corpus delicti rule in Idaho

11 Idaho opinions name it 2 courts 2003–2014 0 in the last five years

The cases below were cited by Idaho 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 (18)

Case	Followed	Cited
State v. Darrahgreen · 1939 · cited in 5 Idaho opinions naming this issue, 2003–2014 2 sentences 2014Roth, 138 Idaho at 823 , 69 P.3d at 1084 (citing State v. Darrah, 60 Idaho 479, 482 , 92 P.2d 143, 144 (1939)). 2014Roth, 138 Idaho at 823 , 69 P.3d at 1084 (citing State v. Darrah, 60 Idaho 479, 482 , 92 P.2d 143, 144 (1939)).	5	5
State v. Kellergreen · 1902 · cited in 5 Idaho opinions naming this issue, 2011–2014 2 sentences 2013The corpus delicti rule is “the fact that a crime has been committed cannot be proved by the extrajudicial confessions or statements of the prisoner, and that there must be some evidence or corroborating circumstances tending to show that a crime has been committed, aside from such confessions or statements.” State v. Keller, 8 Idaho 699, 704 , 70 P. 1051, 1052 (1902). 2013The corpus delicti rule is “the fact that a crime has been committed cannot be proved by the extrajudicial confessions or statements of the prisoner, and that there must be some evidence or corroborating circumstances tending to show that a crime has been committed, aside from such confessions or statements.” State v. Keller, 8 Idaho 699, 704 , 70 P. 1051, 1052 (1902).	5	5
Smith v. United Statesgreen scotus · 1954 · cited in 5 Idaho opinions naming this issue, 2003–2013 2 sentences 2013Although some argue that one rationale supporting the rule is that confessions may be unreliable because they have been coerced or induced, Smith v. United States, 348 U.S. 147, 153 , 75 S.Ct. 194, 197-98 , 99 L.Ed. 192, 198 (1954), the rule was not adopted in Idaho for that purpose because in Keller the defendant’s confession was voluntarily made to a friend at the defendant’s sheep camp. 2013Although some argue that one rationale supporting the rule is that confessions may be unreliable because they have been coerced or induced, Smith v. United States, 348 U.S. 147, 153 , 75 S.Ct. 194, 197-98 , 99 L.Ed. 192, 198 (1954), the rule was not adopted in Idaho for that purpose because in Keller the defendant’s confession was voluntarily made to a friend at the defendant’s sheep camp.	5	5
State v. Tiffanygreen idaho · 2004 · cited in 6 Idaho opinions naming this issue, 2004–2013 2 sentences 2013The last case in which we have addressed the corpus delicti rule is State v. Tiffany, 139 Idaho 909 , 88 P.3d 728 (2004). 2013The last case in which we have addressed the corpus delicti rule is State v. Tiffany, 139 Idaho 909 , 88 P.3d 728 (2004).	3	6
Fontenot v. Stategreen oklacrimapp · 1994 · cited in 3 Idaho opinions naming this issue, 2003–2011 2 sentences 2011State authorities that have adopted a trustworthiness test in preference to the corpus delicti rule include State v. Hafford, 746 A.2d 150, 174 (Conn. 2000); State v. Yoshida, 354 P.2d 986, 990 (Haw. 1960); State v. George, 257 A.2d 19, 21 (N.H. 1969); State v. Parker, 337 S.E.2d 487, 492 (N.C. 1985); Fontenot v. State, 881 P.2d 69, 77-78 (Okla. 2011State authorities that have adopted a trustworthiness test in preference to the corpus delicti rule include State v. Hafford, 746 A.2d 150, 174 (Conn. 2000); State v. Yoshida, 354 P.2d 986, 990 (Haw. 1960); State v. George, 257 A.2d 19, 21 (N.H. 1969); State v. Parker, 337 S.E.2d 487, 492 (N.C. 1985); Fontenot v. State, 881 P.2d 69, 77-78 (Okla.	3	3
State v. Rothgreen idahoctapp · 2003 · cited in 6 Idaho opinions naming this issue, 2007–2014 2 sentences 2014However, when the corpus delicti rule was in effect in Idaho, the State did not have to establish independently from the defendant’s confession each element of the corpus delicti Urie, 92 Idaho at 73 , 437 P.2d at 26 ; Roth, 138 Idaho at 823 , 69 P.3d at 1084 . 2014However, when the corpus delicti rule was in effect in Idaho, the State did not have to establish independently from the defendant’s confession each element of the corpus delicti Urie, 92 Idaho at 73 , 437 P.2d at 26 ; Roth, 138 Idaho at 823 , 69 P.3d at 1084 .	2	6
