corpus delicti rule in Delaware

2026Finally, Defendant posits that the State fails to meet its burden under Section 205(e) because the evidence provided by the State in discovery shows the memories 22 Indictment; Hoennicke, 13 A.3d at 748 . 23 Wright v. State, 953 A.2d 188, 192 (Del. 2008) (quoting Bright v. State, 490 A.2d 564, 569 (Del. 1985)). were recovered through psychotherapy, and there is no independent evidence corroborating those memories.

2016Constructive possession exists where the defendant (1) knew the location of the drugs; (2) had the ability to exercise dominion; and (3) had the intention to guide their destiny.11 Where drugs are found in a car, the presumption of dominion or control is no heavier on the car’s custodian than on the car’s passenger.12 Mere proximity or awareness of drugs is insufficient to establish constructive possession.13 However, if the defendant is found “near the drugs, this may establish a prima facie case of constructive possession if there also is evidence linking the accused to an ongoing criminal o

2026Finally, Defendant posits that the State fails to meet its burden under Section 205(e) because the evidence provided by the State in discovery shows the memories 22 Indictment; Hoennicke, 13 A.3d at 748 . 23 Wright v. State, 953 A.2d 188, 192 (Del. 2008) (quoting Bright v. State, 490 A.2d 564, 569 (Del. 1985)). were recovered through psychotherapy, and there is no independent evidence corroborating those memories.

2022The corpus delicti rule requires the State to “present some evidence of the existence of a crime[] independent of the defendant’s confession[.]” Wright v. State, 953 A.2d 188, 192 (Del. 2008) (internal quotation marks and emphasis omitted). 28 Although the corpus delicti rule guards against “pressured” and false confessions, DeJesus v. State, 655 A.2d 1180, 1202 (Del. 1995), there is no evidence that Stokes’s confession was untrue or coerced. 29 Stokes, 402 A.2d at 382 (emphasis added). 5 For another, Stokes misunderstands actual innocence. “[A]ctual innocence means factual innocence,” not leg

2016He argues the State’s evidence was insufficient to satisfy the requirements of the corpus delicti doctrine.12 (11) A confession without independent evidence of the corpus delicti of the charge is insufficient to support a conviction.13 Corpus delicti means “the body of the crime.”14 To establish the corpus delicti, the State must prove the injury and criminality of an offense.15 The corpus delicti rule is intended to “prevent individuals from being convicted of a crime by confession when there is no other evidence that a crime has been committed.”16 (12) Although there must be evidence of the

2016He argues the State’s evidence was insufficient to satisfy the requirements of the corpus delicti doctrine.12 (11) A confession without independent evidence of the corpus delicti of the charge is insufficient to support a conviction.13 Corpus delicti means “the body of the crime.”14 To establish the corpus delicti, the State must prove the injury and criminality of an offense.15 The corpus delicti rule is intended to “prevent individuals from being convicted of a crime by confession when there is no other evidence that a crime has been committed.”16 (12) Although there must be evidence of the

2016He argues the State’s evidence was insufficient to satisfy the requirements of the corpus delicti doctrine.12 (11) A confession without independent evidence of the corpus delicti of the charge is insufficient to support a conviction.13 Corpus delicti means “the body of the crime.”14 To establish the corpus delicti, the State must prove the injury and criminality of an offense.15 The corpus delicti rule is intended to “prevent individuals from being convicted of a crime by confession when there is no other evidence that a crime has been committed.”16 (12) Although there must be evidence of the

2016He argues the State’s evidence was insufficient to satisfy the requirements of the corpus delicti doctrine.12 (11) A confession without independent evidence of the corpus delicti of the charge is insufficient to support a conviction.13 Corpus delicti means “the body of the crime.”14 To establish the corpus delicti, the State must prove the injury and criminality of an offense.15 The corpus delicti rule is intended to “prevent individuals from being convicted of a crime by confession when there is no other evidence that a crime has been committed.”16 (12) Although there must be evidence of the

2022The corpus delicti rule requires the State to “present some evidence of the existence of a crime[] independent of the defendant’s confession[.]” Wright v. State, 953 A.2d 188, 192 (Del. 2008) (internal quotation marks and emphasis omitted). 28 Although the corpus delicti rule guards against “pressured” and false confessions, DeJesus v. State, 655 A.2d 1180, 1202 (Del. 1995), there is no evidence that Stokes’s confession was untrue or coerced. 29 Stokes, 402 A.2d at 382 (emphasis added). 5 For another, Stokes misunderstands actual innocence. “[A]ctual innocence means factual innocence,” not leg

1995In Stokes v. State, Del.Supr., 402 A.2d 376, 382 (1979), this Court applied the corpus delicti rule in the context of connected crimes, i.e., those crimes arising out of the same act, event, or occurrence.

2022The corpus delicti rule requires the State to “present some evidence of the existence of a crime[] independent of the defendant’s confession[.]” Wright v. State, 953 A.2d 188, 192 (Del. 2008) (internal quotation marks and emphasis omitted). 28 Although the corpus delicti rule guards against “pressured” and false confessions, DeJesus v. State, 655 A.2d 1180, 1202 (Del. 1995), there is no evidence that Stokes’s confession was untrue or coerced. 29 Stokes, 402 A.2d at 382 (emphasis added). 5 For another, Stokes misunderstands actual innocence. “[A]ctual innocence means factual innocence,” not leg

2008See also id. ("Were we to hold that, in a felony murder prosecution, the State must prove only the corpus delicti of homicide, but it need not establish independent evidence of the predicate felony, we would, in effect, relax the corpus delicti rule in its application to the most serious crimes.”).

