State v. Tiffany
| Decision Date | 05 May 2003 |
| Docket Number | Docket No. 27491. |
| Parties | STATE OF IDAHO, Plaintiff-Respondent, v. MICHELLE L. TIFFANY, Defendant-Appellant. |
| Court | Idaho Court of Appeals |
Appeal from the District Court of the First Judicial District, State of Idaho, Kootenai County. Hon. Charles W. Hosack, District Judge.
Judgment of conviction for involuntary manslaughter, vacated and case remanded.
John M. Adams, Kootenai County Public Defender, Coeur d'Alene, for appellant.
Hon. Lawrence G. Wasden, Attorney General; Karen A. Hudelson, Deputy Attorney General, Boise, for respondent. Karen A. Hudelson argued.
A jury found Michelle L. Tiffany guilty of involuntary manslaughter, I.C. § 18-4006(2). On appeal, Tiffany argues that the district court erred in refusing to grant her motion for a judgment of acquittal where the state failed to show the corpus delicti of involuntary manslaughter independently from Tiffany's extrajudicial confessions. Tiffany also argues that the district court erred by giving various jury instructions which misstated applicable law and/or were misleading, and by failing to give requested jury instructions. We vacate the judgment of conviction and remand for a new trial.
In August of 1999, Tiffany called 911 to report that her infant son, Nathan Tiffany, was not breathing. Paramedics arrived at Tiffany's home and attempted CPR, but they were unable to revive Nathan. Tiffany told her husband and the responding police officers that she had found Nathan limp and not breathing when she went to check on him. Following an autopsy, the coroner declared that the cause of Nathan's death was Sudden Infant Death Syndrome (SIDS).
Approximately one year later, Tiffany disclosed to a counselor, to police officers and to her husband, on separate occasions, that she had suffocated Nathan by twice placing her hand over his mouth and nose in an attempt to quiet his crying. Following this disclosure, Tiffany was arrested and charged with involuntary manslaughter.
The case went before a jury and at the close of the state's case, Tiffany moved for a judgment of acquittal, arguing that under the corpus delicti principle she could not be found guilty when the only evidence that she had killed Nathan was her extrajudicial confessions. The district court denied the motion. At the close of trial, Tiffany requested jury instructions addressing the issues of corpus delicti, mental illness, excusable homicide and proximate cause. The district court refused to give these instructions.
The jury returned a verdict finding Tiffany guilty of involuntary manslaughter based on the predicate acts of injury to a child and battery. Thereafter, the district court sentenced Tiffany to a unified term of seven years with three years determinate, suspended the sentence, and placed her on probation for seven years. Tiffany appeals from the judgment of conviction, contending that the state failed to establish the corpus delicti of the crime prior to using Tiffany's extrajudicial confessions as evidence, and that the district court's giving of certain jury instructions, or the court's refusal to give other requested instructions, was error.
Tiffany asserts that the district court should have granted her motion to acquit because the state failed to establish the corpus delicti of involuntary manslaughter independently from her extrajudicial confessions.1 When a defendant presents evidence at trial and later challenges the denial of a motion for judgment of acquittal, this Court considers all the evidence, including that offered by the defense, to determine whether it is sufficient to sustain the conviction. State v Hughes, 130 Idaho 698, 701, 946 P.2d 1338, 1341 (Ct. App. 1997). We do not substitute our view for that of the trier of fact as to the credibility of the witnesses, the weight of the testimony, and the reasonable inferences to be drawn from the evidence. State v. Stricklin, 136 Idaho 264, 269, 32 P.3d 158, 163 (Ct. App. 2001). Moreover, we consider the evidence in the light most favorable to the prosecution. If a jury's verdict is supported by substantial and competent evidence, it will not be set aside on appeal. Id.
Corpus delicti, meaning "the body of a crime," is a common law principle that requires the state to establish some evidence that a crime occurred independently from a defendant's confession.2 See BLACK'S LAW DICTIONARY 344 (6th Ed. 1990). The purpose of corpus delicti is to prevent errors in convictions based on false confessions, to act as a safeguard against the defendant's act of confessing but being mistaken that a crime occurred, and to force the prosecution to use its best evidence. State v. Urie, 92 Idaho 71, 76, 437 P.2d 24, 29 (McFadden, J., special concurrence).
