Armstrong v. State
In Armstrong v. State, 502 P.2d 440 (Alaska 1972) the supreme court acknowledged that there was a "wide diversity" in the formulation of the corpus delicti rule among American jurisdictions. Id. at 447.
The supreme court then declared:
The proper and most workable corpus delicti rule is the one laid down for the federal courts in Opper v. United States, 348 U.S. 84, 75 S.Ct. 158, 99 L.Ed. 101 (1954), where the Supreme Court held that the corroborative evidence need not be sufficient, independent of the defendant's statements, to establish the criminal act. Rather, the prosecution must introduce "substantial independent evidence which would tend to establish the trustworthiness of the defendant's statement." Id., 348 U.S. at 93, 75 S.Ct. at 164, 99 L.Ed. at 109. (Armstrong, 502 P.2d at 447.)