corroboration requirement (Indiana) · Go Syfert
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corroboration requirement in Indiana

6 Indiana opinions name it 1 courts 1988–2020 0 in the last five years

The cases below were cited by Indiana 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 (8)

CaseFollowedCited
Oatts v. Stategreen
indctapp · 2009 · cited in 1 Indiana opinions naming this issue, 2020–2020
1 sentence

2020See Oatts v. State, 899 N.E.2d 714 , 723 n.13 (Ind. Ct. App. 2009) (“Here, . . . there is no evidence other than [the victim]’s testimony that sexual contact occurred.

11
State v. Derngreen
kan · 2015 · cited in 1 Indiana opinions naming this issue, 2018–2018
2 sentences

2018See State v. Dern , 303 Kan. 384 , 362 P.3d 566 , 580-83 (2015) (listing states that have abandoned or modified the corpus delicti rule, explicitly adopting a standard of trustworthiness for the admissibility of confessions for any crime that does not naturally or obviously produce a tangible injury easily susceptible to physical proof, and stating, "The unfortunate fact that our longstanding recognition of [the trustworthiness] method of showing the corpus delicti has all too often been obscured by our previous insistence on reciting the formal rule even when inapplicable is remedied today.")

2018See State v. Dern , 303 Kan. 384 , 362 P.3d 566 , 580-83 (2015) (listing states that have abandoned or modified the corpus delicti rule, explicitly adopting a standard of trustworthiness for the admissibility of confessions for any crime that does not naturally or obviously produce a tangible injury easily susceptible to physical proof, and stating, "The unfortunate fact that our longstanding recognition of [the trustworthiness] method of showing the corpus delicti has all too often been obscured by our previous insistence on reciting the formal rule even when inapplicable is remedied today.")

11
State v. Fearsgreen
moctapp · 2007 · cited in 1 Indiana opinions naming this issue, 2012–2012
1 sentence

2012Ct. App. 2003) (stating that the uncorroborated testimony of a victim is sufficient to support a conviction where that testimony is not discredited or contradicted by other evidence); State v. Fears, 217 S.W.3d 323, 332 (Mo. Ct. App. 2007) (concluding that each child victim offered uncontradicted testimony corroborating the testimony of the other); Shepard v. State, 244 S.W.3d 421, 423-24 (Tex. Ct. App. 2007) (opining that the corroboration requirement contained in the solicitation statute requires that “we eliminate the minor victim’s testimony from consideration and then determine whether th

11
Johnson v. Stategreen
ind · 1995 · cited in 1 Indiana opinions naming this issue, 2012–2012
2 sentences

2012See Johnson v. State, 659 N.E.2d 116, 119 (Ind. 1995) (holding that anonymous tip that provided only information easily obtainable by members of general public was insufficiently reliable to constitute reasonable suspicion to conduct investigatory stop).

2012See Johnson v. State, 659 N.E.2d 116, 119 (Ind.1995) (holding that anonymous tip that provided only information easily obtainable by members of general public was insufficiently reliable to constitute reasonable suspicion to conduct investigatory stop).

11
State v. Craiggreen
neb · 1985 · cited in 1 Indiana opinions naming this issue, 2012–2012
1 sentence

2012Ct. App. 2003) (stating that the uncorroborated testimony of a victim is sufficient to support a conviction where that testimony is not discredited or contradicted by other evidence); State v. Fears, 217 S.W.3d 323, 332 (Mo. Ct. App. 2007) (concluding that each child victim offered uncontradicted testimony corroborating the testimony of the other); Shepard v. State, 244 S.W.3d 421, 423-24 (Tex. Ct. App. 2007) (opining that the corroboration requirement contained in the solicitation statute requires that “we eliminate the minor victim’s testimony from consideration and then determine whether th

11
Shepard v. Stategreen
texapp · 2008 · cited in 1 Indiana opinions naming this issue, 2012–2012
1 sentence

2012Ct. App. 2003) (stating that the uncorroborated testimony of a victim is sufficient to support a conviction where that testimony is not discredited or contradicted by other evidence); State v. Fears, 217 S.W.3d 323, 332 (Mo. Ct. App. 2007) (concluding that each child victim offered uncontradicted testimony corroborating the testimony of the other); Shepard v. State, 244 S.W.3d 421, 423-24 (Tex. Ct. App. 2007) (opining that the corroboration requirement contained in the solicitation statute requires that “we eliminate the minor victim’s testimony from consideration and then determine whether th

11
State v. Petrygreen
indctapp · 1988 · cited in 1 Indiana opinions naming this issue, 1989–1989
2 sentences

1989See e.g., State v. Petry (1988) 2d Dist.Ind.App., 524 N.E.2d 1293 ; Altmeyer v. State (1986) 1st Dist.Ind.App., 496 N.E.2d 1328, 1331 .

1989The phrase simply requires corroboration that the 'act' was committed by someone." However, in State v. Petry, supra, 524 N.E.2d 1293, 1300 , we found corroboration to be a broader term than corpus delicti, although it served the same purpose, i.e., prevention of the danger of falsification.

11
State v. Huntgreen
washctapp · 1987 · cited in 1 Indiana opinions naming this issue, 1988–1988
2 sentences

1988The most thorough examination of the corroboration requirement to date was given in State v. Hunt (1987), 48 Wash.App. 840 , 741 P.2d 566 .

