People v. Borrelli
Michigan Supreme Court
463 Mich. 930 (2000)
- Written by Kelli Lanski, JD
Facts
Joseph Borrelli (defendant) lost his car after a night out at a bar. He reported to the police that he had been carjacked. A few weeks later, Borrelli confessed to police during a follow-up interview that he had no memory of being carjacked and did not know how he lost his car. Borrelli was charged with knowingly filing a false police report based on his confession. The trial court dismissed the charge due to Michigan’s corpus delicti doctrine, which did not permit a criminal case to proceed if it was based on a defendant’s confession unless there was independent evidence establishing a specific injury and criminal agency as the source of that injury. The people (plaintiff) filed for leave to appeal, arguing that the court should adopt the federal standard for corpus delicti, which was less stringent and would allow the case to proceed.
Rule of Law
Issue
Holding and Reasoning ()
Concurrence (Corrigan, J.)
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