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State v. Anglin5/17/2000
unsel opened the door to evidence held inadmissible in a prior appeal).
Anglin next argues that the State failed to meet its burden of proving corpus delicti and that therefore his admissions to Deputy Collamore regarding his drinking were improperly admitted into evidence. The corpus delicti rule places an evidentiary burden upon the State to prevent convictions based solely upon the admissions of a defendant. See State v. Chad B., 1998 ME 150, § 6, 715 A.2d 144, 146. The State must "produce, exclusive of any confession or admission of the defendant, such credible evidence as will create a substantial belief that the crime charged has been committed by some person." State v. Curlew, 459 A.2d 160, 165 (Me. 1983). The substantial belief standard resembles the probable cause standard. See State v. Michaud, 1998 ME 251, § 8, 724 A.2d 1222, 1227. "In the context of the corpus delicti rule, robable cause exists where facts and circumstances within the [factfinder's] knowledge . . . would warrant a prudent and cautious person to believe that someone committed the crime." See id. (alterations in original). The determination of whether the evidence was "sufficient to establish a substantial belief [that a crime occurred] is a question of law that we review de novo." Id. § 7, 724 A.2d at 1227.
Anglin operated a vehicle that left the road at some point on March 17, 1999. The road was not slippery or dangerous to driving. When Anglin was tested, his blood alcohol content was twice the legal limit. This test followed a period of approximately an hour, during which he was under close observation and consumed no alcohol. These facts are sufficient to allow "a prudent and cautious person" to conclude that Anglin's blood alcohol content exceeded the legal limit at the time he drove his car off the road.
Finally, Anglin's challenge to the sufficiency of the evidence to support his conviction is without merit.
The entry is:
Judgment affirmed.
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