People v. Armitage

In People v. Armitage (1987) 194 Cal.App.3d 405, the defendant who was convicted of drunk boating was seen leaving a bar with the victim, and witnesses later saw a boat being operated in an unsafe and reckless manner with two boisterous men on board. (People v. Armitage, supra, 194 Cal.App.3d at p. 422.) The court found ample evidence of the corpus delicti, holding that "since both men were drunk it was immaterial which one of them was actually operating the boat at the time of the accident. In all events, it was being operated in an illegal manner by someone who was drunk. . . . The victim drowned after the accident. Defendant was later observed soaking wet and intoxicated near the river . . . . Consequently, the corpus delicti of the crime of drunk boating causing death was sufficiently shown." (Id. at pp. 422-423.)