally, as Darryl Moore of the rape of that child, perhaps more so because he, unlike Moore, is presumed to be a moral, decent man of intelligence.”

Moore later confessed he made up his testimony and knew nothing of the crimes he got a deal for.

In October 2001, Detective Dale Hundley fabricated an informant and a report to get a judge to issue a warrant against Ann Colomb and her two boys, Edward and Danny, accusing them of selling crack cocaine from their mother’s home. According to Hundley, he equipped the informant with a transmitter concealed inside a pack of cigarettes, gave him $50 in photocopied buy-money, and sent him to the Colomb home. The drug raid that followed turned up a paltry 74 grams of crack cocaine, $160 in cash, and a handgun tucked inside a family room dresser. The investigation, however, turned into a multi-year fiasco in which government informants struck deals for time cuts and special favors for crimes that never occurred.

U.S. Attorney Brett Grayson drummed up federal charges based on a parade of informants giving false information to bolster his case. Grayson and his investigator, Jerry Stutes, looking for snitches, headed to federal prison to talk to Dexter Harmon, a notorious street hustler. Harmon had been sent to prison on the strength of snitch testimony. He quickly learned to work the snitch game to his own advantage. Eventually, he would shave a multi-decade, no parole sentence down to a mere six years. Ann Colomb and her boys were Dexter’s ticket to freedom.

The snitch parade began once the Colomb name entered the federal prison grapevine. Prisoners over 700 miles away were informing on the Colombs. By the time the case went to trial in 2006, Grayson had assembled 32 jailhouse informants. Before long, Danny and Edward Colomb had been tied to 250 kilos of crack cocaine with a street value of $65 million. There were no phone logs, no money wires, and no clear connection between the informants and Danny and Edward, who Grayson claimed were selling millions of dollars of crack every week.

Midway through the trial, a bombshell broke when wannabe jailhouse snitch Quinn Alex said he had paid $2,200 to one of Grayson’s lead snitches in exchange for information that should have allowed him to testify against the Colombs in exchange for a time cut. When Alex got nothing in exchange for his investment, he wrote the judge to snitch on the snitches. Unlike Harmon and the other snitches, Alex had Western Union records to back up his story.

Alex’s letter mentioned several of the witnesses on Grayson’s list by name. Another snitch identified only as “John Doe” made similar allegations against Greyson’s key tellers, asserting that he had personally witnessed Harmon, Marcus Ledet, Cleveland Benoit, and three other snitches conducting a “perjury party” where they shared information provided by the prosecution and coached one another on what to say, and how to say it, as they sat behind bars.

Grayson eventually dropped all charges against Ann and her sons. By then, however, their lives and reputations had been destroyed.

Another notorious informant, Paul Skalnik, has been called one of the most prolific “serial informants” in American history. “I have placed 34 individuals in prison, including four on death row,” he boasted in a 1984 letter to Senator Lawton Chiles of Florida, in a request for favorable treatment. Between 1981 and 1987, Skalnik testified or supplied information in at least 37 cases in one county alone. Eighteen defendants whose cases Skalnik provided information on were under indictment for murder. Four were sentenced to death. Turns out Skalnik was a fat-mouthed liar.

After testifying in one case, Skalnik was released from custody. According to a Florida Parole and Probation Commission memo, his release was “due to his cooperation with the State Attorney’s Office in the first-degree murder trial.” A year earlier, his parole officer had warned the Commission, “This man has been, is, and always will be a danger to society.” Skalnick was able to dodge everything from molesting children to fraud charges in exchange for his services.

Skalnik was charged with “lewd and lascivious conduct on a child under 14,” a felony punishable by up to 15 years in prison.  He was able to get the molestation charge dismissed in return for a new charge of grand theft, for which he had been arrested the previous year. Prosecutors later gave up efforts to extradite him from Texas in 1991, leaving him free to sexually abuse another child. He was never prosecuted for either crime. Ultimately, his status as an informant helped him avoid harsh penalties for a series of cons he played on multiple women.

