Smith's Criminal Case Compendium
Table of Contents
State v. Messer, ___ N.C. App. ___, 806 S.E.2d 315 (Oct. 3, 2017)
The trial court did not err by denying the defendant’s motion to dismiss a charge of armed robbery asserting that the State failed to establish the corpus delicti of the crime. Specifically, the defendant argued that the State relied solely on his uncorroborated confession, which, under the corpus delicti rule, was insufficient to establish guilt. Rejecting the defendant’s argument, the court also rejected the notion that the corpus delicti rule requires non-confessional evidence of every element of a crime. Citing prior case law, it concluded that the State need only show corroborative evidence tending to establish the reliability of the confession. Here, the State presented evidence that aligned with the defendant’s confession, including, among other things, the medical examiner’s determination as to cause of death; the recovery of a firearm at the scene; and DNA evidence.