United States v. Niebla-Torres, No. 15-10261 (9th Cir. 2017)
Annotate this CaseDefendant was convicted of conspiracy to possess with intent to distribute marijuana. On appeal, defendant argues that the government failed to meet its burden under the Lopez-Alvarez test to evaluate whether the government has met its burden under the corpus delicti doctrine. The court concluded that the government satisfied the first prong by introducing sufficient corroborating evidence that the core conduct of defendant's crime actually occurred. The court also concluded that the government introduced sufficient corroborating evidence to satisfy the second prong. Therefore, defendant's confession was adequately corroborated under the corpus delicti doctrine. The court explained that, because the confession is sufficiently corroborated, viewing all the evidence (including the confession) in the light most favorable to the prosecution, any rational trier of fact could have found beyond a reasonable doubt that defendant knowingly entered into an unlawful agreement to serve as a scout for marijuana traffickers. Accordingly, the court affirmed the judgment.
Court Description: Criminal Law. The panel affirmed a conviction for conspiracy to possess with intent to distribute marijuana, in a case in which the defendant argued that the district court erred by denying his motion for a judgment of acquittal because the government did not introduce sufficient evidence to corroborate his confession under the corpus delicti doctrine. The panel held that the government satisfied both prongs of the corpus delicti test set forth in United States v. Lopez- Alvarez, 970 F.2d 583 (9th Cir. 1992), by introducing sufficient corroborating evidence that the core conduct of the defendant’s crime actually occurred, and sufficient evidence to corroborate the reliability of the videotaped confession and the authenticity of the defendant’s confessed involvement in the conspiracy. The panel addressed other issues in a concurrently-filed memorandum disposition. UNITED STATES V. NIEBLA-TORRES 3
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