State v. Villa
In State v. Villa, 179 Ariz. 486, 880 P.2d 706 (App. 1994), the defendant was convicted of driving under the influence of intoxicating liquor while his license was suspended.
He argued that he was entitled to a directed verdict of acquittal because the only evidence that his license was suspended was his uncorroborated confession.
The Court found that the State had presented sufficient independent evidence of the license suspension to permit the admission of the confession. Id. 179 Ariz. at 488, 880 P.2d at 708.
Then it stated in dicta that, even without the evidence, the State had established the corpus delicti.
However, the court also noted that the prosecution had established the underlying offense of driving while intoxicated and that the State was not required to present independent evidence regarding the additional element of the license suspension, which affected the degree of the offense, before admitting the defendant's confession. Id.