Crouch v. State

MOYLAN, Judge. The appellant, David Eugene Crouch, was convicted by a Baltimore County jury, presided over by Judge James T. Smith, Jr., of first-degree felony-murder, armed robbery, and daytime housebreaking. Upon this appeal, he raises the single contention that his numerous confessions were inherently unreliable and that he should not have been convicted on his own uncorroborated statements. The appellant misreads the law.

The corroboration requirement as to a defendant’s confession is very different from the corroboration requirement as to accomplice testimony. When a conviction is based upon the ⁷⁶⁹ testimony of an accomplice, there must be some independent corroboration establishing the defendant’s criminal agency. When a conviction is based upon the testimony or statements of the defendant himself, on the other hand, there must be some independent corroboration of the corpus delicti of the crime itself. This, as we discussed in Borza v. State, 25 Md.App. 391, 403 , 335 A.2d 142 (1975), is to prevent a mentally unstable person from confessing to and being convicted of a crime that never occurred.

See also Bollinger v. State, 208 Md. 298 , 117 A.2d 913 (1955); Wood v. State, 192 Md. 643 , 65 A.2d 316 (1949). In the case at bar, there was ample corroborative evidence of the corpus delicti. Mrs. Helen Weibe, 87 years of age, was found dead in her home at 4380 Hollins Ferry Road. The cause of death was established as having been “blunt head trauma” believed to have been inflicted by a flashlight, found bloodied on the premises.

The appellant’s argument collapses because the only type of corroboration that the law requires was abundantly present. This very situation was discussed by us at length in Lemons v. State, 49 Md.App. 467, 473 ,