After decades of snitching, a prosecutor in Texas declined to offer a deal to Skalnik in another case. In retaliation, he turned his snitching skills on the prosecution. Skalnik filed a motion with the trial court in which he claimed prosecutors had coached him on how to testify in cases to give jurors the false impression that he “had actually heard all these ‘confessions’ and had no agreement with the state for a reward for his testimony.” Prosecutors “knew of the potential questionability of said confessions,” the motion said. Skalnik provided the names of 11 prosecutors whom he accused of misconduct. He claimed to have given information or testimony in more than 50 cases and said much of that evidence was tainted.

The Chicago Tribune raised an alarm in 1999, when it highlighted prosecutors’ over reliance on jailhouse informants in death-penalty cases in Illinois and found that such testimony had helped convict four of the state’s 12 death-row exonerees. In the aftermath of the report, which identified numerous problems with the death penalty in Illinois, Gov. George Ryan declared a statewide moratorium on executions.

Accomplice Informants

John H. Walker Jr. and Darryl A. Boyd, two Buffalo men who served more than two decades in prison for a murder they were wrongly convicted of 44 years ago, had their convictions vacated when false jailhouse snitch testimony unraveled. Buffalo police alleged that four teenagers followed William Crawford to his Fillmore Avenue home on a snowy night in January 1976 and robbed and killed him. A fifth teen, also an alleged accomplice, was given immunity in exchange for his testimony against the others.

The overall case against the teens in 1977 wasn’t strong because it relied on a jailhouse snitch and on a suspected accomplice, who later refused to even cooperate with the prosecutors. Three of the teens were convicted in separate trials in 1977 — Boyd, Walker, and the late Darryn Gibson. The fourth teenager, Floyd Martin, was acquitted. Martin’s defense lawyer was James A. W. McLeod, who later retired as a City Court judge. McLeod recalled a crime scene photograph showing only one set of footprints following Crawford to the crime scene, and they were likely the footprints of a single person, not a group of teens.

In another case, Ramon Ward spent 25 years in prison before he was exonerated for the murders of two women committed by another man. Ward, an 18-year-old Black man, was arrested three months after the murders. There was no warrant, no eyewitnesses, and no physical evidence that implicated Ward.

Monica Childs, an investigator with Detroit’s Squad 7 homicide division, questioned Ward about the murders. Ward signed a statement denying that he had killed the women, but Childs locked him up anyway, where two snitches, Joe Twilley and Oliver Cowan, were waiting, saying they had heard Ward confess to the murders.

“I think there are six people at this point incarcerated for murder that probably would not be without Mr. Cowan’s help,” an officer testified at Ward’s trial.

Cowan, a repeat offender facing up to 15 years in prison, testified that he heard Ward confess. He also testified that he had helped police as an informant “in only a couple of cases” and hadn’t received favors in exchange. A few months later, though, his lawyer and a police officer spoke privately to the judge just before Cowan’s sentencing, which led the judge to consider moving the hearing “away from the prying eyes of the public,” according to the court transcript. Cowan’s sentence was reduced to one year in a detention facility and one year of probation, so long as he continued to cooperate with the police.

Like Cowan, Twilley was serving a 12 to 25-year sentence for second-degree murder when he was placed in the ninth-floor lockup. Officers asked the prosecutor’s office to petition for a reduced sentence for Twilley, but after they refused, the officers sidestepped prosecutors and appealed directly to the judge. Their request led to a hearing that was, as the judge described it in a court transcript, “a suppressed hearing.” The judge continued, “I don’t want this transcript released to anybody.”

One of the officers who approached the judge to advocate for Joe Twilley’s reduced sentence later went to prison for perjury in the case of a Detroit teenager who was exonerated in 2016 for a quadruple murder he did not commit.

In 1995, a jury convicted Ward of two counts of murder. The case hinged on Twilley and Cowan’s testimony, plus that of Childs, who ordered Ward’s arrest. Childs testified that Ward’s cousin, who had identified him as the killer, had been a suspect himself. At trial, however, he recanted all statements implicating Ward. Ward was exonerated only after Twilley and Cowan’s lies were exposed – but not before spending most of his life in prison.

According to court records, Twilley helped detectives on at least 20 cases, some of which were homicides. One has to wonder how many more innocent people are in prison because of Twilley and Cowan.

