People v. Harvey

Defendant was found guilty of misdemeanor unlawful use of a weapon for possessing a firearm on a public street without a concealed carry license. On appeal, defendant argued that the State failed to establish the corpus delicti of the offense because the only evidence that he lacked a concealed carry license came from his own out-of-court statements made to police officers. The appellate court rejected this argument and affirmed. The Supreme Court also affirmed, explaining that independent corroborating evidence was not required under the corpus delicti rule where defendant did not “confess” that he had committed the offense of UUW, but only admitted to one element of the offense. (THEIS, OVERSTREET, and HOLDER WHITE, concurring, and NEVILLE and ROCHFORD, specially concurring, and O’BRIEN, specially concurring)