corroboration rule in Connecticut

2020In deciding whether to review the defendant’s claim in Robert I, the majority stated that this court recently had held, ‘‘in State v. Leniart, 166 Conn. App. 142 , 152–53, 140 A.3d 1026 (2016) [rev’d in part, 333 Conn. 88 , 215 A.3d 1104 (2019)],4 that the corroboration rule is solely a rule of admissibility [and] agree[d] with the state that the defendant [could not] raise his unpre- served [corpus delicti] claim as part of his claim of insufficient evidence.’’ (Footnote added.) Robert I, supra, 168 Conn. App. 422 .

2020In deciding whether to review the defendant’s claim in Robert I, the majority stated that this court recently had held, ‘‘in State v. Leniart, 166 Conn. App. 142 , 152–53, 140 A.3d 1026 (2016) [rev’d in part, 333 Conn. 88 , 215 A.3d 1104 (2019)],4 that the corroboration rule is solely a rule of admissibility [and] agree[d] with the state that the defendant [could not] raise his unpre- served [corpus delicti] claim as part of his claim of insufficient evidence.’’ (Footnote added.) Robert I, supra, 168 Conn. App. 422 .

2008“The corroboration requirement . . . is significant and goes beyond minimal corroboration.” State v. Rosado, 218 Conn. 239, 249 , 588 A.2d 1066 (1991).

2008“The corroboration requirement . . . is significant and goes beyond minimal corroboration.” State v. Rosado, 218 Conn. 239, 249 , 588 A.2d 1066 (1991).

2020This ‘‘trustworthiness rule set forth in Harris, also known as the corroboration rule . . . applies to all types of crimes . . . . [A] con- fession is . . . sufficient to establish the corpus delicti of any crime, without independent extrinsic evidence that a crime was committed, as long as there is sufficient reason to conclude that the confession is reliable.’’ (Internal quotation marks omitted.) State v. Leniart, supra, 333 Conn. 113 , quoting State v. Hafford, 252 Conn. 274, 317 , 746 A.2d 150 , cert. denied, 531 U.S. 855 , 121 S. Ct. 136 , 148 L.

2020This ‘‘trustworthiness rule set forth in Harris, also known as the corroboration rule . . . applies to all types of crimes . . . . [A] con- fession is . . . sufficient to establish the corpus delicti of any crime, without independent extrinsic evidence that a crime was committed, as long as there is sufficient reason to conclude that the confession is reliable.’’ (Internal quotation marks omitted.) State v. Leniart, supra, 333 Conn. 113 , quoting State v. Hafford, 252 Conn. 274, 317 , 746 A.2d 150 , cert. denied, 531 U.S. 855 , 121 S. Ct. 136 , 148 L.

2020This ‘‘trustworthiness rule set forth in Harris, also known as the corroboration rule . . . applies to all types of crimes . . . . [A] con- fession is . . . sufficient to establish the corpus delicti of any crime, without independent extrinsic evidence that a crime was committed, as long as there is sufficient reason to conclude that the confession is reliable.’’ (Internal quotation marks omitted.) State v. Leniart, supra, 333 Conn. 113 , quoting State v. Hafford, 252 Conn. 274, 317 , 746 A.2d 150 , cert. denied, 531 U.S. 855 , 121 S. Ct. 136 , 148 L.

2020This ‘‘trustworthiness rule set forth in Harris, also known as the corroboration rule . . . applies to all types of crimes . . . . [A] con- fession is . . . sufficient to establish the corpus delicti of any crime, without independent extrinsic evidence that a crime was committed, as long as there is sufficient reason to conclude that the confession is reliable.’’ (Internal quotation marks omitted.) State v. Leniart, supra, 333 Conn. 113 , quoting State v. Hafford, 252 Conn. 274, 317 , 746 A.2d 150 , cert. denied, 531 U.S. 855 , 121 S. Ct. 136 , 148 L.

2020This ‘‘trustworthiness rule set forth in Harris, also known as the corroboration rule . . . applies to all types of crimes . . . . [A] con- fession is . . . sufficient to establish the corpus delicti of any crime, without independent extrinsic evidence that a crime was committed, as long as there is sufficient reason to conclude that the confession is reliable.’’ (Internal quotation marks omitted.) State v. Leniart, supra, 333 Conn. 113 , quoting State v. Hafford, 252 Conn. 274, 317 , 746 A.2d 150 , cert. denied, 531 U.S. 855 , 121 S. Ct. 136 , 148 L.

2020This ‘‘trustworthiness rule set forth in Harris, also known as the corroboration rule . . . applies to all types of crimes . . . . [A] con- fession is . . . sufficient to establish the corpus delicti of any crime, without independent extrinsic evidence that a crime was committed, as long as there is sufficient reason to conclude that the confession is reliable.’’ (Internal quotation marks omitted.) State v. Leniart, supra, 333 Conn. 113 , quoting State v. Hafford, 252 Conn. 274, 317 , 746 A.2d 150 , cert. denied, 531 U.S. 855 , 121 S. Ct. 136 , 148 L.