Questions about police and prosecutor conduct prompted the formation of the Wayne County Conviction Integrity Unit (“CIU”) in January 2018 after the prosecutor’s office faced a number of cases that further threatened its credibility. These included the discovery of 11,341 untested rape kits at a police warehouse in 2009. The kits were found while prosecutors were reviewing problems with ballistics testing at Detroit’s shaky crime lab, which had closed permanently a year earlier. The illegal tactics of Detroit’s police department were put under federal oversight from 2003 to 2016.

Monica Childs, the Squad 7 officer who questioned Ward, later became a whistleblower on the use of informants.

Laurence Adams was sentenced to death and spent 30 years wrongfully imprisoned for the 1974 murder of a Boston transit worker. His conviction was based on the false testimony of two informants who claimed that Laurence confessed to them. Massachusetts prosecutors failed to disclose that both informants had their criminal charges dismissed or reduced in exchange for their testimony. Years later, this critical evidence emerged, and there was evidence that both informants had lied. Adams was exonerated in 2004 and won a federal civil rights lawsuit against the city of Boston for $2.1 million and received $325,000 in state compensation.

Informants Becoming Victims

While using incentivized informants can produce bad evidence and wrongful convictions, the snitching phenomenon is problematic in other, more complex ways. Informants themselves are often vulnerable people who may be young, undereducated, and suffering from substance abuse or mental disabilities. When police pressure such suspects to cooperate, many people feel as if they have no choice, even if cooperating is not in their best interests.

Police often also use children as young as 14 as informants. As informants, they are exposed to drugs, violence, and other criminal activities as they work to get information for their “handlers.” Some informants have been killed because of police and prosecutor negligence, which has prompted California, Florida, and New Jersey to pass laws restricting the practice.

Nick Taiber, former City Council member in Cedar Falls, Iowa, was forced to become an undercover drug informant when he was a teenager after getting into a drunk driving accident after a teen drinking party. As it was presented to Taiber, he would face jail time and a serious fine, or he could work toward a deferred sentence that would never appear on his record if he agreed to act as an informant in a drug case.

In Taiber’s case, there wasn’t even a drug-dealing ring. The police wanted to target a local stoner who happened to be a friend of Taiber’s brother. He agreed and was given a deferred sentence, while the stoner was busted with a small amount of marijuana. Not everyone’s case has ended so well. There have been a series of botched informant operations that have ended in far more devastating consequences.

The government has forced women to perform sex acts as informants. In Alexander v. DeAngelo, 329 F.3d 912 (7th Cir. 2003), the U.S. Court of Appeals for the Seventh Circuit ruled that the government could legally pressure an informant to pose as a prostitute and to have oral sex with another suspect in exchange for dropping drug charges.

In 2008, Rachel Hoffman, a college student in Tallahassee, Florida, was arrested with a small amount of marijuana and ecstasy pills. She was threatened with serious charges if she didn’t agree to cooperate. In exchange for leniency, she agreed to do a $13,000 drug and gun deal in a sting operation set up by the police. The police lost track of her, and she was brutally murdered by the dealers.

Rachel’s parents fought to have “Rachel’s Law” passed in her name to create guidelines governing the process of creating informants and, in particular, to consider a suspect’s youth and inexperience, as well as the level of danger they might face, before making an informant deal.

In response to the 1998 murder of teenager Chad MacDonald, the California State Legislature similarly passed a bill known as “Chad’s Law” that places limits on the way law enforcement uses minors as informants.

MacDonald, 17, had been arrested in January on a small possession charge and wore a wire as part of a deal to have the charges dropped. Two months later, he was beaten and strangled, and his 15-year-old girlfriend raped, beaten, and left for dead.

In 2015, Andrew Sadek, a 20-year-old student at North Dakota State College of Science, was threatened with 40 years in prison after he was busted with almost $80 worth of pot. Sadek himself was snared by an informant who bought marijuana from him. Understandably scared, he agreed to do to others what had been done to him, buying marijuana from other students.

Andrew disappeared and was found in a river with a gunshot wound to the head and a backpack filled with rocks. Andrew’s parents say he was murdered. The police say it was a suicide — Andrew’s way of trying to get out of his informant deal.

