State v. Cox, 367 N.C. 147

Police conducted a DWI checkpoint; a Chevrolet Impala attempted to avoid it and parked in a driveway. Three passengers remained in the car, including defendant (front passenger). The driver fled on foot.
Officers found a loaded firearm and packaged marijuana in the yard about 10–12 feet from the driver’s side door; another firearm was found at a rear passenger’s feet inside the car. The outside firearm was warm and dry despite wet grass.
At the magistrate’s office, after Miranda warnings, defendant orally admitted the firearm found outside belonged to him; the group sought to avoid charging defendant’s younger brother. Defendant waived counsel in writing.
State charged defendant with possession of a stolen firearm (later dismissed), possession of a controlled substance, and possession of a firearm by a felon; jury convicted on the latter two counts.
Court of Appeals reversed on the firearm-by-a-felon charge, holding the State failed to provide corroborative evidence required by the corpus delicti rule. Supreme Court granted review to consider corpus delicti application under Parker and traditional tests and whether the confession was corroborated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether corpus delicti is satisfied so defendant's extrajudicial confession may be used to prove possession of a firearm by a felon	State: independent evidence (gun near car, warm/dry, marijuana packaging, flight, opportunity) corroborates trustworthiness of confession under Parker	Cox: corroboration insufficient; State must provide evidence tending to show defendant (not just the crime) possessed the gun; other occupants could have possessed it	Reversed Court of Appeals. Under Parker, independent evidence tending to establish confession’s trustworthiness (including opportunity) satisfied corpus delicti; confession plus prior felony conviction sufficed to survive dismissal.

State v. Parker, 315 N.C. 222 (adopted Parker rule allowing conviction on confession supported by substantial independent evidence tending to establish its trustworthiness)
State v. Trexler, 316 N.C. 528 (discussed Parker and corroboration alternatives)
State v. Sloan, 316 N.C. 714 (explained availability of traditional or Parker corpus delicti formulations)
State v. Butler, 356 N.C. 141 (application of "light most favorable to the State" standard when others could have placed contraband)
State v. Miller, 363 N.C. 96 (definition of substantial evidence)
State v. Sweat, 366 N.C. 79 (recent corpus delicti guidance cited on review)
State v. Bradshaw, 366 N.C. 90 (statutory elements and sufficiency review for firearm-by-felon charge)
State v. Powell, 299 N.C. 95 (contradictions are for the jury; motion-to-dismiss standard)