State v. Morgan
In State v. Morgan, 204 Ariz. 166, 170, P15, 61 P.3d 460, 464 (App. 2002), the defendant was charged with multiple, closely-related crimes after confessing to police officers. Id. at 169, P6, 61 P.3d at 463.
While independent evidence corroborated the defendant's confession to several of the crimes, the defendant argued on appeal that the corpus delicti rule was violated because two of the charged crimes lacked such corroboration. Id. at 170, P14, 61 P.3d at 464.
The court found that even absent corroborating evidence of these two crimes, the defendant's confession itself was sufficiently corroborated by the direct and circumstantial evidence supporting the other crimes charged to satisfy the corpus delicti rule. Id. at 173, P24, 61 P.3d at 467 (holding that "the confession was sufficiently corroborated to eliminate any concern that it could be untrue, and, thus, supported a 'reasonable inference' that the offense had occurred").
The Morgan court stressed that a confession could be corroborated when "independent evidence . . . bolsters the confession itself and thereby proves the offense 'through' the statements of the accused." Id. at 171, P18, 61 P.3d at 465.