2016The corpus delicti rule, which is often also referred to as the corroboration rule, exists "to protect against conviction of offenses that have not, in fact, occurred, in other words, to prevent errors in convictions based solely upon untrue confessions to nonexistent crimes." State v. Arnold, 201 Conn. 276 , 287, 514 A.2d 330 (1986).

2016The corpus delicti rule, which is often also referred to as the corroboration rule, exists "to protect against conviction of offenses that have not, in fact, occurred, in other words, to prevent errors in convictions based solely upon untrue confessions to nonexistent crimes." State v. Arnold, 201 Conn. 276 , 287, 514 A.2d 330 (1986).

2017As the defendant acknowledges, in State v. Leniart , 166 Conn.App. 142 , 151, 140 A.3d 1026 , cert. granted, 323 Conn. 918 , 150 A.3d 1149 , and cert. granted, 323 Conn. 918 , 149 A.3d 499 (2016), 10 this court recognized "that under Connecticut law the corpus delicti rule is an evidentiary rule regarding the admissibility of confessions rather than a substantive rule of criminal law to be applied in reviewing the sufficiency of the state's evidence." With respect to the reviewability of corpus delicti claims, the court stated: "A defendant who fails to challenge the admissibility of the defen

2017As the defendant acknowledges, in State v. Leniart , 166 Conn.App. 142 , 151, 140 A.3d 1026 , cert. granted, 323 Conn. 918 , 150 A.3d 1149 , and cert. granted, 323 Conn. 918 , 149 A.3d 499 (2016), 10 this court recognized "that under Connecticut law the corpus delicti rule is an evidentiary rule regarding the admissibility of confessions rather than a substantive rule of criminal law to be applied in reviewing the sufficiency of the state's evidence." With respect to the reviewability of corpus delicti claims, the court stated: "A defendant who fails to challenge the admissibility of the defen

2024Ed. 1270 (1952). 7 The majority contends that my reliance on State v. Harris, supra, 405 N.W.2d 227 , People v. Ohlstein, supra, 54 App. Div. 2d 112, Chapman v. State, supra, 470 S.W.2d 660 , and Schnidt v. State, supra, 357 S.W.3d 851 , is misplaced because Connecticut has not adopted a corroboration rule for the testimony of accomplices and jailhouse informants.

2020The substantial evidence standard is met if the record provides a ‘‘substantial basis of fact from which the fact in issue can be reasonably inferred.’’ (Internal quotation marks omitted.) Adriani v. Commission on Human Rights & Opportunities, 220 Conn. 307, 315 , 596 A.2d 426 (1991).

2020The substantial evidence standard is met if the record provides a ‘‘substantial basis of fact from which the fact in issue can be reasonably inferred.’’ (Internal quotation marks omitted.) Adriani v. Commission on Human Rights & Opportunities, 220 Conn. 307, 315 , 596 A.2d 426 (1991).

2017As the defendant acknowledges, in State v. Leniart , 166 Conn.App. 142 , 151, 140 A.3d 1026 , cert. granted, 323 Conn. 918 , 150 A.3d 1149 , and cert. granted, 323 Conn. 918 , 149 A.3d 499 (2016), 10 this court recognized "that under Connecticut law the corpus delicti rule is an evidentiary rule regarding the admissibility of confessions rather than a substantive rule of criminal law to be applied in reviewing the sufficiency of the state's evidence." With respect to the reviewability of corpus delicti claims, the court stated: "A defendant who fails to challenge the admissibility of the defen

2017As the defendant acknowledges, in State v. Leniart , 166 Conn.App. 142 , 151, 140 A.3d 1026 , cert. granted, 323 Conn. 918 , 150 A.3d 1149 , and cert. granted, 323 Conn. 918 , 149 A.3d 499 (2016), 10 this court recognized "that under Connecticut law the corpus delicti rule is an evidentiary rule regarding the admissibility of confessions rather than a substantive rule of criminal law to be applied in reviewing the sufficiency of the state's evidence." With respect to the reviewability of corpus delicti claims, the court stated: "A defendant who fails to challenge the admissibility of the defen

2017As the defendant acknowledges, in State v. Leniart , 166 Conn.App. 142 , 151, 140 A.3d 1026 , cert. granted, 323 Conn. 918 , 150 A.3d 1149 , and cert. granted, 323 Conn. 918 , 149 A.3d 499 (2016), 10 this court recognized "that under Connecticut law the corpus delicti rule is an evidentiary rule regarding the admissibility of confessions rather than a substantive rule of criminal law to be applied in reviewing the sufficiency of the state's evidence." With respect to the reviewability of corpus delicti claims, the court stated: "A defendant who fails to challenge the admissibility of the defen

2017Accordingly, it is not necessary for us to decide whether there was substantial independent evidence tending to establish the trustworthiness of the defendant's confession, and we will consider his unobjected-to statements in the light most favorable to the state in evaluating his current claim of evidentiary insufficiency." Id. at 422 , 146 A.3d 995 .