To prove a crime generally, the state must provide evidence in the context of three broad elements: (1) that an injury occurred; (2) that criminal agency was involved in causing the injury; and (3) the identity of the person who caused the injury. See id. at 75, 437 P.2d at 28 (special concurrence). Under the standard formulations of the corpus delicti principle, the state must show the "body" of a crime by establishing the first two elements of a crime, i.e., the injury and the criminal agency, independently from a defendant's confession. Id.; State v. Darrah, 60 Idaho 479, 482, 92 P.2d 143, 144. Thus, the state cannot prove its case by solely using a defendant's confession to establish that a crime occurred. See Urie, 92 Idaho at 73, 437 P.2d at 26; State v. Wilson, 51 Idaho 659, 669, 9 P.2d 497, 500-501; State v. Keller, 8 Idaho 699, 704-05, 70 P. 1051, 1052.
In Idaho, the state need not establish independently from the defendant's confession each element of the corpus delicti.3 Urie, 92 Idaho at 73, 437 P.2d at 26; but see State v. Cutler, 94 Idaho 295, 296-97, 486 P.2d 1008, 1009-10. Thus, as the corpus delicti of the crime consists of injury and criminal agency, the state needs to independently corroborate only one of those elements to meet its burden. Moreover, only slight corroboration of the corpus delicti by independent evidence is required.4 Id.; Wilson, 51 Idaho at 669, 9 P.2d at 497; State v. Downing, 23 Idaho 540, 544, 130 P. 461; Keller, 8 Idaho at 705, 70 P. at 1052.
Having reviewed the foregoing principles, we now apply Idaho's law of corpus delicti to the instant case. The state was required to show slight corroborating evidence of at least one element of the corpus delicti of involuntary manslaughter independently from Tiffany's confession. In a homicide case or related case, the corpus delicti consists of a death (the injury) and that the death occurred by criminal action or means (the criminal agency). See Cutler, 94 Idaho at 296, 486 P.2d at 1009. The state met its burden to show evidence of one element of the corpus delicti of involuntary manslaughter — that death occurred. Dr. George Lindholm, the pathologist who performed the autopsy on Nathan, confirmed Nathan's death. Because only one element of the corpus delicti needs to be corroborated, the state met its burden to establish the corpus delicti of the crime independently from Tiffany's confessions. Therefore, we affirm the district court's denial of Tiffany's motion for judgment of acquittal.
Tiffany argues that the district court did not properly instruct the jury on various issues. Whether the district court properly instructed the jury is a question of law over which this Court exercises free review. State v. Bush, 131 Idaho 22, 32, 951 P.2d 1249, 1259; State v. Buckley, 131 Idaho 179, 182, 953 P.2d 619, 622 (Ct. App. 1997). On appeal, we view jury instructions as a whole, not individually, to determine whether the jury was properly and adequately instructed on the applicable law. State v. Row, 131 Idaho 303, 310, 955 P.2d 1082, 1089; State v. Rozajewski, 130 Idaho 644, 646, 945 P.2d 1390, 1392 (Ct. App. 1997). To be reversible error, instructions must have misled the jury or prejudiced the complaining party. Row, 131 Idaho at 310, 955 P.2d at 1089. The court is required to provide instructions on all matters of law necessary for the jury's information. I.C. § 19-2132(a); State v. Patterson, 126 Idaho 227, 230, 880 P.2d 257, 260 (Ct. App. 1994). The court should not use an instruction, however, which misleads the jury or misstates the law. See Humpherys, 134 Idaho at 659, 8 P.3d at 654; State v. Merwin, 131 Idaho 642, 647, 962 P.2d 1026, 1031.
Tiffany argues that the district court's failure to give Tiffany's requested corpus delicti jury instructions to the jury was reversible error.5 We determine that Tiffany's proposed instructions were misleading and inaccurate statements of Idaho's law and thus, were properly refused by the district court. Both instructions discuss that the state must provide evidence that a crime has occurred independently from Tiffany's confessions. While this is the general purpose of corpus delicti, the state is actually required to corroborate the corpus delicti, or the body of the crime - not the elements of the crime itself. Thus, in the case of involuntary manslaughter, the state has the burden to corroborate that either death occurred or that criminal means was involved. See Cutler, 94 Idaho at 296, 486 P.2d at 1009; Urie, 92 Idaho at 73, 437 P.2d at 26. Tiffany's proposed instructions, however, require that the state corroborate the elements of the crime itself, rather than the corpus delicti of the crime.6 This is a misleading and inaccurate statement of Idaho law. Thus, the district court did not err by refusing to give Tiffany's requested corpus delicti instructions.
Tiffany also argues that the intent instructions given by the district court constitute error. In State v. Young, ___ Idaho ___, 64 P.3d 296, the Idaho Supreme Court...
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