corpus delicti rule (Virginia) · Go Syfert
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corpus delicti rule in Virginia

5 Virginia opinions name it 2 courts 2011–2025 2 in the last five years

The cases below were cited by Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Watkins v. Commonwealthgreen
va · 1989 · cited in 3 Virginia opinions naming this issue, 2014–2025
2 sentences

2025Under the corpus delicti rule, “an accused cannot be convicted solely on his uncorroborated extrajudicial admission or confession.” Id. (quoting Watkins v. Commonwealth, 238 Va. 341, 348 (1989)).

2019Under the corpus delicti rule, “an accused cannot be convicted solely on his uncorroborated extrajudicial admission or confession.” Id. (quoting Watkins v. Commonwealth, 238 Va. 341, 348 (1989)).

33
Marable v. Commonwealthgreen
vactapp · 1998 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025Although Quiros tried to explain away his confession at trial, the jury “is entitled to disbelieve the self-serving testimony of the accused and to conclude that the accused is lying to conceal his guilt.” Marsh v. Commonwealth, 57 Va. App. 645, 655 (2011) (quoting Marable v. Commonwealth, 27 Va. App. 505, 509-10 (1998)).

11
Marsh v. Commonwealthgreen
vactapp · 2011 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025Although Quiros tried to explain away his confession at trial, the jury “is entitled to disbelieve the self-serving testimony of the accused and to conclude that the accused is lying to conceal his guilt.” Marsh v. Commonwealth, 57 Va. App. 645, 655 (2011) (quoting Marable v. Commonwealth, 27 Va. App. 505, 509-10 (1998)).

11
Brown v. Commonwealthgreen
va · 1892 · cited in 1 Virginia opinions naming this issue, 2014–2014
2 sentences

2014See Brown v. Commonwealth, 89 Va. 379, 382 , 16 S.E. 250, 251 (1892).

2014See Brown v. Commonwealth, 89 Va. 379, 382 , 16 S.E. 250, 251 (1892).

11
Moore v. Commonwealthgreen
va · 1922 · cited in 1 Virginia opinions naming this issue, 2014–2014
2 sentences

2014Moore v. Commonwealth, 132 Va. 741, 745 , 111 S.E. 128, 129 (1922). 4 1.

2014Moore v. Commonwealth, 132 Va. 741, 745 , 111 S.E. 128, 129 (1922). 4 1.

11
Cherrix v. Commonwealthgreen
va · 1999 · cited in 1 Virginia opinions naming this issue, 2014–2014
2 sentences

2014Instead, "slight corroboration of the confession is required to establish corpus delicti beyond a reasonable doubt." Cherrix v. Commonwealth, 257 Va. 292, 305 , 513 S.E.2d 642, 651 (1999) (emphasis added).

2014Instead, "slight corroboration of the confession is required to establish corpus delicti beyond a reasonable doubt." Cherrix v. Commonwealth, 257 Va. 292, 305 , 513 S.E.2d 642, 651 (1999) (emphasis added).

11
Commonwealth v. Kavanaughgreen
pa · 1984 · cited in 1 Virginia opinions naming this issue, 2011–2011
2 sentences

2011It has no application in probation revocation proceedings and a trial court may revoke a defendant's probation based solely on defendant's voluntary confession or reliable extrajudicial admission that he violated the conditions of his probation.”); People v. Monette, 25 Cal.App.4th 1572, 1575 , 31 Cal.Rptr.2d 203 (1994) ("The nature of a probation revocation hearing, however, does not require the application of the corpus delicti rule.”); State v. Sanchez, 109 N.M. 718 , 790 P.2d 515, 517 (N.M.App.1990) (holding “that the corpus delicti rule is inapplicable in probation revocation proceedings,

2011It has no application in probation revocation proceedings and a trial court may revoke a defendant's probation based solely on defendant's voluntary confession or reliable extrajudicial admission that he violated the conditions of his probation.”); People v. Monette, 25 Cal.App.4th 1572, 1575 , 31 Cal.Rptr.2d 203 (1994) ("The nature of a probation revocation hearing, however, does not require the application of the corpus delicti rule.”); State v. Sanchez, 109 N.M. 718 , 790 P.2d 515, 517 (N.M.App.1990) (holding “that the corpus delicti rule is inapplicable in probation revocation proceedings,

