When Is a Confession Alone Enough? Minnesota Supreme Court Answers in State v. Hill
Earlier this month, the Minnesota Supreme Court weighed in on a long-standing question in criminal law: how much evidence is needed to support a confession of guilt? In State v. Hill, the MN Supreme Court reversed an appeals decision invalidating conviction on the grounds that the defendant’s confession was not properly supported by other evidence. This case clarifies Minnesota’s corpus delicti statute and confirms that a confession will support conviction when independent evidence shows a crime was likely intended to happen.
The phrase corpus delicti means “body of the crime.” Under Minnesota law, a confession cannot be the sole basis for a conviction. Instead, there must be some independent evidence that the charged crime actually occurred. This rule has been part of Minnesota law since 1851 and exists to prevent convictions based on false confessions, especially in cases where no crime took place at all. However, the threshold for this rule is low, and the State only needs to offer independent evidence that reasonably indicates the offense happened.
In May of 2020, the defendant visited a senior living apartment complex in Minneapolis and asked a staff member to show him a vacant unit. Once inside, he violently assaulted the staff member and pushed her into a closet. When she screamed and resisted, he eventually stopped. He apologized, handed her the knife he had brought with him, and left. Police arrested him two days later. During questioning, he admitted he planned to rape the woman but changed his mind. He said he had been thinking about sex but stopped because the situation felt wrong.
At trial, the district court found the defendant guilty of attempted first-degree criminal sexual conduct and sentenced him to 180 months in prison. The court ruled that his actions showed a substantial step toward committing the crime, and that his confession confirmed his intent. On appeal, the Minnesota Court of Appeals reversed the conviction. The appellate court held the only evidence of intent to sexually assault the victim came from the defendant’s confession because he never said anything sexual during the attack, never removed clothing, and never touched intimate parts. According to the Court of Appeals, the corpus delicti rule requires more evidence.
The Minnesota Supreme Court disagreed. It reaffirmed that the rule only requires some independent evidence that makes it reasonably likely the crime occurred. The Court said that the State is not required to prove each element of the offense through separate evidence but rather must prove likelihood of criminal conduct by the totality of the circumstances. Here, the defendant brought a knife, isolated the victim, physically attacked her, and locked the door behind him. Taken together, these facts suggested more than just a random assault. Rather, they supported the idea that he was following through on a plan, and his confession helped explain that plan.
Ultimately, this case confirms that Minnesota courts will take a practical approach to the corpus delicti rule. The purpose of the rule is to avoid convictions for crimes that never happened, not to require a piece-by-piece match between the confession and each element of the offense. If the overall facts suggest that something criminal occurred, and a confession fits that picture, the confession can be used to support a conviction.
Robert H. Ambrose is a criminal defense lawyer and DWI attorney in Minnesota and Wisconsin. Super Lawyers named him a Super Lawyer for the past four years and a Rising Star in the preceding six years. He is an adjunct professor at the University of Minnesota Law School. Criminal Defense Lawyer Woodbury, Criminal Defense Attorney Minnesota, DWI Lawyer Minnesota.