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Washington Court Analyzes the Rule of Corpus Delecti

On Behalf of | May 21, 2019 | Evidence

In any Washington criminal case, there are procedural and evidentiary rules with which both the State and the defendant must comply. If a defendant is convicted based on evidence introduced by the State at trial that lacks a proper foundation or was improperly obtained it can result in a reversal of a conviction. A Washington Court of Appeals recently addressed the issue of whether the evidentiary rule of corpus delecti applies in a case in which the defendant entered a guilty plea for robbery in the first degree with a firearm enhancement. If you are a resident of Washington and are currently charged with a crime that includes a firearm enhancement it is important to meet with a skillful Washington weapons charge defense attorney to discuss the impact the firearm enhancement may have on your case and what evidence the State needs to obtain a conviction.

Factual Background of the Case

Reportedly, in November 2015, the defendant and another person broke into the home of an elderly man with the intent of robbing the man. Upon entering the home, one of them forced the elderly man to the ground, pointed a gun at him and demanded he relinquish his property, while the other person searched the property. The defendant and his co-conspirator ultimately left the elderly man’s home with a substantial amount of property, after which they were arrested. The defendant was charged with first-degree robbery with a firearm enhancement, first-degree burglary, and unlawful imprisonment.

It is alleged that the defendant’s attorney advised the defendant that he would probably lose if the case proceeded to trial and would receive a substantial sentence. Thus, the defendant pleaded guilty, advising the court that he entered his plea knowingly and voluntarily. The defendant subsequently appealed his conviction, arguing in part that his conviction violated the corpus delecti rule.

Corpus Delecti Rule in Washington Criminal Cases

The rule of corpus delecti, which means “body of the crime,” requires the State to introduce certain evidence at trial prior to introducing a defendant’s confession of a crime. Specifically, the rule requires the State to present evidence that a specific injury occurred and a criminal act most likely caused the injury. The rule is meant to protect criminal defendants against convictions that are based on false confessions.

In the subject case, the court found that the rule of corpus delecti did not apply due to the fact that the defendant entered a guilty plea. The court explained that because a guilty plea bypasses a trial it results in the waiver of a defendant’s constitutional rights during a trial, including the right against self-incrimination. Rather, in entering a guilty plea a defendant admits he or she is factually and legally guilty and waives the right to challenge the sufficiency of the State’s evidence. As such, the court affirmed the defendant’s conviction.

Retain a Knowledgeable Washington Weapons Charges Defense Attorney

If you are charged with a crime that includes a firearm enhancement it is critical to engage a knowledgeable Washington weapons charges defense attorney to assist you in protecting your liberties. The trusted weapons charge defense attorneys of the Law Offices of Smith & White will assertively advocate on your behalf to help you seek the best legal outcome possible under the unique facts of your case. We can be reached at 253-363-8662 or via our online form to schedule a free and confidential meeting to discuss your case.