State v. Leniart

Summary

The court held that the defendant's unpreserved corpus delicti claim was reviewable because the rule has both evidentiary and substantive due process components, but concluded that independent evidence sufficiently corroborated the alleged confessions and supported the convictions. It further held that the trial court improperly excluded the polygraph pretest interview categorically, but that the error was harmless, and that the trial court acted within its discretion in excluding expert testimony about incarcerated informants. Justice Kahn concurred, while Justices Palmer and D'Auria would have found the videotape exclusion harmful; Justice Palmer also would have admitted the informant expert's testimony.