The police required Sadek to purchase drugs five times “to fulfill his obligation in resolving the charges he had been facing.” After the third buy, Sadek stopped communicating with his handler and went missing. A missing person report was filed by his family. The police made no effort to find him — instead they charged him with two felonies and a misdemeanor. A week after he was reported missing, his body was found.

In 2019, John and Denise Klaus fought to pass “Matthew’s Law” after their 32-year-old son Matthew died of a drug overdose while working as a confidential informant for Rochester police in Minnesota.

Matthew was a recovering heroin and alcohol addict who had relapsed when he was hired by police — in violation of their own policy requiring them to ask the county corrections office for approval while he was on probation – to purchase heroin for two cases. The dealer sold Matthew the fatal dose.

The dealer, Michelle A. Williams, was arrested after Matthew died and later pleaded guilty to third-degree murder; she was sentenced to a little less than nine years in prison. None of the police who hired a known heroin addict in violation of established policy faced charges for leading him to Williams in the first place.

Even if family members do receive justice for their loved ones killed while acting as informants, that justice can be ripped away from them.

In February 2004, Anthony Velez was murdered shortly after Sgt. Michael Ruggiero and Officer Rudolph Hall recovered a gun and crack cocaine inside an apartment based on a tip from Velez. Someone blew Velez’s cover, but both Ruggiero and Hall insisted it wasn’t them.

Velez’s family sued, and after deliberating for four hours, the jury awarded Velez’s mother, Towanda Velez, $1 million in damages and $4,000 for his funeral. Judge Eric Vitaliano didn’t like the decision and directed the jurors to return to deliberations where they reached a second verdict that awarded no damages.

Racial Bias

Prosecutors and police have bad reputations in communities of color for racial bias, corruption, and mishandling of cases, which has created salient dividing lines and inequalities in the system.

In 2017, Multnomah County prosecutors in Oregon indicted Rashad Banks and two codefendants for an alleged gang retaliation shooting of Cherie Thompson and a 9-year-old child in their apartment. Also in the apartment at the time of the shooting was Ervan Herring.

All three were tried at the same time in a bench trial. Both Thompson and Herring testified they could not identify the “shooters.” No other evidence linked any of the defendants to the crime.

However, while Banks’ codefendants were acquitted, Banks was convicted of attempted first-degree murder with a firearm and first-degree assault with a firearm. The difference was caused by the testimony of Randy Bunch, who slept next to Banks in the Inverness Jail in 2018.

Bunch had a lengthy history of convictions (possession of meth, theft, taking a motor vehicle without permission, failure to report as a sex offender, burglary, felon in possession of stolen property, attempt to elude, and domestic violence), and at the time he shared the cell with Banks, he was facing charges for kidnapping, attempted rape, robbery, and burglary.

According to court records, Bunch, who is white (whereas Banks is Black), admitted on the stand to using the “n-word” “probably … a million times.” He also agreed that he volunteered information about Banks so that he could “get a better deal” on his sentence. In fact, he got a better deal. Instead of facing trial and, potentially, the equivalent of a life sentence, he was allowed to plead guilty to just the burglary and robbery and thus limit his sentence to 100 months, with 40 months suspended.

At Banks’ trial, Judge Benjamin Souede admitted, “[t]he only evidence in this case that relates to [Banks] and to the site of the shooting at the time of the shooting, comes [from] the testimony of Randy Bunch.” Despite that finding, Souede found Banks guilty and sentenced him to a mandatory minimum of 90 months in prison.

In 1998, Donna Brown was shot and killed in a Taco Bell parking lot. Devonia Inman, a Black teen with a history of run-ins with the police, was immediately targeted for the murder. There was no real evidence linking him to the murder.

Police apparently targeted Inman in a mix of racial profiling and because Inman surrounded himself with the wrong kind of people. After his arrest, a newspaper carrier came forward to finger Inman as the murderer, but her testimony changed. And she later recanted her statement. Similarly, a jailhouse snitch contacted law enforcement to say Inman had confessed in prison, but again, he, too, later recanted. Inman always maintained his innocence.