State v. Uriegreen idaho · 1968 · cited in 5 Idaho opinions naming this issue, 2011–2014 2 sentences 2014However, when the corpus delicti rule was in effect in Idaho, the State did not have to establish independently from the defendant’s confession each element of the corpus delicti Urie, 92 Idaho at 73 , 437 P.2d at 26 ; Roth, 138 Idaho at 823 , 69 P.3d at 1084 . 2014However, when the corpus delicti rule was in effect in Idaho, the State did not have to establish independently from the defendant’s confession each element of the corpus delicti Urie, 92 Idaho at 73 , 437 P.2d at 26 ; Roth, 138 Idaho at 823 , 69 P.3d at 1084 .	2	5
Opper v. United Statesgreen scotus · 1954 · cited in 3 Idaho opinions naming this issue, 2003–2011 2 sentences 2011See Opper v. United States, 348 U.S. 84, 93 (1954); Smith v. United States, 348 U.S. 147, 156 (1954). 2011See Opper v. United States, 348 U.S. 84, 93 (1954); Smith v. United States, 348 U.S. 147, 156 (1954).	2	3
State v. Maidwellgreen idaho · 2002 · cited in 2 Idaho opinions naming this issue, 2012–2013 2 sentences 2013“While we are cognizant of the importance stare decisis plays in the judicial process, we are not hesitant to reverse ourselves when a doctrine, a defense, or a holding in a case has proven over time to be unjust or unwise.” State v. Maidwell, 137 Idaho 424, 426 , 50 P.3d 439, 441 (2002). 2013“While we are cognizant of the importance stare decisis plays in the judicial process, we are not hesitant to reverse ourselves when a doctrine, a defense, or a holding in a case has proven over time to be unjust or unwise.” State v. Maidwell, 137 Idaho 424, 426 , 50 P.3d 439, 441 (2002).	2	2
United States v. Northrupgreen nvd · 1980 · cited in 2 Idaho opinions naming this issue, 2011–2011 2 sentences 2011See United States v. Calderon, 348 U.S. 160, 163-64 (1954) (holding additional admissions were insufficient to corroborate defendant’s initial confession and the Court must look for other evidence a crime was committed); United States v. Northrup, 482 F. Supp. 1032, 1037 (D. 2011See United States v. Calderon, 348 U.S. 160, 163-64 (1954) (holding additional admissions were insufficient to corroborate defendant’s initial confession and the Court must look for other evidence a crime was committed); United States v. Northrup, 482 F. Supp. 1032, 1037 (D.	2	2
People v. Robsongreen coloctapp · 2003 · cited in 2 Idaho opinions naming this issue, 2011–2011 2 sentences 2011See People v. Robson, 80 P.3d 912, 913 (Colo. App. 2003) (holding trial court did not err in granting motion to dismiss because the State proved only that defendant had the opportunity to commit the crime and opportunity alone is insufficient to satisfy the requirements of corpus delicti); People ex rel. 2011See People v. Robson, 80 P.3d 912, 913 (Colo. App. 2003) (holding trial court did not err in granting motion to dismiss because the State proved only that defendant had the opportunity to commit the crime and opportunity alone is insufficient to satisfy the requirements of corpus delicti); People ex rel.	2	2
State v. Haffordgreen conn · 2000 · cited in 2 Idaho opinions naming this issue, 2011–2011 2 sentences 2011State authorities that have adopted a trustworthiness test in preference to the corpus delicti rule include State v. Hafford, 746 A.2d 150, 174 (Conn. 2000); State v. Yoshida, 354 P.2d 986, 990 (Haw. 1960); State v. George, 257 A.2d 19, 21 (N.H. 1969); State v. Parker, 337 S.E.2d 487, 492 (N.C. 1985); Fontenot v. State, 881 P.2d 69, 77-78 (Okla. 2011State authorities that have adopted a trustworthiness test in preference to the corpus delicti rule include State v. Hafford, 746 A.2d 150, 174 (Conn. 2000); State v. Yoshida, 354 P.2d 986, 990 (Haw. 1960); State v. George, 257 A.2d 19, 21 (N.H. 1969); State v. Parker, 337 S.E.2d 487, 492 (N.C. 1985); Fontenot v. State, 881 P.2d 69, 77-78 (Okla.	2	2
