State v. Keadle, 977 N.W.2d 207

Tyler Thomas, a 19-year-old Peru State College student, disappeared the early morning of Dec. 3, 2010; her body and cell phone were never recovered and she left behind personal documents and a paycheck with no subsequent financial activity.
Joshua Keadle, a fellow student who lived nearby, was the last known person to see Thomas; he admitted picking her up, driving her to the Missouri River, engaging in sexual contact, having a physical altercation, and leaving her at the river.
Investigators observed drag marks near the boat ramp and tire tracks consistent with Keadle’s vehicle; bank surveillance placed Keadle’s vehicle near the campus/river area at relevant times; searches of his vehicle found no blood or Thomas DNA.
Keadle made multiple statements to police and others (including a jailhouse remark) implicating disposal at the dock and researched forensic issues about submerged bodies; he also sought alibis and asked another student to hold a gun for him.
Procedural posture: charged with first-degree murder in 2017, tried in 2020; jury convicted Keadle of second-degree murder and he was sentenced to 71 years to life; on appeal his sole claim was that the evidence was insufficient to establish the corpus delicti of homicide.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence was sufficient to establish the corpus delicti of homicide beyond a reasonable doubt	The State: circumstantial evidence (abrupt cessation of victim’s contacts and finances, drag marks, surveillance, tire tracks) plus Keadle’s admissions and incriminating statements corroborate death by criminal agency	Keadle: no body, no blood/DNA or direct proof of death; conviction rests on his extrajudicial statements and alternative noncriminal explanations (e.g., accidental hypothermia)	Court affirmed: corpus delicti satisfied beyond a reasonable doubt by circumstantial evidence corroborating Keadle’s admissions; body not required; accused’s rule does not bar conviction on circumstantial proof

State v. Edwards, 278 Neb. 55 (corpus delicti can be proven by circumstantial evidence where body is not found)
State v. Golyar, 301 Neb. 488 (circumstantial proof of death and criminal agency from disappearance and corroborative evidence)
State v. Stubbendieck, 302 Neb. 702 (confession may be considered with corroborative evidence to establish corpus delicti)
State v. Olbricht, 294 Neb. 974 (rejecting the accused’s rule requiring the State to disprove every hypothesis but guilt when relying on circumstantial evidence)
State v. Hassan, 309 Neb. 644 (standard of appellate review in criminal sufficiency challenges)