State v. Thompson
In State v. Thompson, 146 Ariz. 552, 557, 707 P.2d 956, 961 (App. 1985), one of the child victims displayed numerous bruises and welts and told officers that the defendant had inflicted the injuries with a belt. 146 Ariz. at 554, 707 P.2d at 958.
The defendant admitted hitting the child with the belt after losing his temper, but claimed to have "caught himself" and stopped. Id. at 555, 707 P.2d at 959.
On appeal, the Court found that the victim's statements to police officers were inadmissible hearsay, but found the error harmless because the defendant's own statements were not barred by the corpus delicti rule as the "multiple bruises on the victim's back and thigh in a pattern consistent with the belt's impact are sufficient to establish the corroboration needed to consider the defendant's own statement." Id. at 557, 707 P.2d at 961.
This evidence was established before the defendant's inculpatory statements were admitted. Id