State v. Wilsongreen idaho · 1932 · cited in 2 Idaho opinions naming this issue, 2011–2011 2 sentences 2011See State v. Tiffany, 139 Idaho 909, 913 , 88 P.3d 728, 732 (2004); State v. Urie, 92 Idaho 71, 73 , 437 P.2d 24, 26 (1968); State v. Wilson, 51 Idaho 659, 669 , 9 P.2d 497, 500-01 (1932); State v. Keller, 8 Idaho 699, 704-05 , 70 P. 1051, 1052 (1902); State v. Roth, 138 Idaho 820, 822 , 69 P.3d 1081, 1083 (Ct. App. 2003). 2011See State v. Tiffany, 139 Idaho 909, 913 , 88 P.3d 728, 732 (2004); State v. Urie, 92 Idaho 71, 73 , 437 P.2d 24, 26 (1968); State v. Wilson, 51 Idaho 659, 669 , 9 P.2d 497, 500-01 (1932); State v. Keller, 8 Idaho 699, 704-05 , 70 P. 1051, 1052 (1902); State v. Roth, 138 Idaho 820, 822 , 69 P.3d 1081, 1083 (Ct. App. 2003).	2	2
United States v. Calderongreen scotus · 1954 · cited in 2 Idaho opinions naming this issue, 2011–2011 2 sentences 2011See United States v. Calderon, 348 U.S. 160, 163-64 (1954) (holding additional admissions were insufficient to corroborate defendant’s initial confession and the Court must look for other evidence a crime was committed); United States v. Northrup, 482 F. Supp. 1032, 1037 (D. 2011See United States v. Calderon, 348 U.S. 160, 163-64 (1954) (holding additional admissions were insufficient to corroborate defendant’s initial confession and the Court must look for other evidence a crime was committed); United States v. Northrup, 482 F. Supp. 1032, 1037 (D.	2	2
State v. Parkergreen nc · 1985 · cited in 2 Idaho opinions naming this issue, 2011–2011 2 sentences 2011State authorities that have adopted a trustworthiness test in preference to the corpus delicti rule include State v. Hafford, 746 A.2d 150, 174 (Conn. 2000); State v. Yoshida, 354 P.2d 986, 990 (Haw. 1960); State v. George, 257 A.2d 19, 21 (N.H. 1969); State v. Parker, 337 S.E.2d 487, 492 (N.C. 1985); Fontenot v. State, 881 P.2d 69, 77-78 (Okla. 2011State authorities that have adopted a trustworthiness test in preference to the corpus delicti rule include State v. Hafford, 746 A.2d 150, 174 (Conn. 2000); State v. Yoshida, 354 P.2d 986, 990 (Haw. 1960); State v. George, 257 A.2d 19, 21 (N.H. 1969); State v. Parker, 337 S.E.2d 487, 492 (N.C. 1985); Fontenot v. State, 881 P.2d 69, 77-78 (Okla.	2	2
State v. Francis Noboru Yoshidagreen haw · 1960 · cited in 2 Idaho opinions naming this issue, 2011–2011 2 sentences 2011State authorities that have adopted a trustworthiness test in preference to the corpus delicti rule include State v. Hafford, 746 A.2d 150, 174 (Conn. 2000); State v. Yoshida, 354 P.2d 986, 990 (Haw. 1960); State v. George, 257 A.2d 19, 21 (N.H. 1969); State v. Parker, 337 S.E.2d 487, 492 (N.C. 1985); Fontenot v. State, 881 P.2d 69, 77-78 (Okla. 2011State authorities that have adopted a trustworthiness test in preference to the corpus delicti rule include State v. Hafford, 746 A.2d 150, 174 (Conn. 2000); State v. Yoshida, 354 P.2d 986, 990 (Haw. 1960); State v. George, 257 A.2d 19, 21 (N.H. 1969); State v. Parker, 337 S.E.2d 487, 492 (N.C. 1985); Fontenot v. State, 881 P.2d 69, 77-78 (Okla.	2	2
State v. Georgegreen nh · 1969 · cited in 2 Idaho opinions naming this issue, 2011–2011 2 sentences 2011State authorities that have adopted a trustworthiness test in preference to the corpus delicti rule include State v. Hafford, 746 A.2d 150, 174 (Conn. 2000); State v. Yoshida, 354 P.2d 986, 990 (Haw. 1960); State v. George, 257 A.2d 19, 21 (N.H. 1969); State v. Parker, 337 S.E.2d 487, 492 (N.C. 1985); Fontenot v. State, 881 P.2d 69, 77-78 (Okla. 2011State authorities that have adopted a trustworthiness test in preference to the corpus delicti rule include State v. Hafford, 746 A.2d 150, 174 (Conn. 2000); State v. Yoshida, 354 P.2d 986, 990 (Haw. 1960); State v. George, 257 A.2d 19, 21 (N.H. 1969); State v. Parker, 337 S.E.2d 487, 492 (N.C. 1985); Fontenot v. State, 881 P.2d 69, 77-78 (Okla.	2	2
State v. Drapergreen idaho · 2011 · cited in 1 Idaho opinions naming this issue, 2014–2014 2 sentences 2014State v. Draper, 151 Idaho 576, 587 , 261 P.3d 853, 864 (2011). 2014State v. Draper, 151 Idaho 576, 587 , 261 P.3d 853, 864 (2011).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway.

