In a criminal law matter, the Appellate Court of Connecticut affirmed a defendant’s conviction following the strangulation murder of a woman, despite the defendant’s argument that his conviction violated the rule of corpus delicti, because the defendant’s confession was sufficiently corroborated by evidence that a crime actually occurred.
This case arose from an incident that occurred on January 2, 1998 in Hartford, CT. The defendant called an escort service to set up an arrangement before leaving his home in search of narcotics. He was stabbed multiple times following a failed robbery attempt, after which Good Samaritans treated his wounds and drove him home. The escort (the victim) arrived at the defendant’s residence and called her boss from inside, stating she was going to leave. When she stated her intention to the defendant, he blocked the entrance and a lengthy physical struggle ensued, during which he suffocated the victim.
The defendant transported the victim’s body in her own car to Suffield, where he disposed of it in a wooded area. Upon returning to Hartford, he traded the car to two drug dealers for $50 worth of cocaine and then saw various family members for treatment of his injuries and to request that his apartment be cleaned out. Afterwards, the defendant fled to Massachusetts.
A missing person’s report was filed by the victim’s daughters, and telephone records directed investigators to the victim’s boss, who told them the victim was with the defendant on the night she disappeared. Officers then went to the defendant’s apartment, where the front door was open, bloodstains were on multiple pieces of furniture, and a gold hoop earring similar to one owned by the victim was located underneath the bed.
Conviction based on Confessions
The defendant was tracked down in Massachusetts, where he was in prison for other offenses. On three occasions, he confessed to strangulating the victim and disposing of her body. He twice showed police to the wooded area in Suffield, and skeletal remains were recovered. The remains were identified as belonging to the victim, and a medical examiner cited “homicidal violence” as the cause of death. In addition, the medical examiner found that “the remains recovered were consistent with someone who had been killed by strangulation.”
The defendant was subsequently convicted of manslaughter in the first degree, felony murder, kidnapping in the first degree, and larceny in the third degree. On appeal, he challenged the sufficiency of the evidence to convict, in part [uniquely] because the state “failed to present substantial independent evidence that indicated that his confessions were true.” As such, the State’s case “based solely on his uncorroborated confessions… failed to comply with the rule of corpus delicti.”
Compliance with Corpus Delicti
Under the rule of corpus delicti, out-of-court confessions cannot be the sole basis for a conviction. Instead, the confession must be corroborated by proof that a crime in fact had occurred. However, many jurisdictions, including Connecticut, have moved away from this doctrine and adopted the trustworthiness doctrine. Direct corpus delicti proof is not required if there is “substantial independent evidence which would tend to establish the trustworthiness of the [defendant’s] statement.”
In this case, the Appellate Court found that there was sufficient independent evidence which established the trustworthiness of the defendant’s confessions. He led police to where the victim’s skeletal remains were located, and the medical examiner concluded death was not natural but the result of homicidal violence consistent with strangulation.
Additional support came from the discovery of the victim’s earring, as well as the boss’s testimony and telephone records. All of this taken together established that a crime did take place, and that the defendant was the perpetrator. Therefore, this aspect of the defendant’s insufficiency of the evidence claim failed, and after addressing additional matters on appeal, the judgment was affirmed.
Written by Lindsay E. Raber, Esq.
When faced with a charge of a homicide crime, kidnapping, or larceny, an individual is best served by consulting with an experienced criminal law practitioner. Should you have any questions regarding criminal defense, please do not hesitate to contact Attorney Joseph C. Maya in the firm’s Westport office in Fairfield County at 203-221-3100 or at JMaya@Mayalaw.com.