Corpus Delicti Evidence Example Case in California
In People v. Johnson (1991) 233 Cal. App. 3d 425, the victim vanished under circumstances suggesting she intended to return to work that day. She left behind all her personal effects and never contacted her family. The records of the Internal Revenue Service reflected no activity under her social security number after the last day she was seen. While not eliminating every other possibility, these facts were sufficient to create a reasonable inference the victim died by criminal agency.
In People v. Johnson, supra, 233 Cal. App. 3d at p. 442, defendant was convicted of second degree murder. Defendant and the victim, Adrianne, lived together for three years but never married. Adrianne's family knew defendant slapped and punched her. Adrianne disappeared when she briefly left her work at a convalescent hospital to go home and change into her uniform. Defendant reported the disappearance and cooperated with the police, but also gave inconsistent statements about her possible fate. Defendant claimed Adrianne frequently hitchhiked rides and thought she might have left with a stranger, but there was no evidence she actually engaged in this activity. Defendant told various friends that someone saw two men pull Adrianne into a truck, but he never gave this information to the police. Adrianne's body was never found. ( Id. at pp. 434-437)
Five years later, defendant married and moved to another state. Defendant repeatedly beat his wife and threatened to kill her, and said "that what had happened to Adrianne would happen to her." ( Id. at p. 435.) Defendant's wife escaped to a battered women's shelter, and reported that defendant claimed he had killed Adrianne and he could kill her, too. (Ibid.)
Johnson held there was sufficient evidence of the corpus delicti to permit the introduction of defendant's inconsistent and incriminating statements. ( People v. Johnson, supra, 233 Cal. App. 3d at pp. 439-442.) Johnson also held the trial court properly admitted evidence that defendant beat his wife to establish motive, intent, and identity, pursuant to Evidence Code section 1101, subdivision (a). Defendant's beating of his wife, considered in light of his simultaneous statement that what happened to Adrianne would happen to her, was probative of and necessary to establish the motive, intent, and the identity of Adrianne's killer. ( Id. at p. 444.) "Instances of defendant's abuse of Adrianne and his wife present similar features and invite the conclusion that his intent in each situation was the same." ( Id. at p. 445.)
". . . Defendant's properly admitted threats . . . illuminate his intent both in the beating of his wife and in the killing of Adrianne. The fact of the beating, in turn, sheds light on the significance of the statement that what happened to Adrianne would happen to his wife. Defendant verbally linked his violent abuse of his wife to the murder of Adrianne. The jury could logically infer from this and the other indications of his violence toward Adrianne that he harbored a murderous intent and motive toward both women." ( People v. Johnson, supra, 233 Cal. App. 3d at p. 445.)