Also cited on this issue (3)

Case	Cited	Years
State v. Todd James Suriner green idaho · 2013 2 sentences 2014Following the filing of its respondent’s brief in this appeal, the State filed a motion to stay the proceedings until the issuance of a remittitur in a ease then pending before the Idaho Supreme Court, State v. Suriner, 154 Idaho 81 , 294 P.3d 1093 (2013), where a key issue raised was the continued viability of the corpus delicti rule in Idaho. 2014Following the filing of its respondent’s brief in this appeal, the State filed a motion to stay the proceedings until the issuance of a remittitur in a ease then pending before the Idaho Supreme Court, State v. Suriner, 154 Idaho 81 , 294 P.3d 1093 (2013), where a key issue raised was the continued viability of the corpus delicti rule in Idaho.	3	2014–2014
State v. Richardson neutral · 1935 2 sentences 2014In State v. Richardson, 56 Idaho 150 , 50 P.2d 1012 (1935), our Supreme Court addressed the requisite corroborative evidence to establish the corpus delicti of adultery. 2014In State v. Richardson, 56 Idaho 150 , 50 P.2d 1012 (1935), our Supreme Court addressed the requisite corroborative evidence to establish the corpus delicti of adultery.	1	2014–2014
State v. Mauchley green utah · 2003 1 sentence 2003See Smith v. Unites States, 348 U.S. 147 , 75 S.Ct. 194 , 99 L.Ed. 192 (1954); Opper v. United States, 348 U.S. 84 , 75 S.Ct. 158 , 99 L.Ed. 101 (1954); Fontenot v. State, 881 P.2d 69, 77-78 (Okla.Crim.App.1994); State v. Mauchley, 67 P.3d 477 (Utah 2003). 4 .	1	2003–2003

Statutes the citing opinions construe

ID § Idaho Code § 18-1508 (4) ID § Idaho Code § 18-8004 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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.

← Caselaw search · G Cite Topics · Brief Check