Confessions Must Be Corroborated By Independent Evidence To Prove the Crime
The Minnesota Supreme Court just issued a ruling (State v. Holl, A19-1464) relating to the corpus delicti rule of law, in which a confession to a crime must be accompanied by some other evidence to result in a conviction. The idea is that criminal confessions must be corroborated in order to ensure the confessed-to crime did, in fact, happen. The risk is that criminal confessions could be the byproduct of improper interrogation tactics, otherwise unreliable, and that a resultant conviction could be incorrect. All these issues led to this ruling based on a statute stating that criminal confessions must be corroborated before they can be introduced at trial. But, the question before the Court was what amount of independent evidence is sufficient?
What is the Minnesota Statute Regarding Criminal Confessions?
First, the statute at issue is Minn. Stat. 634.03. It reads:
A confession of the defendant shall not be sufficient to warrant conviction without evidence that the offense charged has been committed; nor can it be given in evidence against the defendant whether made in the course of judicial proceedings or to a private person, when made under the influence of fear produced by threats.
The Court’s Ruling Focused on Evidence That the Crime Was Committed
The Court’s focus was on the phrase regarding “evidence that the offense charged has been committed.” There were two competing approaches in how to interpret this phrase that the Supreme Court ultimately resolved.
First, the traditional approach dates back to the creation of the corpus delicti rule, which is Latin for “the body of the crime.” Under the traditional interpretation, the State is generally required to “introduce evidence independent of an extrajudicial confession to prove that the confessed crime actually occurred.”
But, this traditional rule has been rejected by the Supreme Court of the United States, which has adopted an alternative rule, known as the “trustworthiness standard.” Under this rule, “confessions no longer had to be corroborated by independent evidence, but instead the prosecution is required to produce ‘substantial independent evidence which would tend to establish the trustworthiness of the statement’ or confession… For a confession to be sufficiently corroborated under the trustworthiness standard, ‘the essential facts admitted’ must ‘justify a jury inference of their truth.'”
The Difference Between the Rules According to the Minnesota Supreme Court
The distinction between these two rules is summarized by the Minnesota Supreme Court as follows: “The trustworthiness standard differs from the traditional formulation of the corpus delicti rule by focusing on the content and context of the confession and the facts rather than simply looking to whether there is evidence, completely independent of the confession, showing that the crime was committed.”
With this historical background, the Minnesota Supreme Court then turned to the plain language of the statute. If the language was unambiguous, then it must favor its plain meaning. If not, then the Court had room to interpret what approach it supported. And based upon the plain language, the Court found it was unambiguous and mandated the traditional rule relating to using criminal confessions at trial.
Namely, criminal confessions must be corroborated by independent evidence in order for the defendant to be convicted of the confessed crime. In making this ruling, the Court had to acknowledge its poor handling of this issue in previous cases, which tended to support the trustworthiness standard. But, when confronted with this issue alone, it was required to follow the plain letter of the law, which mandates independent evidence.
So, what does this mean for a defendant? Summarily, the State needs more than just a confession to prove its case. It can rely upon both direct and circumstantial evidence to do so. But there must be some independent evidence to point to beyond defendants’ criminal confessions.
While this issue may not come up in most cases, it absolutely does happen periodically and knowing how to interpret a possible confession and how it plays into the case can lead to greater legal defenses than one might think after having supposedly confessed to the crime. If you have been charged with a crime in Minnesota, North Star Criminal Defense can help evaluate the evidence against you and find the best defense for your specific circumstances.