Miller, Christopher Adrian
2015 Tex. Crim. App. LEXIS 384
| Tex. Crim. App. | 2015Background
- In Nov–Dec 2011, defendant (Appellant) gave multiple extrajudicial confessions — two oral and two written — admitting to four incidents of aggravated sexual assault of his infant daughter over a 27‑day period.
- Police recovered seminal fluid from carpet next to the nursery changing table corroborating one confessed incident (Count Three); forensic examiners could not recover the alleged photo or other digital evidence (deleted/overwritten).
- Appellant was convicted on all four counts at trial and sentenced to life on each count.
- The court of appeals reversed and rendered acquittals on Counts One, Two, and Four, holding the State failed to corroborate those confessions (corpus delicti not established).
- The State sought review, arguing (1) the corpus delicti rule should be abolished, (2) replaced by a trustworthiness standard, or (3) relaxed so that corroboration of one closely related offense can satisfy corpus delicti for other proximate confessed offenses.
- The Texas Court of Criminal Appeals reinstated the convictions, declining to abolish or replace the corpus delicti rule but recognizing a limited "closely related crimes" exception when offenses are temporally proximate and the corroboration of one offense does not frustrate the rule’s protective purpose.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Appellant) | Held |
|---|---|---|---|
| Whether Texas should abolish the corpus delicti rule | Abolish it as obsolete and obstructive given doctrinal developments and safeguards (Miranda, voluntariness rules, recording requirements) | Corpus delicti is longstanding and protects mentally infirm and others who might falsely confess; should not be abolished | Denied — court retains the corpus delicti rule |
| Whether Texas should replace corpus delicti with a trustworthiness standard | Replace with Opper‑style trustworthiness inquiry focused on substantial independent evidence supporting confession reliability | Trustworthiness standard is unnecessary and would erode the long‑standing protection of corpus delicti | Denied — court declines to adopt trustworthiness standard |
| Whether corroboration of one closely related confessed offense can satisfy corpus delicti for other confessed offenses arising in same course of conduct | Corroboration of Count Three (seminal fluid) + close temporal/transactional link among confessions suffices to corroborate the others | Exception would permit circular/confabulating confessions and improperly relax safeguards | Granted in limited form — court recognizes a closely related crimes exception when offenses are sufficiently proximate so the rule’s protective purpose is not violated; applied to reinstate convictions |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for legal sufficiency of evidence under due process)
- Opper v. United States, 348 U.S. 84 (1954) (adopted trustworthiness test for admitting confessions)
- Willoughby v. State, 552 N.E.2d 462 (Ind. 1990) (recognized corroboration of principal offense may suffice for closely related offenses)
- Pennsylvania v. Verticelli, 706 A.2d 820 (Pa. 1998) (described closely related crimes exception where statement admissible for all charged crimes if relationship is sufficiently close)
- Carrizales v. State, 414 S.W.3d 737 (Tex. Crim. App. 2013) (discussing corpus delicti rule and its purpose)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (addressing sufficiency review and referenced by parties concerning corpus delicti)