State v. Angulo

¶45 (dissenting) — The majority’s opinion overrules multiple opinions of the divisions of this court as well as Washington Supreme Court precedent. It also changes the manner in which the corpus delicti rule is applied in Washington — a result the parties neither sought nor had an opportunity to oppose. Because I believe the majority’s overhaul of the rule is unnecessary and inconsistent with established precedent, I must respectfully dissent.

¶46 In order to satisfy the corpus delicti rule, the State must present evidence independent of the defendant’s incriminating statement to corroborate…