Does the corpus delicti rule require corroboration of a criminal injury?

California, United States of America


The following excerpt is from People v. Alvarez, 119 Cal.Rptr.2d 903, 27 Cal.4th 1161, 46 P.3d 372 (Cal. 2002):

Notwithstanding the assumption of the parties and the lower courts that the corpus delicti rule required corroboration of not only a criminal injury but also the mental element of lewd intent (see maj. opn., ante, 119 Cal.Rptr.2d at p. 910, 46 P.3d at p. 378), we have long held otherwise. "All that need be shown by independent evidence ... is that a crime has been committed by someone." (People v. Cobb (1955) 45 Cal.2d 158, 161, 287 P.2d 752.)

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