Opper v. United States
348 U.S. 84 (1954)
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Rule of Law:
An accused's extrajudicial, exculpatory statements that admit to essential facts of the crime require corroboration. The corroborative evidence need not independently establish the corpus delicti but must consist of substantial independent evidence that establishes the trustworthiness of the statement.
Facts:
- Hollifield was an employee of the U.S. Air Force whose job included preparing specifications for survival kits.
- Opper was a subcontractor who supplied goggles for these kits.
- In January 1951, goggles supplied by Opper were rejected for failing to meet specifications.
- Shortly after the rejection, Hollifield, accompanied by Opper, strongly urged a project engineer to reconsider, and Hollifield prepared a memorandum arguing for acceptance.
- In February 1951, the use of Opper's goggles was recommended and approved.
- Phone records showed a call from Hollifield’s residence to Opper on April 13, 1951.
- Opper later made voluntary statements to the FBI admitting he gave Hollifield $1,000 in cash on April 14, 1951, and another $200 later.
- In his statements, Opper consistently maintained that the money was a personal loan and denied any guilt or illicit purpose.
Procedural Posture:
- Opper and Hollifield were indicted and tried jointly in a federal trial court.
- Opper's motion for severance was denied by the trial judge.
- A jury found Opper guilty on several counts, including conspiracy and aiding and abetting the receipt of unlawful compensation.
- Opper appealed his conviction to the U.S. Court of Appeals for the Sixth Circuit.
- The Court of Appeals affirmed Opper's conviction on the counts at issue.
- The U.S. Supreme Court granted certiorari to resolve a conflict among circuit courts regarding the corroboration of extrajudicial statements.
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Issue:
Do a defendant's extrajudicial, exculpatory statements that admit to essential facts or elements of the crime require corroboration by independent evidence to sustain a conviction?
Opinions:
Majority - Mr. Justice Reed
Yes. An accused’s extrajudicial admissions of essential facts or elements of a crime, made subsequent to the offense, are of the same character as confessions and require corroboration. This rule extends to exculpatory statements (i.e., those that seek to explain actions rather than admit guilt) because such statements, when given under suspicion, are also questionable and call for corroboration. The Court rejected the stricter rule requiring independent proof of the entire crime (the corpus delicti). Instead, it established that the corroborative evidence need only consist of substantial independent evidence that tends to establish the trustworthiness of the statement. Here, the evidence of a phone call, a cashed check, and an airline ticket sufficiently corroborated Opper's admission of payment, making the admission trustworthy and allowing the jury to consider it alongside all other evidence.
Concurring - Mr. Justice Frankfurter
Concurred in the result without a written opinion.
Dissenting - Mr. Justice Douglas
No. The judgment should be reversed because the stricter corroboration rule from Forte v. United States, which requires corroborating evidence to establish the whole of the corpus delicti, is the better rule.
Analysis:
This case significantly clarifies the corroboration rule for out-of-court statements in federal criminal law. By extending the corroboration requirement to exculpatory statements that admit key facts, the Court recognized that such statements carry similar risks of unreliability as confessions. More importantly, the decision established the 'trustworthiness' standard, a more flexible approach than the traditional 'corpus delicti' rule. This allows prosecutors to use a defendant’s statements as long as they can provide some reliable, independent evidence to back them up, without having to prove the entire crime independently of the statement itself, thus shaping how admissions are treated in federal prosecutions.
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