State Of Washington v. Lafe William Hotchkiss, Ii, 48963-5

Police executed a search warrant at Hotchkiss’s Vancouver residence and found 8.1 grams of methamphetamine and $2,150 in a safe.
During the search Hotchkiss told officers he had an “8‑ball,” procured about one 8‑ball per day, broke it down, and had about 10 customers.
At trial Hotchkiss admitted to personal meth use (3–4 grams/day with a roommate), said the cash was rent and wages, and claimed the selling statements referred to conduct 20 years earlier.
A rebuttal officer testified typical meth doses are 0.2–0.4 grams and it would be very rare to possess eight grams solely for personal use.
The trial court applied the corpus delicti rule, found the meth amount combined with the cash corroborated the incriminating statement, and convicted Hotchkiss of possession with intent to deliver; Hotchkiss appealed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hotchkiss)	Held
Whether independent evidence satisfied the corpus delicti rule to corroborate Hotchkiss’s statement that he intended to deliver methamphetamine	Meth quantity (8.1 g → ~20–40 doses) plus $2,150 cash next to the drugs provide independent corroboration of intent to deliver	The corpus delicti rule requires independent evidence inconsistent with an innocent explanation; cash and drugs are consistent with rent, wages, and personal use	The court held the meth quantity combined with the cash was sufficient independent corroboration under the corpus delicti rule, so the statement was admissible and the conviction was affirmed

State v. Green, 182 Wn. App. 133 (2014) (corpus delicti requires independent corroboration of incriminating statements)
State v. Dow, 168 Wn.2d 243 (2010) (defendant’s statements alone cannot establish that a crime occurred)
State v. Aten, 130 Wn.2d 640 (1996) (independent evidence need only support a logical inference that the charged crime occurred)
State v. Brockob, 159 Wn.2d 311 (2006) (independent evidence must support criminal explanation rather than equally reasonable innocent explanation)
State v. O’Connor, 155 Wn. App. 282 (2010) (possession plus another factor — e.g., large cash — can support inference of intent to deliver)
State v. Whalen, 131 Wn. App. 58 (2005) (possession plus an additional factor can satisfy corpus delicti for intent-to-manufacture/distribute charges)
State v. Cobelli, 56 Wn. App. 921 (1989) (mere possession of controlled substance is insufficient to infer intent to deliver)
State v. Campos, 100 Wn. App. 218 (2000) (large drug quantity plus cash supports inference of distribution)
State v. Hagler, 74 Wn. App. 232 (1994) (cash contemporaneous with drugs can be probative of intent to distribute)
State v. Lane, 56 Wn. App. 286 (1989) (quantity sufficient for multiple sales together with cash supports distribution inference)