Evidence – Corroboration of Extrajudicial Confession – Quantum of Independent Evidence Required to Sustain Conviction

Sent to a hotel room at midnight to investigate reports of a contemplated robbery, the police found the defendant and another man, strangers in town, with loaded revolvers nearby. After defendant failed to account for the guns, the police confronted him with the robbery report, and he signed a confession. On appeal of his conviction for conspiracy to commit robbery, held, reversed, two justices dissenting in part. If evidence independent of the confession is such that reasonable minds could believe that the crime was in fact committed, the corpus delicti is sufficiently established to make the confession admissible. The independent evidence in this case is inadequate for that purpose. State v. Weldon, (Utah 1957) 314 P. (2d) 353.