11
State v. Sanchezgreen
nmctapp · 1990 · cited in 1 Virginia opinions naming this issue, 2011–2011
2 sentences

2011It has no application in probation revocation proceedings and a trial court may revoke a defendant's probation based solely on defendant's voluntary confession or reliable extrajudicial admission that he violated the conditions of his probation.”); People v. Monette, 25 Cal.App.4th 1572, 1575 , 31 Cal.Rptr.2d 203 (1994) ("The nature of a probation revocation hearing, however, does not require the application of the corpus delicti rule.”); State v. Sanchez, 109 N.M. 718 , 790 P.2d 515, 517 (N.M.App.1990) (holding “that the corpus delicti rule is inapplicable in probation revocation proceedings,

2011It has no application in probation revocation proceedings and a trial court may revoke a defendant's probation based solely on defendant's voluntary confession or reliable extrajudicial admission that he violated the conditions of his probation.”); People v. Monette, 25 Cal.App.4th 1572, 1575 , 31 Cal.Rptr.2d 203 (1994) ("The nature of a probation revocation hearing, however, does not require the application of the corpus delicti rule.”); State v. Sanchez, 109 N.M. 718 , 790 P.2d 515, 517 (N.M.App.1990) (holding “that the corpus delicti rule is inapplicable in probation revocation proceedings,

11
People v. Woznickgreen
illappct · 1996 · cited in 1 Virginia opinions naming this issue, 2011–2011
2 sentences

2011See, e.g., People v. Woznick, 278 Ill.App.3d 826 , 215 Ill.Dec. 523 , 663 N.E.2d 1037, 1039 (1996) ("The corpus delicti rule pertains to the substantive proof requisite in a criminal proceeding.

2011See, e.g., People v. Woznick, 278 Ill.App.3d 826 , 215 Ill.Dec. 523 , 663 N.E.2d 1037, 1039 (1996) ("The corpus delicti rule pertains to the substantive proof requisite in a criminal proceeding.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
Powell v. Commonwealth green
va · 2004
1 sentence

2025Hence, her testimony sufficiently corroborated Quiros’s confession under the corpus delicti rule.5 See Powell, 267 Va. at 145 .

12025–2025
Opper v. United States green
scotus · 1954
1 sentence

2014Opper v. United States, 348 U.S. 84 , 90 & n.5 (1954) ("[English] courts have been hesitant to lay down a rule that an uncorroborated extrajudicial confession may not send an accused to prison or to death."); 7 John H.

12014–2014
People v. Monette green
calctapp · 1994
2 sentences

2011It has no application in probation revocation proceedings and a trial court may revoke a defendant's probation based solely on defendant's voluntary confession or reliable extrajudicial admission that he violated the conditions of his probation.”); People v. Monette, 25 Cal.App.4th 1572, 1575 , 31 Cal.Rptr.2d 203 (1994) ("The nature of a probation revocation hearing, however, does not require the application of the corpus delicti rule.”); State v. Sanchez, 109 N.M. 718 , 790 P.2d 515, 517 (N.M.App.1990) (holding “that the corpus delicti rule is inapplicable in probation revocation proceedings,

2011It has no application in probation revocation proceedings and a trial court may revoke a defendant's probation based solely on defendant's voluntary confession or reliable extrajudicial admission that he violated the conditions of his probation.”); People v. Monette, 25 Cal.App.4th 1572, 1575 , 31 Cal.Rptr.2d 203 (1994) ("The nature of a probation revocation hearing, however, does not require the application of the corpus delicti rule.”); State v. Sanchez, 109 N.M. 718 , 790 P.2d 515, 517 (N.M.App.1990) (holding “that the corpus delicti rule is inapplicable in probation revocation proceedings,

12011–2011

Where else courts name it

CA 200 (1930–2026) TX 145 (1927–2025) PA 132 (1973–2026) WA 128 (1977–2026) OH 66 (1978–2026) MI 61 (1975–2026) IL 61 (1990–2024) FL 53 (1961–2025) IN 45 (1975–2023) NC 43 (1983–2025) AZ 29 (1992–2025) ME 29 (1973–2019) CT 29 (1964–2020) NM 28 (1990–2024) MO 22 (1987–2025) AR 17 (1995–2023) ID 11 (2003–2014) OR 11 (1921–2023) LA 10 (1971–2017) TN 9 (2012–2024) AK 8 (1980–2014) DE 8 (1985–2026) NV 7 (1990–2016) UT 7 (1991–2005) OK 6 (1994–2026) VT 5 (1996–2025) KS 5 (2014–2024) VA 5 (2011–2025) SC 4 (1997–2015) MD 4 (1975–2010) ND 4 (2021–2026) SD 3 (2002–2015) MN 3 (2010–2025) WV 3 (2012–2023) MT 3 (1984–2006) CO 3 (2013–2019) WY 3 (2010–2023) VI 2 (2010–2016) AL 2 (1986–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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