Colorado v. LaRosaAnnotate this Case
Defendant Jason LaRosa confessed to his wife, mother, pastor, a police dispatcher and an investigating police officer that he had sexually assaulted his two year old daughter. He was charged with multiple crimes, and a jury convicted him on all charges. On appeal, an appellate panel reversed Defendant's convictions under the corpus delicti rule, reasoning that the prosecution had presented only opportunity evidence (other than the confessions) establishing that Defendant had an opportunity to commit crime, but not that the crimes in fact, occurred. The State appealed that decision. The issue before the Supreme Court required the Court to decide whether to abandon the judicially created "corroboration requirement," the corpus delicti rule, and all of the attendant precedent. After review the Court decided to abandon the corpus delicti rule because "sound reasons exist[ed] for doing so." In its place, the Court articulated "the trustworthiness standard," requiring the prosecution to present evidence that proves a confession is trustworthy or reliable. The Court affirmed the appellate court's decision to reverse Defendant's convictions because having consistently applied the corpus delicti rule as substantive law for over one hundred years, Defendant did not have fair warning of the Court's decision to abandon it. Therefore the Court was constitutionally prohibited from applying the new trustworthiness standard in this case.