State v. Liles-Heide

— When a defendant testifies following the trial court’s denial of the defendant’s corpus delicti claim, an appellate court must review the record as a whole, including that testimony, to determine whether there was sufficient independent evidence to support a logical and reasonable inference that the charged crime occurred. Because the Snohomish County Superior Court erred when it refused to consider evidence presented by Liles-Heide establishing the sufficiency of the corpus delicti, we reverse and reinstate her conviction.

FACTS

On December 23, 1995, at approximately 10:30 p.m., a Snohomish…