In People v. Denis (1990) 224 Cal. App. 3d 563, the Second District was confronted with the question of whether the corpus delicti rule applied to prior crimes evidence. In that case, the defendant was convicted of felony murder and attempted robbery. The defendant admitted to the police that he and his cohort had previously engaged in prior robberies of a similar type to the charged offense. The defendant's statement was admitted in evidence for the limited purpose of demonstrating his intent at the time of the charged crime. ( Id. at p. 566.) In a habeas petition, the defendant argued his trial counsel was ineffective for failing to object to the evidence on the ground that no independent evidence of the defendant's involvement in the prior crimes was provided. The court analyzed six prior Supreme Court opinions, including Robertson, and determined after a "close reading" of the cases that none had used the corpus delicti rule to exclude evidence of prior crimes when offered for the sole purpose of demonstrating the defendant's state of mind at the time of the charged offense. ( Id. at p. 569.)