JAMES ERIC KNIGHT, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
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Knight appeals his conviction for murder and robbery, challenging whether the state proved corpus delicti independent of his confession. The court held that the victim's injuries and missing wallet sufficiently established corpus delicti without relying solely on Knight's confession, allowing his conviction to stand.
The corpus delicti was adequately established by the victim's condition (strangulation and battering) and the missing wallet, which together proved both the murder and robbery occurred independent of the confession. Knight's detailed and consistent confession, combined with this independent proof of corpus delicti, was sufficient to prove guilt beyond a reasonable doubt.
“The concerns underlying the prophylactic rule precluding a conviction solely on a confession are not the same where, for example, the defendant's testimony at trial is used to supply the missing proof of corpus delicti, see Alvarez v. State, 403 So. 2d 1005 (Fla. 3d DCA 1981) or where res gestae statements made by the defendant supply the proof of corpus delicti, see State v. Snowden, 345 So. 2d 856 (Fla. 1st DCA 1977).”
Establishes that the prophylactic rule against conviction solely on confession applies differently depending on the source of corpus delicti proof.
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Join FLexlaw to unlock all legal intelligenceThe victim was found dead from strangulation and battering with his wallet and contents removed from his person. Knight provided a detailed and comple…
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. The concerns underlying the prophylactic rule precluding a conviction solely on a confession are not the same where, for example, the defendant’s testimony at trial is used to supply the missing proof of corpus delicti, see Alvarez v. State, 403 So. 2d 1005 (Fla. 3d DCA 1981) or where res gestae statements made by the defendant supply the proof of corpus delicti, see State v. Snowden, 345 So. 2d 856 (Fla. 1st DCA 1977). In the latter instances, the statements made by the defendant are not induced by possible police pressure and thus are not of suspect reliability.
. The victim was found dead from strangulation and battering, his wallet and its contents removed from his person. These circumstances clearly tended to show that a robbery of the victim occurred, and therefore established the corpus delicti. See Ussery v. State, supra. The corpus delicti, in conjunction with the completely consistent and detailed confession of Knight, was more than adequate to prove the guilt of the defendant beyond a reasonable doubt.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Anderson v. State, 467 So. 2d 781 (Fla. 3d DCA 1985)…held, in effect, that it is proper to challenge the admissibil [*783] ity of a defendant’s statement to the police, based on insufficient independent proof of a corpus delicti, on a defense motion at trial for judgment of acquittal. Knight v. State, 402 So. 2d 435 (Fla. 3d DCA 1981). The point on appeal, then, centers on the admissibility of the defendant’s statement as against a no corpus delicti challenge asserted by the defendant. The Florida Supreme Court has summarized the controlling Florida law on thi…
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Williams v. State, 689 So. 2d 393 (Fla. 3d DCA 1997)…ccurred at that time. Therefore, the state has shown that the victim suffered the type of harm contemplated by the robbery charge and that the harm was caused by the criminal agency of another. See State v. Allen, 335 So. 2d at 825; Knight v. State, 402 So. 2d 435 (Fla. 3d DCA 1981). See also Kearse v. State, 662 So. 2d 677, 685 (Fla.1995). Hence, reversal on this basis is inappropriate. Because the state presented independent evidence of corpus delicti, we conclude that the court properly admitted Williams’…
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State v. Hepburn, 460 So. 2d 422 (Fla. 5th DCA 1984)…t is a correct statement of the law that before a defendant’s confession is admissible in evidence the state must prove with substantial evidence the corpus delicti of the offenses charged. State v. Allen, 335 So. 2d 823 (Fla.1976); Knight v. State, 402 So. 2d 435 (Fla.3d DCA 1981); Nelson v. State, 372 So. 2d 949 (Fla. 2d DCA 1979), cert. denied, 396 So. 2d 1130 (Fla.1981); McQueen v. State, 304 So. 2d 501 (Fla. 4th DCA 1974), cert. denied, 315 So. 2d 193 (Fla.1975); Farley v. City of Tallahassee, 243 So. 2d…
Previewing 3 of 8 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Smith v. United States, 348 U.S. 147 (U.S. 1954)
- State v. Allen, 335 So. 2d 823 (Fla. 1976)
- Jenkins Lambright and Albert Stevens v. State, 34 Fla. 564 (Fla. 1894)
- Elliot Tucker v. State, 64 Fla. 518 (Fla. 1912)
- Ruiz v. State, 388 So. 2d 610 (Fla. 3d DCA 1980)
- McQUEEN v. State, 304 So. 2d 501 (Fla. 4th DCA 1974)
- State v. Snowden, 345 So. 2d 856 (Fla. 1st DCA 1977)
- Ussery v. State, 382 So. 2d 380 (Fla. 3d DCA 1980)
- Alvarez v. State, 403 So. 2d 1005 (Fla. 3d DCA 1981)