Confession Isn’t Conviction: How Minnesota Codified Corpus Delicti

The Corpus Delicti doctrine has been foundational in Minnesota for over one hundred years. Codified in 1851, it remains an unmoving ideology that protects defendants from convictions based on uncorroborated or coerced confessions. Corpus Delicti, which translates to “the body of the crime,” is a legal doctrine that requires proof of a crime’s occurrence before a defendant can be convicted based on their confession or admission. Corpus delicti’s primary purpose is to protect defendants from convictions based solely on uncorroborated or coerced confessions.

Corpus Delicti in Minnesota

Minnesota codified the Corpus Delicti doctrine through Minn. Stat. § 634.03. Through a court decision in State v. Holl. The court interpreted the Corpus Delicti requirement, which requires the state to introduce independent evidence of the defendant’s confession to prove that the crime confessed to occurred. The state must establish an occurrence of the crime before statements and confessions can be used to convict a defendant. From felonies to misdemeanors, in Minnesota, the Corpus Delicti doctrine has protected defendants from convictions based on uncorroborated confessions.

What is Independent Evidence in Minnesota?

In Minnesota, “independent evidence” refers to evidence that is entirely separate from a defendant’s confession or admission. The defendant’s statements should not influence the independent evidence and must be able to corroborate the confession or admission without relying on it.

State v. Holl

In this criminal sexual conduct case, the court ruled that, under Minn. Stat. § 634.03.  The state failed to provide sufficient, reasonable, and independent evidence, apart from the defendant’s confession, to secure a conviction on the specific charges Holl faced. State v. Holl, 966 N.W.2d 803, 814 (Minn. 2021). The court determined that independent evidence must also be specific to the charge and reasonably tend to prove that the specific charge had been committed. If the state cannot provide such evidence, under Minn. Stat. § 634.03. There cannot be a conviction. Id. At 817.

State v. Hill

The court in the present case had to analyze whether an action, along with a confession of the defendant’s mental state at the time of the action, is sufficient to convict. State v. Hill, 10 N.W.3d 317 (Minn. Ct. App. 2024). Hill was charged with first-degree sexual assault for pushing a woman against a closet door and choking her, he admitted to police he did think about raping her, but he did not. Instead, he ran away, but after the incident, he confessed to wanting to rape her, leading to his charge. Id. At 320. Hill appealed, stating that there was no specific independent evidence to prove that he attempted to rape her other than his confession to the police. Id. At 320. While attempted crimes complicate the Doctrine of Corpus Delicti, the court ruled that to fulfill the Doctrine of Corpus Delicti, there must be an intent to commit a crime and a substantial step toward the crime’s commission. Id. At 322. The court determined that there was no independent evidence, separate from Hill’s confession, that he was going to sexually assault the woman, as he did not touch her in any intimate parts and did not say anything to her about sexually assaulting her. Id. At 327. The court ruled that the state did not establish reasonable independent evidence of Hill’s alleged attempt at first-degree sexual assault. Therefore, his conviction of first-degree sexual assault was reversed. Id. At 328.

State v. Sellers

Corpus Delicti also applies to misdemeanors; in 1993, Sellers was charged with keeping ferrets in his home without a permit. State v. Sellers, 507 N.W.2d 235 (Minn. 1993). He did not let animal control into his house to see the ferrets. Id. At 326. The only evidence that the state could provide is that he potentially made a self-incriminating statement about owning ferrets and that he would not let animal control into his house. Id. Therefore, the court ruled in favor of the defendant, stating that the state had not provided sufficient independent evidence to convict Sellers. Id.

Contact a Minnesota Criminal Defense Attorney Today

Corpus Delicti has been an enduring doctrine in Minnesota’s legal framework, ensuring that confessions are not taken at face value and there must be sufficient evidence to establish a crime has occurred. Minnesota court decisions continue to affirm the importance of the doctrine, which serves as a safeguard to ensure that the state provides independent, reasonable evidence against defendants. As a result, Minnesotans do not need to defend themselves against unsubstantiated confessions and omissions. Contact North Star Criminal Defense for more information on your case.