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Court of Appeals — Confession: People v. Santiago

New York State Court of Appeals


Corroboration — Medical Testimony

People v. Santiago
No. 22
Judge Pigott

Background: The defendant appealed arguing that her confession to the police following the death of her stepdaughter was insufficiently corroborated by independent evidence at trial to support her conviction of manslaughter. Further, she argued that certain letters written between the defendant and another inmate were improperly admitted into evidence that were not sufficiently redacted.

Ruling: The Court of Appeals held that there was independent evidence that a crime occurred. The jury heard evidence that the child victim had died by suffocation and that it was the result of human agency, especially given the medical testimony establishing that the child would not have died due to a loose object such as a plastic bag. Also, the letters had been redacted to a degree and the court provided a limiting instruction to the jury to ignore unrelated sexually charged content contained in the letters.

Malvina Nathanson for the appellant; Kirsten A. Rappleyea for the respondent