Is there sufficient evidence to satisfy the corpus delicti rule except J. R.'s inadmissible statements?

California, United States of America


The following excerpt is from People v. Lewis, C076108 (Cal. App. 2015):

Defendant points to two cases to support his argument that there was no sufficient evidence to satisfy the corpus delicti rule except J. R.'s inadmissible statements. The first is People v. Herrera (2006) 136 Cal.App.4th 1191. In Herrera, the defendant was arrested for stealing a large amount of pseudoephedrine pills and charged with conspiracy to manufacture methamphetamine. (Id. at pp. 1195-1196.) The defendant admitted to the investigating detective that he sold the pills to someone who used them to make methamphetamine. (Id. at p. 1196.) No methamphetamine producing equipment was found in the defendant's home. (Ibid.) The defendant appealed the trial court's decision to deny his motion to dismiss the conspiracy charge arguing that, absent his own statement about his coconspirator, there was insufficient independent evidence to establish the corpus delicti of a conspiracy charge. (Id. at pp. 1196-1197.) In response, the People argued that the large quantity of pills combined with the nonexistence of a methamphetamine lab in the defendant's residence " 'support[ed] an inference that [the defendant] conspired with at least one other person to manufacture methamphetamine.' "

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