Roach v. Commonwealth

In Roach v. Commonwealth, 251 Va. 324, 468 S.E.2d 98, 110 (Va. 1996), the court held that because both the corpus delicti of a homicide and the corpus delicti of robbery were established by independent evidence, the corpus delicti of capital murder was sufficiently corroborated. Thus, Virginia requires corroboration of the predicate offense and the homicide to establish the corpus delicti of capital murder. See id.