Pierce v. State

Horntjy, J.,

filed the following concurring opinion.

The effect of the majority opinion is to hold that in all manslaughter by automobile cases there has been sufficient proof of the corpus delicti when it has been shown that the death of the victim was the result of the operation of the automobile by someone in a grossly negligent manner. To me, the showing of these two elements (conceded by the defendant) was not enough to establish the “body of the crime” in this case. For, under the unusual circumstances of this tragic automobile accident, it is certain that had the deceased been operating the lethal instrument at the time of the accident, a crime could not have been committed. Contrary to the majority, it is my opinion that in this case a third fact or element had to be shown in order to fully establish the corpus delicti.

Since the term corpus delicti means the substantial and fundamental facts that are necessary to show that a crime has been committed, it seems apparent to me that in order to establish the body of the crime with certainty, it should not only be shown that the defendant was operating the automobile at the time of the accident as the extrajudicial statements of the defendant indubitably admit, but that that admitted fact must also be corroborated by some evidence from a source other than the admissions of the defendant.

It being conceded that there was ample evidence to support a finding that the automobile involved in the accident was then-being operated in a grossly negligent manner, the real question is whether the evidence produced was sufficient in law for the trial court to find beyond a reasonable doubt that the defendant was operating the automobile when the accident happened.

We are in agreement that there was sufficient evidence to-justify the conviction of the defendant, but we do not agree as to how that result should have been reached. We further *228agree that extrajudicial statements made by an accused, whether they be confessions or admissions (as they were in this case), must be corroborated unless they come into the evidence (as they did here) without objection. And, though we disagree as to what are the component elements of the corpus delicti, we also agree in principle that the rules governing the corroboration of extrajudicial statements in this State —as they are set forth in such cases as Wood v. State, 192 Md. 643, 65 A. 2d 316 (1949) ; Davis v. State, 202 Md. 463, 97 A. 2d 303 (1953); Hall v. State, 213 Md. 369, 131 A. 2d 710 (1957) ; and Cooper v. State, 220 Md. 183, 152 A. 2d 120 (1959)—recognize, among other things, that the corroborating circumstance need not establish the corpus delicti beyond a reasonable doubt; that the corpus delicti may be proved by circumstantial evidence when direct evidence is not available; that proof of the corpus delicti need not be full and positive but may be established by the circumstances of each particular case; and that the corroborating evidence is sufficient to establish the corpus delicti if, when considered in connection with the confession or admission, it satisfies the trier of fact beyond a reasonable doubt that the offense charged was committed and that the accused committed it.

The rule in this and most other jurisdictions goes even further in that the evidence in corroboration of an extrajudicial statement need not connect the defendant with the crime charged: his connection therewith may be shown by his statement without corroboration on that point. Weller v. State, 150 Md. 278, 132 Atl. 624 (1926). But in a case such as this, where one of the elements of the corpus delicti is intangible— in that it cannot be definitely established that a crime has been committed other than by the admissions of the defendant—it is my belief that this general rule is inapplicable here, and that the accused should not be convicted unless there is some evidence aliunde the statements (as there was in this case) to fortify the truth of the admissions that the defendant was the -operator of the automobile. See the Annotation, “Corroboration of Extrajudicial Confession or Admission,” 45 A.L.R. 2d 1316, 1322, [§ 4]. See also Smith v. United States, 348 U. S. 147 (1954) ; Tabor v. United States, 152 F. 2d 254 (1945); *229and compare the majority and dissenting opinions in Smyly v. United States, 287 F. 2d 760, 763 (1961).

In the instant case, where there was some evidence from another source—to the effect that the deceased was seated on the passenger side of the automobile when the accident occurred—tending to substantiate the fact that the defendant (as he had admitted) was operating the automobile, it was not improper for the trial court to consider the admissions in connection with that evidence (even though it was circumstantial and unpositive), and the inference deducible therefrom, in deciding that the corpus delicti had been established to its satisfaction beyond a reasonable doubt. Cf. Davis v. State, supra, (202 Md. at p. 471). And, when that had been done, there was clearly no doubt as to the guilt of the defendant.