California, United States of America
The following excerpt is from People v. Huynh, D060327 (Cal. App. 2012):
caused by a criminal agencymust be established independently of the extrajudicial statements, confessions or admissions of the defendant." (People v. Towler (1982) 31 Cal.3d 105, 115.)10 The corpus delicti of murder consists of the death of the victim and a criminal agency as the cause of that death. (People v. Small (1970) 7 Cal.App.3d 347, 354.)
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