52
It is equally clear that "the corroborative evidence need not be sufficient, independent of the statements, to establish the corpus delicti" (Opper v. United States, 348 U.S. 84, 93) or, as elaborated in Smith v. United States, 348 U.S. 147, 156 (emphasis added):
It is agreed that the corroborative evidence does not have to prove the offense beyond a reasonable doubt, or even by a preponderance, as long as there is substantial independent evidence that the offense has been committed, and the evidence as a whole proves beyond a reasonable doubt that defendant is guilty. [citing decisions]. In addition to differing views on the substantiality of specific independent evidence, the debate has centered largely about two questions: (1) whether corroboration is necessary for all elements of the offense established by admissions alone [comparing decisions], and (2) whether it is sufficient if the corroboration merely fortifies the truth of the confession, without independently establishing the crime charged. [comparing decisions]. We answer both in the affirmative. All elements of the offense must be established by independent evidence or corroborated admissions, but one available mode of corroboration is for the independent evidence to bolster the confession itself and thereby prove the offense "through" the statements of the accused. * * *
While it is concededly difficult to match the facts of the various cases in which this type of question arises, the independent testimony here is at least as corroborative as that held sufficient in other cases
