State v. Puckett
191 Ohio App. 3d 747
Ohio Ct. App.2010Background
- Appellant Darrell A. Puckett was convicted of one count of rape and sentenced to life imprisonment without parole.
- Three counts of rape were charged based on three separate time frames/incidents; two counts were dismissed during trial for lack of corpus delicti.
- The alleged 2009 rape occurred on August 18, 2009; the victim was a two-to-three-year-old grandchild of appellant.
- The State presented a taped confession by appellant and testimony from the victim’s mother and others, plus a medical examination with no conclusive physical findings.
- The court found corpus delicti proven for the 2009 count based on (a) a statement to appellant’s son and (b) the mother’s actions leading to hospital admission and examination; other counts lacked sufficient independent evidence.
- Appellant challenged admissibility of the confession for lack of independent corpus delicti evidence; the trial court admitted the confession for the third count.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether corpus delicti was shown before admitting the confession | Puckett: corpus delicti not proven independent of confession | Puckett: confession should be excluded if corpus delicti lacking | Confession admitted; corpus delicti shown for at least the 2009 count |
| Whether the conviction is against the manifest weight or is supported by sufficient evidence | Puckett: weight/sufficiency insufficient aside from confession | Puckett: confession plus other evidence establishes guilt | Conviction not against weight; evidence sufficient to support rape charge |
Key Cases Cited
- State v. Edwards, 49 Ohio St.2d 31 (1976) (corpus delicti requires some independent evidence)
- State v. Maranda, 94 Ohio St.364 (1916) (minimal independent evidence required to admit confession)
- State v. Kraft, 2007-Ohio-2247 (Hamilton App. 2007) (information source can be circumstantial; corpus delicti may be proven by surrounding facts)
- State v. Edinger, 2006-Ohio-1527 (Franklin App. 2006) (child-victim context; corroborative circumstantial evidence suffices)
- In re W.B. II, 2009-Ohio-1707 (Highland App. 2009) (corpus delicti standard and independence of outside evidence)