2025We find no merit to Washington’s claim. (10) To sustain a conviction based on a defendant’s confession, the corpus delicti rule requires “some evidence of the existence of a crime, independent of the defendant’s confession.”20 The rule protects “those defendants who may be pressured to confess to crimes that they either did not commit or crimes that did not 20 Wright, 953 A.2d at 192 (citations omitted); see also Johnson v. State, 338 A.2d 124, 125 (Del. 1975) (rejecting requirement for “substantial” independent evidence and instead finding that “some proof” suffices) (emphasis not in original

1995See State v. Blackburn, 23 Del. 479 , 75 A. 536 (homicide); State v. Miller, 14 Del. 564 , 32 A. 137 (1892) (same); State v. Galvano, 34 Del. 409 , 154 A. 461 (same); Nelson v. State, 50 Del. 96 , 123 A.2d 859 (same); Derrickson, 321 A.2d 497 (same); Shipley v. State, 570 A.2d 1159 (same); State v. Hand, 15 Del. 545 , 41 A. 192 (1894) (arson); Johnson v. State, 338 A.2d 124 (rape); Jenkins v. State, 401 A.2d 83 (possession of a deadly weapon during the commission of a felony); Stokes v. State, 402 A.2d 376 (1979) (robbery); Bright v. State, 490 A.2d 564 (rape and kidnapping; Clendaniel v. Vosh

2016He argues the State’s evidence was insufficient to satisfy the requirements of the corpus delicti doctrine.12 (11) A confession without independent evidence of the corpus delicti of the charge is insufficient to support a conviction.13 Corpus delicti means “the body of the crime.”14 To establish the corpus delicti, the State must prove the injury and criminality of an offense.15 The corpus delicti rule is intended to “prevent individuals from being convicted of a crime by confession when there is no other evidence that a crime has been committed.”16 (12) Although there must be evidence of the

2016He argues the State’s evidence was insufficient to satisfy the requirements of the corpus delicti doctrine.12 (11) A confession without independent evidence of the corpus delicti of the charge is insufficient to support a conviction.13 Corpus delicti means “the body of the crime.”14 To establish the corpus delicti, the State must prove the injury and criminality of an offense.15 The corpus delicti rule is intended to “prevent individuals from being convicted of a crime by confession when there is no other evidence that a crime has been committed.”16 (12) Although there must be evidence of the

2016Constructive possession exists where the defendant (1) knew the location of the drugs; (2) had the ability to exercise dominion; and (3) had the intention to guide their destiny.11 Where drugs are found in a car, the presumption of dominion or control is no heavier on the car’s custodian than on the car’s passenger.12 Mere proximity or awareness of drugs is insufficient to establish constructive possession.13 However, if the defendant is found “near the drugs, this may establish a prima facie case of constructive possession if there also is evidence linking the accused to an ongoing criminal o

2016Constructive possession exists where the defendant (1) knew the location of the drugs; (2) had the ability to exercise dominion; and (3) had the intention to guide their destiny.11 Where drugs are found in a car, the presumption of dominion or control is no heavier on the car’s custodian than on the car’s passenger.12 Mere proximity or awareness of drugs is insufficient to establish constructive possession.13 However, if the defendant is found “near the drugs, this may establish a prima facie case of constructive possession if there also is evidence linking the accused to an ongoing criminal o

1995See Commonwealth v. Forde, 392 Mass. 453 , 466 N.E.2d 510 (1984). 11 .As one commentator has noted: The traditional approach [to the corpus delicti rule] has been to require that the elements of the offense be carefully distinguished and that the corroborating evidence tend to show each of those elements.

1995See Commonwealth v. Forde, 392 Mass. 453 , 466 N.E.2d 510 (1984). 11 .As one commentator has noted: The traditional approach [to the corpus delicti rule] has been to require that the elements of the offense be carefully distinguished and that the corroborating evidence tend to show each of those elements.

1995See State v. Blackburn, Del.Oyer & Term., 75 A. 536, 542 (1892) (corpus delicti rule “well settled”).

1995See State v. Blackburn, 23 Del. 479 , 75 A. 536 (homicide); State v. Miller, 14 Del. 564 , 32 A. 137 (1892) (same); State v. Galvano, 34 Del. 409 , 154 A. 461 (same); Nelson v. State, 50 Del. 96 , 123 A.2d 859 (same); Derrickson, 321 A.2d 497 (same); Shipley v. State, 570 A.2d 1159 (same); State v. Hand, 15 Del. 545 , 41 A. 192 (1894) (arson); Johnson v. State, 338 A.2d 124 (rape); Jenkins v. State, 401 A.2d 83 (possession of a deadly weapon during the commission of a felony); Stokes v. State, 402 A.2d 376 (1979) (robbery); Bright v. State, 490 A.2d 564 (rape and kidnapping; Clendaniel v. Vosh

1985Lemons v. State, 49 Md.App. 467 , 433 A.2d 1179, 1181 (1981).

1985Lemons v. State, 49 Md.App. 467 , 433 A.2d 1179, 1181 (1981).