State v. Heiges, Minn.S.Ct., 8/17/2011. I wrote about this case here, when the court of appeals had it. Although for slightly different reasons, the supreme court affirms the court of appeals. A jury convicted Ms. Heiges of second degree murder for the death of her newborn daughter. After delivering the baby, she drowned the baby in the bathtub. Roughly five months later, Ms. Heiges confided to A.B. (and others, but let’s keep it simple) that she had drowned the child. A.B. reported this to the police, who commenced an investigation. Police interviewed Ms. Heiges several times, during which she eventually made similar admissions.
The court of appeals had concluded that Ms. Heiges’ statements to friends before commencement of a police investigation need not be corroborated because such statements are not “confessions” within the meaning of Minn.Stat. 634.03; the court of appeals also concluded that such statements may be used to corroborate a defendant’s later confession to the police. The supreme court had a slightly different take. They conclude that such statements to friends before commencement of a police investigation are “confessions” under the statute, citing an opinion in which the court said that “any statement in which a defendant acknowledges guilt of a crime” was a confession. State v. Vaughn, 361 N.W.2d 54 (Minn. 1985).
That then presents the question whether this “confession” to friends was sufficiently corroborated by independent evidence of attending facts or circumstances from which a jury could infer trustworthiness of that confession. The court concludes that it was. It parses the confession to friends to include seven significant facts. The court then goes looking for independent evidence to prop up those significant facts, and finds that evidence.
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