People v. Lara, 2012 IL 112370

Defendant Lara was tried on two counts of predatory criminal sexual assault of a child (PCSA) based on an 8-year-old victim, J.O.
Defendant confessed to two acts of penetration and touching the victim’s vagina; penetration is the distinguishing element between PCSA and ACSA.
J.O. provided interview statements and later testified, describing two nighttime incidents consistent with the confession.
Appellate Court reversed, holding that independent corroboration of the penetration element was required; convictions reduced to aggravated criminal sexual abuse (ACSA).
State sought review; Supreme Court held that independent corroboration of every element is not required; the confession may be corroborated by evidence tending to show the crime and relating to the confession.
The case remanded for consideration of related issues not reached by the appellate court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether corpus delicti requires corroboration of every element	State contends not every element needs separate corroboration	Lara argues corroboration of penetration is required	No; corroboration need only tend to connect the defendant with the crime and correspond to the confession
Whether corroboration of one closely related act suffices for multiple PCSA counts against the same victim	State argues corroboration of related acts can support multiple charges	Lara argues Sargent requires separate corroboration per act	Yes; corroboration may suffice for multiple closely related acts; convictions reinstated
Whether the trial court properly admitted the confession without requiring full corroboration of each element	Confession admissible with corroborating circumstances	Overly strict corroboration would undermine confession reliability	Confession admissible with corroboration tending to prove corpus delicti; not all elements must be independently proven

People v. Sargent, 239 Ill. 2d 166 (2010) (corpus delicti requires corroboration related to the specific events; multiple offenses may affect corroboration needs)
People v. Dalton, 91 Ill. 2d 22 (1982) (age as immutable characteristic exempt from corroboration; limits to that rule's applicability)
People v. Willingham, 89 Ill.2d 352 (1982) (corroboration may be less than beyond-reasonable-doubt; may infer crime from surrounding circumstances)
People v. Perfecto, 26 Ill. 2d 228 (1962) (corroborating evidence need not prove beyond reasonable doubt; must tend to prove corpus delicti and correspond with confession)
People v. Bounds, 171 Ill.2d 1 (1995) (demonstrated corroboration of penetration through circumstantial evidence; no strict element-by-element corroboration)
People v. Stevens, 188 Ill. App. 3d 865 (1989) (conviction sustained when surrounding circumstances tend to establish penetration even without memory of assault)
People v. Cloutier, 156 Ill. 2d 483 (1993) (assess circumstantial evidence and threats; corroboration may be inferred from surrounding circumstances)
People v. Furby, 138 Ill. 2d 434 (1990) (independent evidence need only tend to prove the offense and corroborate confession; exact match not required)
People v. Richmond, 341 Ill. App. 3d 39 (2003) (explored limits of corroboration when acts involve different parts of victim's body)