In Epperly v. Commonwealth, 224 Va. 214, 294 S.E.2d 882 (Va. 1982), the Supreme Court of Virginia considered whether, in the absence of a body and a confession, the evidence was sufficient to support a jury verdict of first-degree premeditated murder.
In that case, the defendant and the victim met at a bar and went to a lake house that belonged to a friend of the defendant.
The victim's sister reported her missing the next evening. The police ultimately arrested the defendant for her murder despite the fact that the victim's body was never found.
In affirming the defendant's conviction for first- degree murder the Virginia Supreme Court noted that a "spattering of tiny droplets of blood through two rooms, the bloodstained clothing, the broken ankle bracelet, the large bloodstain on the carpet, and the disparity of size and strength between the victim and the defendant are all circumstances from which the jury could properly infer that she was subjected to a savage beating, resulting in her death." Epperly, 294 S.E.2d at 892.