JAMES ERIC KNIGHT, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
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A conviction cannot rest solely on a confession, but where independent evidence establishes the corpus delicti of the crime charged, the confession combined with that evidence is sufficient to support conviction.
[1] A conviction may not rest solely upon a defendant's confession, but independent evidence of corpus delicti combined with a confession is sufficient to support conviction…
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“Sufficient evidence of corpus de-licti is not only a predicate to the admission of a confession...but is, as well, a sine qua non of conviction.”
The court established that corpus delicti is a prerequisite both to admitting a confession and to obtaining a conviction.
Knight was charged with first-degree murder and robbery. The victim was found dead from strangulation and battering with his wallet and contents remov…
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DANIEL S. PEARSON, Judge.
Sufficient evidence of corpus de-licti is not only a predicate to the admission of a confession, see State v. Allen, 335 So. 2d 823 (Fla.1976); Ruiz v. State, 388 So. 2d 610 (Fla. 3d DCA 1980); Ussery v. State, 382 So. 2d 380 (Fla. 3d DCA 1980); McQueen v. State, 304 So. 2d 501 (Fla. 4th DCA 1974), but is, as well, a sine qua non of conviction. Tucker v. State, 64 Fla. 518, 59 So. 941 (1912). Accord, Smith v. United States, 348 U.S. 147, 75 S.Ct. 194, 99 L.Ed. 192 (1954); State v. Allen, supra; Lambright v. State, 34 Fla. 564, 16 So. 582 (1894); Ruiz v. State, supra. Thus, Knight’s failure to object to the introduction of his confession on the ground that the corpus delicti was not established is not fatal to his present claim that he was entitled to judgment of acquittal on the robbery count if, as he contends, conviction were rendered on the confession alone. The distinct rule of sufficiency upon which Knight relies is founded on
“... a long history of judicial experience with confessions and in the realization that sound law enforcement requires police investigation which extends beyond the words of the accused. Confessions may be unreliable because they are coerced or induced, and although separate doctrines exclude involuntary confession from consideration by the jury [citations omitted], further caution is warranted because the accused may be unable to establish the involuntary nature of his statements. Moreover, though a statement may not be ‘involuntary’ within the meaning of this exclusionary rule, still its reliability may be suspect if it is under the pressure of a police investigator— whose words may reflect the strain and confusion attending his predicament rather than a clear reflection of his past. Finally, the experience of the courts, the police and the medical profession recount a number of false confessions voluntarily made [citation omitted]. These are the considerations which justify a restriction on the power of the jury to convict, for this experience with confessions is not shared by the average juror.”1
Smith v. United States, 348 U.S. at 153, 75 S.Ct. at 197.
But while Knight did not waive his right to assail his conviction, his attack is unavailing, since there was sufficient evidence to establish, independent of the confession, that the specific crime of robbery charged in the information had been committed.2
All other points on appeal being either without merit or not preserved below, Knight’s convictions for first-degree murder and robbery are
Affirmed.
. 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)