Corpus Delicti Definition

In criminal cases a court describes the commission of a crime as the corpus delicti. See People v. Lara, 2012 IL 112370, ¶ 17. That just means a court acknowledges that something happened that was criminal in nature.

In order to obtain a valid conviction, the State must prove both the corpus delicti and the identity of the person who committed the offense.

In other words, in all criminal prosecutions the state must prove two things. They must establish that a crime happened (the corpus delicti). Then they must prove-up the accused is the person who did it.

The Corpus Delicti Rule

Rather, where a defendant’s confession is part of the proof of the corpus delicti, the State must also provide independent corroborating evidence.

Another way to think about the corpus delicti rule is that it is saying that a defendant cannot be convicted based entirely on a confession.

Corpus Delicti Example

Say a defendant walks into a police station and tells police he has just committed a murder.

That person’s conviction in court would require much more than just their word that they killed somebody. The police would have had to confirm that a murder happened with independent corroborative evidence.

Say, for example finding the body.

Corpus Delicti Rule Requires Independent Evidence

Under the corpus delicti rule, the independent evidence need only tend to show the commission of a crime. It need not be so strong that it alone proves the commission of the charged offense beyond a reasonable doubt.

The corpus delicti rule requires only that the corroborating evidence correspond with the circumstances recited in the confession and tend to connect the defendant with the crime. 

The independent evidence need not precisely align with the details of the confession on each element of the charged offense, or indeed to any particular element of the charged offense.

Corpus Delict Example From The Case Law

Consider the case of People v. Sanchez, 2019 IL App (3d) 160643  (March). Episode 608 (Duration 9:08).

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Defendant is arrested at his home where he was found intoxicated and driven back to the crash scene by police.

Accident Scene

Police found a vehicle had been driven up a raised median separating the roadway from the sidewalk.

The officer looked up the vehicle’s registration number and learned that the vehicle was registered to defendant who resided approximately 3½ blocks from the site of the collision.

The officer proceeded to the residence and made contact with defendant.

Defendant Located

The officer testified that defendant’s eyes were glassy, his speech was slurred, he staggered and stumbled when he walked, and a strong odor of an alcoholic beverage emanated from his breath.

Defendant told The officer that he was driving the vehicle involved in the collision. Defendant said that he went home after the collision.

No Field Sobriety Tests

The officer asked defendant to take field sobriety tests.

Defendant refused.

Corpus Delicti Issue

Defendant argues that his conviction for DUI should be reversed because the State failed to prove that he was under the influence of alcohol at the time of the motor vehicle collision under the corpus delicti rule.

While defendant admits that there was sufficient corroborating evidence that he drove the vehicle involved in the collision, he contends that the only evidence that he consumed alcohol before driving the vehicle were his own uncorroborated statements on the squad car video recording.

Analysis

Here, the squad car video recording showed that defendant admitted that he drove onto the raised median while driving home from Puerto, where he had been drinking.

The evidence, independent of defendant’s statements, showed that:

(1) A vehicle registered to defendant was discovered driven onto a raised median on a bridge
(2) The officer located defendant at his residence, which was 3½ blocks from the site of the collision
(3) When the officer located defendant, defendant displayed signs of intoxication, including glassy eyes, slurred speech, stumbling while walking, and a strong odor of an alcoholic beverage on his breath and
(4) defendant was in possession of the keys to the vehicle involved in the collision.

The court said there was independent corroborating evidence was sufficient to satisfy the corpus delicti rule.

Holding

Because there was sufficient independent corroborating evidence to satisfy the corpus delicti rule, defendant’s admissions were properly considered by the circuit court along with the independent evidence.

When viewed in the light most favorable to the State, a reasonable trier of fact could find that this evidence was sufficient to prove beyond a reasonable doubt that defendant drove a motor vehicle while under the influence of alcohol.

The State presented sufficient independent evidence to corroborate defendant’s out-of-court statements such that the admission of these statements did not violate the corpus delicti rule.

DUI conviction affirmed.

See Also

Episode 588 – People v. Day, 2019 IL App (4th) 160217 (January) (defendant is arrested miles away walking in the street and he made up a story that his friend was driving)