1988The most thorough examination of the corroboration requirement to date was given in State v. Hunt (1987), 48 Wash.App. 840 , 741 P.2d 566 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (7)

CaseCitedYears
Miller v. State green
indctapp · 1986
2 sentences

1989The First District in Miller v. State (1986) 1st Dist.Ind.App., 498 N.E.2d 1008, 1013 , viewed the corroboration requirement as serving "the same purpose as the requirement that independent corroborative proof of. the corpus delicti be introduced before a confession is admitted.

1989App., 498 N.E.2d 1008, 1013 , viewed the corroboration requirement as serving "the same purpose as the requirement that independent corroborative *210 proof of the corpus delicti be introduced before a confession is admitted.

21988–1989
Ohio v. Roberts red
scotus · 1980
2 sentences

1989By requiring corroborative evidence whenever the child was not available to testify, the legislature enacted a higher burden of proof than was required under Ohio v. Roberts (1980) 448 U.S. 56 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 . 8 To allow the child's complaint to her mother or doctor, albeit in a different form than her videotaped statement, to constitute corroborative evidence of the act is to virtually eliminate the corroboration requirement and to bootstrap the statement into substantive evidence which alone would justify a conviction of the crime.

1989By requiring corroborative evidence whenever the child was not available to testify, the legislature enacted a higher burden of proof than was required under Ohio v. Roberts (1980) 448 U.S. 56 , 100 S.Ct. 2531 , 65 L.Ed.2d 597 . 8 To allow the child's complaint to her mother or doctor, albeit in a different form than her videotaped statement, to constitute corroborative evidence of the act is to virtually eliminate the corroboration requirement and to bootstrap the statement into substantive evidence which alone would justify a conviction of the crime.

11989–1989
Altmeyer v. State neutral
indctapp · 1986
1 sentence

1989See e.g., State v. Petry (1988) 2d Dist.Ind.App., 524 N.E.2d 1293 ; Altmeyer v. State (1986) 1st Dist.Ind.App., 496 N.E.2d 1328, 1331 .

11989–1989
State v. John Doe green
wash · 1986
1 sentence

1988Acknowledging that in most cases of child sexual abuse there is no physical evidence or eyewitness, Hunt follows the concurrence in Doe, 719 P.2d 554 , in stating that the corroboration requirement encompasses both direct and indirect evidence.

11988–1988
State v. Jones green
washctapp · 1988
2 sentences

1988The Washington Court of Appeals extended its Hunt analysis in State v. Jones (1988), 50 Wash.App. 709 , 750 P.2d 281 .

1988The Washington Court of Appeals extended its Hunt analysis in State v. Jones (1988), 50 Wash.App. 709 , 750 P.2d 281 .

11988–1988
State v. Gitchel green
washctapp · 1985
2 sentences

1988In State v. Gitchel (1985), 41 Wash.App. 820 , 706 P.2d 1091 , the Washington Court of Appeals upheld the trial court's determination that the evidence corroborated the child's hearsay statements.

1988In State v. Gitchel (1985), 41 Wash.App. 820 , 706 P.2d 1091 , the Washington Court of Appeals upheld the trial court's determination that the evidence corroborated the child's hearsay statements.

11988–1988
City of Bremerton v. Corbett green
wash · 1986
2 sentences

1988The corroboration requirement was defined as "'evidence of sufficient circumstances which would support a logical and reasonable inference' that the act of abuse described in the hearsay statement occurred." Id. at 571-72, quoting Bremerton v. Corbett (1986), 106 Wash.2d 569, 578 , 723 P.2d 1135, 1140 .

1988The corroboration requirement was defined as "'evidence of sufficient circumstances which would support a logical and reasonable inference' that the act of abuse described in the hearsay statement occurred." Id. at 571-72, quoting Bremerton v. Corbett (1986), 106 Wash.2d 569, 578 , 723 P.2d 1135, 1140 .

11988–1988

Where else courts name it

NY 213 (1967–2025) TX 147 (1979–2026) CA 117 (1945–2025) MO 67 (1911–2024) IL 64 (1977–2024) OH 56 (1980–2026) WA 48 (1981–2025) GA 48 (1931–2025) MA 43 (1984–2025) DC 41 (1963–2019) WI 29 (1987–2025) CT 26 (1964–2024) ID 26 (1947–2026) MD 26 (1967–2023) TN 25 (1979–2025) OR 23 (1968–2022) VA 21 (1994–2025) NJ 21 (1944–2026) IA 19 (1966–2025) AL 17 (1980–2016) MN 14 (1951–2026) LA 14 (1994–2018) SD 13 (2001–2024) SC 11 (1999–2024) FL 11 (1967–2019) WV 9 (1981–2023) AZ 9 (1980–2023) PA 8 (1974–2023) CO 8 (1989–2019) MI 7 (1976–2020) NV 7 (1980–2017) NE 7 (1988–2014) NM 6 (1972–2017) IN 6 (1988–2020) ND 6 (1990–2016) OK 5 (1976–2018) KY 5 (1998–2014) UT 5 (2003–2025) AK 5 (1976–2021) KS 5 (2002–2015) RI 4 (1980–2024) MS 4 (2002–2020) MT 4 (1938–2006) DE 3 (1997–2018) NC 3 (1977–1985) ME 2 (1830–1981) AR 2 (1980–1987) VT 2 (1987–1994)

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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