Minnesota Statutes
Minn. Stat. § 634.03 (2026)
Confession, Inadmissible When
✓ current as of May 2026
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A confession of the defendant shall not be sufficient to warrant conviction without evidence that the offense charged has been committed; nor can it be given in evidence against the defendant whether made in the course of judicial proceedings or to a private person, when made under the influence of fear produced by threats.
Notes of Decisions
Cited in 35
cases (7 in the last 5 years), 1963–2026 · leading case: State v. Heiges, 806 N.W.2d 1 (Minn. 2011).
State v. Heiges, 806 N.W.2d 1 (Minn. 2011). “Accordingly, the court held that Heiges’s statements to her friends provided sufficient evidence to corroborate her confessions to Pfaff, and therefore, her conviction did not violate Minn.Stat. § 634.03. Heiges, 779 N.W.2d at 913 .”
State v. HEIGES, 779 N.W.2d 904 (Minn. Ct. App. 2010). “Heiges contends that (1) there *907 was insufficient evidence to corroborate her confessions to the police under Minn. Stat. § 634.03 ; (2) the district court erred in instructing the jury on the burden of proof and duress; (3) the district court erred by allowing testimony of a…”
State v. Silvernail, 831 N.W.2d 594 (Minn. 2013). “See Minn.Stat. § 634.03 (2012). Because Sil-vernail does not argue that section 634.”
Matter of Welfare of M.D.S., 345 N.W.2d 723 (Minn. 1984). “sues we are presented with the following questions: whether the State presented sufficient evidence to prove that the juvenile defendant intentionally aided and advised in the intentional criminal damage to property which resulted in the victim’s death, and whether defendant’s…”
State v. Glaze, 452 N.W.2d 655 (Minn. 1990). “" It is hornbook law, codified at Minn.Stat. § 634.03 (1988), that a person's uncorroborated confessions of guilt are not sufficient to support a conviction.”
In re the Welfare of C.M.A., 671 N.W.2d 597 (Minn. Ct. App. 2003). “The district court determined that the delinquency petition lacked probable cause because respondent’s confession was not sufficiently corroborated by independent evidence that the charged offense had been committed, as required by Minn.Stat. § 634.03 (2002). Because the…”
State of Tennessee v. Courtney Bishop, 431 S.W.3d 22 (Tenn. 2014). “See Minn.Stat. Ann. § 634.03 (West 2009) ("A confession of the defendant shall not be sufficient to warrant conviction without evidence that the offense charged has been committed.”
State v. Olhausen, 669 N.W.2d 385 (Minn. Ct. App. 2003). “The state next argues that appellant's confession sufficiently supports his conviction. Following his arrest, while being interviewed by Agent Nance, appellant admitted that the package he offered to sell Nance contained methamphetamine.”
State v. Fader, 358 N.W.2d 42 (Minn. 1984). “” Minn.Stat. § 634.03 (1982). In other words, a confession by itself will not support a conviction, but must be corroborated.”
State v. Azzone, 135 N.W.2d 488 (Minn. 1965). “” One object of § 634.03 is to discourage invasions of the constitutional rights of accused persons to be free from undue pressure to confess exerted by law enforcement authorities.”
State v. Koskela, 536 N.W.2d 625 (Minn. 1995). “Minn.Stat. § 634.03 (1994). In a burglary case, this court has held that it is not necessary for the state to prove that anything actually was taken from the premises in order to meet its burden of proof — the critical point is the defendant’s intentions.”
State v. Vaughn, 361 N.W.2d 54 (Minn. 1985). “(i) Defendant’s contention that the convictions are based on insufficient evidence that the property transferred was stolen property is premised on the requirement that the corpus delicti be established by evidence independent of the defendant’s confession.”
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