State v. Heiges, 806 N.W.2d 1

Samantha Heiges, 19, lived with boyfriend Matlock; pregnancy began around mid-2004; pregnancy unplanned and kept secret.
May 6, 2005: Heiges allegedly gave birth in a bathtub, drowned the live baby, and placed the body in a shoebox later disposed of via garbage chute; Matlock allegedly threatened to harm them if she did not kill the baby.
After the birth, Heiges slept, then attempted suicide by cutting wrists; she later wrote 'Sydney' in the bathroom with her blood.
Matlock denied causing the events and claimed Heiges initiated violence; he did not witness the birth; he testified to cleaning up blood and disputes about disposal.
New Year’s Day 2006: Heiges confessed to a friend, A.B., that she had killed the baby and disposed of the body; A.B. reported the statements to police, leading to an investigation.
Pfaff, a detective, interviewed Heiges; Heiges admitted to the birth, drowning, and shoebox disposal; the State later introduced corroborating evidence and paid for landfill and forensic analyses; Heiges was convicted of second-degree murder in 2008 after trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether postoffense confessions to friends are confessions under 634.03	Heiges’s statements to A.B. and R.C. are confessions to private persons	Postoffense statements to friends are not confessions requiring corroboration	Postoffense confessions to friends are confessions; require corroboration
Whether the postoffense confessions were sufficiently corroborated under 634.03	Friend statements corroborate the later police confession	Corroboration insufficient or improperly applied	Sufficient independent corroboration existed for the attendant facts of the confessions
Whether 634.051 requires independent evidence of death separate from killing	Death and killing facts must be independently established	Death and killing are not severed in meaning of statute; may be same evidentiary stream	634.051 requires independent establishment that death is not solely derived from the defendant’s confession
Whether the overall evidence, including confessions, supports second-degree murder	Confessions plus corroborating evidence prove intent to kill	Challenged corroboration fails or is insufficient to prove death and culpability	Evidence, including confessions and corroboration, suffices to sustain conviction

State v. Vaughn, 361 N.W.2d 54 (Minn. 1985) (definition of confession as admission of guilt)
State v. Propotnik, 280 Minn. 556 (Minn. 1968) (exculpatory statements do not constitute confessions)
State v. M.D.S., 345 N.W.2d 723 (Minn. 1984) (states corroboration purpose and reliability of confessions)
State v. Azzone, 271 Minn. 166 (Minn. 1965) (policy and reliability of corroboration)
State v. Koskela, 536 N.W.2d 625 (Minn. 1995) (acquaintance statements and corroboration analysis)
State v. New, 22 Minn. 76 (Minn. 1875) (confession to agent requires corroboration)
State v. Johnson, 152 N.W.2d 768 (Minn. 1967) (definition of confession as acknowledgment of guilt)
State v. Smith, 264 Minn. 307 (Minn. 1962) (confession requires acknowledgment of guilt)
State v. McClain, 208 Minn. 91 (Minn. 1940) (definition of confession)