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Minnesota Supreme Court Announces Confession Must Be Corroborated by Independent Evidence Crime Occurred, Rejects Federal ‘Trustworthiness Standard’ for Corpus Delicti Rule
Loaded on May 1, 2022
by Douglas Ankney
published in Criminal Legal News
May, 2022, page 41
Filed under:
Impeachment Evidence/Purposes,
Confessions and Statements of Defendant.
Location:
Minnesota.
by Douglas Ankney
The Supreme Court of Minnesota announced that Minn. Stat. § 634.03 (2020) requires a defendant’s confession to be corroborated by independent evidence reasonably tending to prove that the specific offense charged has been committed.
During a police interview, Bryan Morgan Holl confessed to several incidents of sexually ...
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More from this issue:
- The Pseudoscientific Practice of Blood Spatter Analysis How the Desire for Convictions Drives Flawed Prosecutions, by Anthony Accurso
- Tennessee County Disproportionately Jails Black Children, and It’s Not Getting Better, by Jacob Barrett
- Digital Tyranny: Beware of the Government’s Push for a Digital Currency, by Nisha Whitehead, John W. Whitehead
- California Court of Appeal: Fifth Amendment Violation Where Police Use Two-Step Interrogation in Deliberate Strategy to Circumvent Miranda, by Richard Resch
- Seventh Circuit: Four-Year Delay in Filing Appeal Excused Habeas Exhaustion Requirement Because Any Further Attempts for Postconviction Remedies in State Court Would Have Been Futile, by Dale Chappell
- Ninth Circuit: IAC for Failure to Engage Mental Health Expert and Testing, State PCR Court’s Decision Contrary to Federal Law and Defective Factfinding, Habeas Relief Granted, by Dale Chappell
- Hawaii Supreme Court: Due Process Violation to Exclude Evidence of Victim’s BAC in Assault Case in Which Defendant Claims Self-Defense, by Matthew Clarke
- Sixth Circuit: Courts May Consider Nonretroactive Change in Law as One of Several Factors for Extraordinary and Compelling Circumstances for Compassionate Release, by Matthew Clarke
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- Kentucky Supreme Court: Officer’s History of Arresting Defendant on Multiple Occasions Constituted ‘Show of Authority’ That Defendant Was Not Free to Leave, Resulting in Unlawful Terry Stop, by Anthony Accurso
- Connecticut Supreme Court: Trial Court Abused Discretion by Limiting Self-Represented Defendant’s Direct Examination Regarding Risk of Injury to a Child, by Matthew Clarke
- Fifth Circuit Affirms Habeas Relief and New Trial Based on Counsel’s Failure to Interview State’s Key Eyewitness in Murder Case, by Dale Chappell
- Minnesota Supreme Court Announces Confession Must Be Corroborated by Independent Evidence Crime Occurred, Rejects Federal ‘Trustworthiness Standard’ for Corpus Delicti Rule, by Douglas Ankney
- Crushing Whistleblowers, by Jayson Hawkins
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- California Court of Appeal: Evidence Insufficient to Show Robbery Victim Moved ‘Substantial Distance’ to Support Simple Kidnapping Conviction and Amendments to § 186.22 Require Vacatur of Gang Enhancements, Feb. 15, 2025
- Fourth Circuit Revives Claims Against Virginia Jailers by Detainee They Allegedly Manhandled While Handcuffed, Feb. 15, 2025
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- Minnesota Supreme Court Announces No Duty to Retreat When Using Reasonable Force in Defense of Another and Provides Framework for Analyzing Such Claims, Feb. 1, 2025
- NIJ Partners With Doctor to Develop Better Screening Method to Detect and Identify Drugs Postmortem, Jan. 15, 2025
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More from these topics:
- Kansas Supreme Court Announces Clarification of Framework for Deciding Whether Confession Is Voluntary and Overrules Precedents That Held Reliability of Confession Is Factor to Be Considered, June 15, 2024. Confessions and Statements of Defendant, Voluntary Nature/Voluntariness.
- Research Paper Reveals Laypeople Have Insufficient Understanding of False Confessions by Examining Prior Research Based on Surveys and Mock Juries, March 15, 2024. Commentary/Reviews, False Confessions, Confessions and Statements of Defendant.
- Michigan Supreme Court: Defendant’s Statements Involuntary and Inadmissible, Feb. 15, 2024. Juvenile Offenses/Offenders, Confessions and Statements of Defendant, Voluntary Nature/Voluntariness.
- The Diminishment of Miranda Is Leading to False Confessions and Conviction of Innocents, Feb. 15, 2024. Commentary/Reviews, Wrongful Conviction, Confessions - Admissibility, Impeachment Evidence/Purposes, Miranda, Interrogation, In Custody, Confessions and Statements of Defendant, Voluntary Nature/Voluntariness.
- Oregon Supreme Court Clarifies Test to Determine When Person Becomes Agent of the State and Rules Jailhouse Snitch Was Agent, Requiring Suppression of Defendant’s Statements, Jan. 15, 2024. Informants, Post-Arrest Statements, Informants and Paid Witnesses, Confessions - Admissibility, Police Interrogations, Custodial Interrogations, Confessions and Statements of Defendant.
- Idaho Supreme Court: Confession Obtained in Violation of Miranda Inadmissible in State’s Case in Chief but May Be Used for Impeachment Purposes Where Defendant’s Will Was Not ‘Overborne’ During Interrogation, May 15, 2023. Impeachment Evidence/Purposes, Impeachment, Interrogation.
- Oregon Bans Police Lying to Obtain Confessions from Juveniles, March 15, 2022. Police Misconduct, Juvenile Offenses/Offenders, Confessions and Statements of Defendant.
- Texas Court of Criminal Appeals: Defendant Satisfied Requirements of Confession and Avoidance, ‘Unintentional Self-Defense’ Jury Instruction Allowed Against Charge of Intentional Offense, Feb. 15, 2022. Jury Instructions, Confessions and Statements of Defendant.
- North Carolina Supreme Court Announces Pretrial Notice of Duress Defense Does Not Forfeit Fifth Amendment Right to Silence, Reaffirms Rule Against Preemptive Impeachment, Dec. 15, 2021. Impeachment Evidence/Purposes, Right to Testify/Remain Silent.
- Maine Supreme Court: Counsel’s Introduction of Victim’s Video Interview with Police Was Not ‘Sound Trial Strategy,’ Constituted IAC, June 15, 2021. Per se ineffectiveness, Confessions and Statements of Defendant.