State v. Todd James Suriner
154 Idaho 81
| Idaho | 2013Background
- Todd Suriner, father of twin girls aged ~3.5 in Dec 2008, faced allegations from daughter about his conduct; detective contact and polygraph confession followed shortly after investigation began.
- Defendant confessed in two interviews that he had sexually abused his daughters for about a year, primarily Sundays when wife was at work.
- He was charged with two counts of lewd conduct (Idaho Code 18-1508), tried before a jury, and the State introduced videotaped confessions and jail calls.
- Pediatrician examined the girls; no trauma found, but expert noted many abused children show normal exams; wife testified he was alone with girls on Sundays.
- District court denied acquittal based on corpus delicti; jury found guilt; sentence was 25 years to Board of Correction concurrent; Court of Appeals reversed for lack of corroboration; Supreme Court granted review.
- The Supreme Court ultimately affirmed, holding corroboration adequate and abandoning the corpus delicti rule.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is there sufficient corroboration under corpus delicti? | State argues confessions plus corroborating factors suffice. | Suriner contends there is no independent proof crime occurred apart from confessions. | Yes; sufficient corroboration under Idaho corpus delicti rule. |
| Was the jury instruction correct on corpus delicti? | State argues instruction properly required slight corroboration. | Suriner argues instruction improperly allowed extrajudicial statements to prove elements. | Instruction correct; not reversible error. |
| Should Idaho abandon the corpus delicti rule? | State seeks abolition of corpus delicti rule. | Suriner urges abolition on policy grounds. | Yes; corpus delicti rule abandoned. |
Key Cases Cited
- State v. Keller, 8 Idaho 699 (1902) (corroboration is slight; may cover non-criminal elements; early corpus delicti)
- State v. Urie, 92 Idaho 71 (1968) (extrajudicial statements consistent with confession may corroborate)
- State v. Tiffany, 139 Idaho 909 (2004) (autopsy/consistency can corroborate; limits of corroboration in homicide)
- State v. Byers, 102 Idaho 159 (1981) (rejected requiring corroboration of accuser’s testimony in sex crimes; shift away from old rule)
- State v. Maidwell, 137 Idaho 424 (2002) (acknowledged stare decisis but reversed on corpus delicti sensu stricto; urged reform)
- Opper v. United States, 348 U.S. 84 (1954) (discussion of corroboration across jurisdictions (federal context))