2017Accordingly, it is not necessary for us to decide whether there was substantial independent evidence tending to establish the trustworthiness of the defendant's confession, and we will consider his unobjected-to statements in the light most favorable to the state in evaluating his current claim of evidentiary insufficiency." Id. at 422 , 146 A.3d 995 .

2016State v. Oliveras, supra, 210 Conn. 751 , 557 A.2d 534 , was decided before our Supreme Court reformulated the corpus delicti rule in State v. Hafford, supra, 252 Conn. at 314 -18 , 746 A.2d 150 , by extending the Opper rule to all crimes, including homicides.

2016State v. Oliveras, supra, 210 Conn. 751 , 557 A.2d 534 , was decided before our Supreme Court reformulated the corpus delicti rule in State v. Hafford, supra, 252 Conn. at 314 -18 , 746 A.2d 150 , by extending the Opper rule to all crimes, including homicides.

2016Although the court in Beverly allowed the defendant to raise the corroboration rule in challenging the sufficiency of the evidence, the court also somewhat contradictorily stated: "The corpus delicti rule is a rule of evidence intended to protect an accused from conviction as a result of a baseless confession when no crime has in fact been committed." (Emphasis added.) Id., at 375 , 618 A.2d 1335 .

2016Although the court in Beverly allowed the defendant to raise the corroboration rule in challenging the sufficiency of the evidence, the court also somewhat contradictorily stated: "The corpus delicti rule is a rule of evidence intended to protect an accused from conviction as a result of a baseless confession when no crime has in fact been committed." (Emphasis added.) Id., at 375 , 618 A.2d 1335 .

2016An early version of Connecticut's corroboration rule was extensively discussed in State v. Doucette, 147 Conn. 95 , 98-100, 157 A.2d 487 (1959), overruled in part by State v. Tillman, 152 Conn. 15 , 20, 202 A.2d 494 (1964).

2016An early version of Connecticut's corroboration rule was extensively discussed in State v. Doucette, 147 Conn. 95 , 98-100, 157 A.2d 487 (1959), overruled in part by State v. Tillman, 152 Conn. 15 , 20, 202 A.2d 494 (1964).

2016For example, the United States Court of Appeals for the Seventh Circuit recently stated: "The corroboration principle sometimes comes into play in the trial court's decision to admit the defendant's confession and also if he later challenges the sufficiency of the evidence." United States v. McDowell, 687 F.3d 904 , 912 (7th Cir.2012) ; see also United States v. Dickerson, 163 F.3d 639 , 642 (D.C.Cir.1999) ("[t]o be sure, the corroboration requirement has also been described as a rule governing the sufficiency of the evidence").

2016For example, the United States Court of Appeals for the Seventh Circuit recently stated: "The corroboration principle sometimes comes into play in the trial court's decision to admit the defendant's confession and also if he later challenges the sufficiency of the evidence." United States v. McDowell, 687 F.3d 904 , 912 (7th Cir.2012) ; see also United States v. Dickerson, 163 F.3d 639 , 642 (D.C.Cir.1999) ("[t]o be sure, the corroboration requirement has also been described as a rule governing the sufficiency of the evidence").

2016This court cannot substitute its own judgment for that of the jury if there is sufficient evidence to support the jury’s verdict. . . . [W]e do not sit as the seventh juror when we review the sufficiency of the evidence . . . rather, we must determine, in the light most favorable to sustaining the verdict, whether the totality of the evidence, including reasonable infer- ences therefrom, supports the jury’s verdict of guilt beyond a reasonable doubt.’’ (Citation omitted; internal quotation marks omitted.) State v. Miles, 97 Conn. App. 236, 240 , 903 A.2d 675 (2006). ‘‘The corpus delicti rule,

2016This court cannot substitute its own judgment for that of the jury if there is sufficient evidence to support the jury’s verdict. . . . [W]e do not sit as the seventh juror when we review the sufficiency of the evidence . . . rather, we must determine, in the light most favorable to sustaining the verdict, whether the totality of the evidence, including reasonable infer- ences therefrom, supports the jury’s verdict of guilt beyond a reasonable doubt.’’ (Citation omitted; internal quotation marks omitted.) State v. Miles, 97 Conn. App. 236, 240 , 903 A.2d 675 (2006). ‘‘The corpus delicti rule,

2016Instead, the defendant argued in Hafford , the trial court should have applied the corroboration rule set forth in State v. Tillman, supra, 152 Conn. 15 , 202 A.2d 494 , and, before admitting the confession, required independent corroborating evidence of the corpus delicti itself, i.e., that the victim was sexually assaulted, rather than evidence that did not relate to the corpus delicti but otherwise corroborated the reliability of the defendant's admission that he sexually assaulted her.

2016Instead, the defendant argued in Hafford , the trial court should have applied the corroboration rule set forth in State v. Tillman, supra, 152 Conn. 15 , 202 A.2d 494 , and, before admitting the confession, required independent corroborating evidence of the corpus delicti itself, i.e., that the victim was sexually assaulted, rather than evidence that did not relate to the corpus delicti but otherwise corroborated the reliability of the defendant's admission that he sexually assaulted her.