State v. Janise
In State v. Janise, 116 Ariz. 557, 570 P.2d 499 (1977), the defendant had submitted the case to the trial court to decide based on a police report that contained his inculpatory statements. Id. at 558, 570 P.2d at 500.
On appeal, the supreme court agreed with the defendant that if the "police departmental report lacked sufficient independent evidence to warrant a reasonable inference that the crime charged was actually committed by some person, then appellant's 'confession' in the report could not be used." Id. at 559, 570 P.2d at 501.
Applying the corpus delicti rule, the court found there was independent evidence to support the conviction. Id.
Addressing a different issue--whether the defendant had to be advised of the possible range of sentence before the case could be submitted to the trial court--the supreme court stated that submitting the case to the court based on the report was "tantamount to a plea of guilty." Id. at 558, 570 P.2d at 500.
The defendant was not convicted based on statements he had made in a judicial proceeding.
The trial court had relied on the defendant's extrajudicial statements to support the finding of guilt. For that reason, independent, corroborating evidence was required to support the conviction.