U.S. v. Baldwin, 54 M.J. 464

Core Criminal Law Subjects: Evidence: Confessions and Admissions › Corroboration

1. (the corroboration requirement for admission of a confession at court-martial does not necessitate independent evidence of all the elements of an offense or even the corpus delicti of the confessed offense; rather, the corroboration must raise only in inference of truth as to the essential facts admitted, and the reliability of the essential facts need only be established by a preponderance of the evidence
2. where the military judge made detailed findings of fact, those findings adequately corroborated the facts contained in appellant’s confession where the judge’s findings had direct corroborative value as to two specific facts in appellant’s confession and raised an inference of truth as to the essential facts admitted in the confession