State of West Virginia v. William L.E., 14-1055

In May 2013 a four‑year‑old child reported to his mother that his father, petitioner William L.E., had touched his penis after a visitation. The mother reported the allegation to the State Police.
Corporal Louden interviewed the child; the child described the father touching his penis with a sideways hand motion. That interview was used to explain police actions, not for truth.
Officers interviewed petitioner at his home; petitioner gave a written statement saying the child had slept in bed with him and that he had masturbated with the child in the bed and may have touched the child while asleep.
After arrest petitioner waived Miranda and made a recorded statement describing actively placing his hand over the child’s hand and teaching the child to masturbate; he admitted direct contact lasted about five minutes. Both statements were admitted at trial and petitioner’s suppression motion was denied.
A clinical psychologist who evaluated and treated the child testified the child exhibited signs consistent with sexual abuse (attachment issues, anxiety, mood/behavior changes). Petitioner testified denying abuse and suggesting the mother made false accusations.
A jury convicted petitioner of first‑degree sexual abuse and sexual abuse by a parent; petitioner challenged sufficiency of the evidence on appeal, arguing the State failed to establish corpus delicti independent of his confessions.

Issue	Plaintiff's Argument (State)	Defendant's Argument (William)	Held
Whether corpus delicti was proved beyond a reasonable doubt so confessions could be used for conviction	The confessions were corroborated by independent evidence: the clinical psychologist’s testimony that the child exhibited specific signs of sexual abuse; physical evidence or the child’s courtroom testimony is not required	The only evidence of abuse was petitioner’s extrajudicial confessions; absent physical/medical evidence or the child’s testimony, the State failed to prove corpus delicti	Court held the psychologist’s expert testimony was material and substantial corroboration of the confessions and, taken together, established the corpus delicti and supported the convictions

State v. LaRock, 196 W. Va. 294 (de novo sufficiency review standard for judgment of acquittal)
State v. Guthrie, 194 W. Va. 657 (appellate standard: view evidence in light most favorable to prosecution)
State v. Blackwell, 102 W. Va. 421 (corroboration rule: confession must be corroborated by evidence aliunde of corpus delicti)
State v. Garrett, 195 W. Va. 630 (corroboration need not be conclusive; sufficient if, with confession, it establishes crime beyond reasonable doubt)
State v. Walter, 188 W. Va. 129 (reversal where absolutely no evidence of required element such that convictions must be vacated)
State v. Murray, 180 W. Va. 41 (post‑assault condition of child is relevant to prove corpus delicti)