After Inman’s arrest, Caroll Bennet, a local grocer, and his employee Rebecca Browning were found murdered. Hercules Brown was arrested and later pleaded guilty to their murders to avoid the death penalty.

In a twist of events, Hercules Brown worked at the very same Taco Bell as Donna Brown. A break in the case came when the police returned Donna’s car to her family, and they found a ski mask inside that the police had overlooked. Since the ski mask was never tested, the Georgia Innocence Project was able to have it tested for DNA. It was linked to Hercules Brown.

In 2002, no one disputed that informant Derrick Megress, who claimed he bought drugs from 28 Black people in the community of Hearne, Texas, was a liar. Robertson County District Attorney John Paschall was forced to admit Megress stole some of the cocaine he was supposed to turn over to police as evidence, masking the thefts with flour. Megress also probably pocketed some of the money he was supposed to use to buy drugs, Paschall said.

The investigation that culminated with the arrests of 28 people on felony charges of possessing or distributing crack cocaine began when Megress, who was in the Robertson County jail, after being accused of burglarizing a home, wrote the drug task force and said he could help them with an investigation in exchange for leniency in his case. Paschall offered Megress a sentence of probation on the burglary charge if Megress gathered evidence for drug cases against 20 people.

Problems with the case became apparent when one man, Corvian Workman, took his case to trial. The tape Megress made of an alleged drug buy with Workman was unintelligible. The jury that heard the evidence against Workman could not reach a verdict. “I’ve been prosecuting long enough to know if the jury is hung up 11–1 for acquittal you’ve got a problem,” Paschall said.

Paschall interviewed jurors after the case. They told him they didn’t believe Megress. After the trial, Paschall asked Megress to take a polygraph test in which he was asked whether he stole drugs or money. Megress failed. Paschall dismissed the cases against 17 defendants. Three others had already taken plea bargains to avoid harsher charges.

The ACLU compares the Hearne bust to the now-infamous 1999 drug sting in the panhandle community of Tulia, Texas, where a white undercover police officer targeted the town’s small Black population. In a town of 4,600, the Tulia drug sweep netted 46 arrests, almost all of them Black, even though Black residents made up just 5% of the town’s population. That investigation has since been discredited.

In another case, Curtis Flowers was employed at a furniture store in Winona, Mississippi, in 1996 when the owner of the store and three employees were found murdered. He was convicted of the crime based on a supposed confession he made to two jailhouse snitches. Flowers was tried for the crime six times, and the case was overturned based on racial bias in jury selection. The snitches later admitted they had lied, having been fed details of the crime by prosecutor Doug Evans. After that, Evans gave up, the state Attorney General declined to prosecute again, and charges against Flowers were eventually dropped in 2019. He is now suing Evans for misconduct.

Facts and Figures

A 2005 study by the Center for Wrongful Convictions at Northwestern School of Law examined 111 cases in which the defendants were exonerated from death row. The study found that in 51 of those cases, the defendants were wrongfully sentenced to death based, at least in part, on the testimony of witnesses with incentives to lie.

Families Against Mandatory Minimums noted in 2010 that the threat of mandatory minimum sentences coerced 25% of defendants to cooperate with law enforcement in hopes of persuading the government to file a motion for a sentence below the mandatory minimum, since only a motion by the government can get around a mandatory minimum sentence.

A 2014 Northwestern University study found that almost half of the wrongful convictions in death penalty cases were based on false testimony of informants, making snitches the leading cause of wrongful convictions in capital cases.

The National Registry of Exonerations, founded in 2012, lists 2,842 exonerations across the country since 1989, an average of 88 a year. By 2016, it found that 81 of 116 death penalty exonerations involved perjury or false testimony by incentivized witnesses — an increase of up to 70%. Barry Scheck’s Innocence Project found that 25% of DNA exonerations involved the knowing use of false incentivized witness testimony, and 11% involved the use of coerced witness testimony. [See: CLN, Mar. 2019, p.1.]

At the federal level, the U.S. Sentencing Commission reported that in 2017, 26.2% of all federal defendants received a “substantial assistance” departure.

