State v. HollAnnotate this Case
The Supreme Court affirmed the decision of the court of appeals affirming in part and reversing in part Defendant's convictions, holding that Minn. Stat. 634.093 requires a defendant's confession to be corroborated by independent evidence reasonably tending to prove that the specific offense charged was committed.
Defendant confessed to committing multiple acts of criminal sexual conduct against his minor stepdaughter. One such incident allegedly occurred when the two were scouting for deer. A jury found Defendant guilty of five counts of criminal sexual conduct, including one count based on the deer-scouting incident. The court of appeals reversed the deer-scouting incident conviction based on a lack of independent evidence corroborating Defendant's confession to that specific incident. The Supreme Court affirmed, holding that the State failed to introduce sufficient evidence to corroborate Defendant's confession to the deer-scouting incident.