Studies on Incentivized Witnesses

Numerous studies have been conducted on incentivized witnesses, including their effect on wrongful convictions, why they decide to cooperate with the government, and what it takes to persuade someone to become an incentivized witness. They have identified eyewitness misidentification, flawed forensic science, false informant testimony, and false confessions as the four categories of evidence most frequently associated with wrongful convictions.

Rob Warden, a leading scholar, cited informants as “the leading cause of wrongful convictions in U.S. capital cases.” His analysis revealed that informants contributed in 46% of the 111 death row cases resulting in exonerations between 1973 and 2004.

In August 2007, Professor Richard Moran penned a New York Times op-ed in which he stated that a study of 124 exonerations of death row prisoners between 1973 and 2007 showed 80 — two thirds — resulted not from good-faith mistakes or errors but “from intentional, willful, malicious prosecutions.”

“Yet too often this behavior is not singled out and identified for what it is,” Moran wrote. “When a prosecutor puts a witness on the stand whom he knows to be lying, or fails to turn over evidence favorable to the defense, or when a police officer manufactures or destroys evidence to further the likelihood of a conviction, then it is deceptive to term these conscious violations of law … merely mistakes.”

Researchers at the University of Arkansas in 2009 found that an offer to students to get out of having to complete another assignment resulted in about one-third of them providing false testimony against someone, even when they were told that the person had not committed the offense.

In a 2017 study led by University of Arizona law professor Christopher Robertson, two experiments conducted on hundreds of people showed that 20% of one group would lie as a witness for the government in a case against someone else to obtain leniency for an unrelated offense, and 55% in another study group would lie against one of their codefendants in order to get leniency.

Of the 2,130 exonerations registered by the University of Michigan, 1,205 involved perjury or false accusations. Researchers at the Bluhm Legal Clinic at Northwest University School of Law said studies show many informants lack confidence in themselves, crave attention, and have a need to feel important. [See: CLN, Mar. 2019, p.1.]

The cases and studies mentioned above illustrate how the use of informants distorts and undermines the legitimacy of the criminal justice process. This unchecked authority has created an enormous market for information and cooperation in the criminal process. Everyone involved in the system understands that cooperation is a way of working off sentences. This awareness affects the behavior of every player at every stage of the process.

Despite the fact that every stakeholder within the criminal justice system — especially police, prosecutors, and judges — is keenly aware of the perverse motivation for snitches to provide compelling testimony against others, regardless of its veracity, police and prosecutors nevertheless are often all too eager to suspend their disbelief and take the word of their incentivized snitches at face value to rack up convictions. Maddeningly, police, prosecutors, and snitches are rarely ever held accountable when false and incentivized testimony leads to the wrongful conviction of the innocent. 

Sources: Dale Chappell, Government Snitches: Incentivized Witnesses Are the Leading Cause of Wrongful Convictions, Criminal Legal News, (March 2019);Richard Moran, The Presence of Malice, New York Times, (August 2, 2007); R. Michael Cassidy Professor, Boston College Law School, “Soft Words of Hope”: Giglio, Accomplice Witnesses, and the Problem of Implied Inducements (2004); Christopher T. Robertson and D. Alex Winkelman, Incentives, Lies, and Disclosures; James C. McKinley, Jr., Key Witness in Bomb-Plot Trial Admits Lying about His Exploits, NY Times (Mar. 8, 1995); Univ. Cal. Irvine Newkirk Ctr. For Sci. & Soc’y, Mich. State Univ. Coll. Of L. & Univ. Of Mich. L. Sch. & The National Registry Of Exonerations; Melanie B. Fessinger, Brian H. Bornstein, Jeffrey S. Neuschatz, Danielle Deloach, Megan A. Hillgartner, Stacy A. Wetmore, And Amy Bradfield Douglass, Informants v. Innocents: Informant Testimony And Its Contribution To Wrongful Convictions, Capital University Law Review (2020); slate.com, bostonglobe.com, courses2.cit.comell.edu, oyez.org, sgp.fas.org, theintercept.com, stltoday.com, sun-sentinel.com, ocregister.com, rewirenewsgroup.com, actionnewsjax.com, snitching.org, govinfo.gov, nytimes.com, newrepublic.com, latimes.com, buffalonews.com

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