On July 24, 2019, the Fourth Circuit Court of Appeals held in United States v. Rodriguez-Soriano that a defendant’s conviction for lying to a federally-licensed firearms dealer during the purchase of a firearm must be reversed because it was based on his own uncorroborated confession.
The defendant had filled out an ATF form before purchasing two guns from a licensed gun dealer stating that he was the actual purchaser of both handguns and acknowledging that he cannot engage in a “straw purchase,” which is a purchase on behalf of someone else. One of the two guns was later used by another individual in a homicide, and the ATF traced the gun purchase back to the defendant.
Federal agents interviewed the defendant, who initially falsely told them that the guns had been stolen from him but later admitted he had purchased the guns on behalf of a friend. He also admitted that the signature on the ATF form was his and that the statement on the form was false. He was re-interviewed by the agents on another date and again confessed to providing false information on the ATF form.
At trial, the Government presented the testimony of the gun dealer and the ATF agents who interviewed the defendant. However, the actual gun was never admitted into evidence, and no testimony from the defendant’s friend for whom the gun was purchased was introduced to corroborate the confession. The district court denied the defendant’s motion for acquittal, and the jury convicted the defendant.
On appeal, the Fourth Circuit reversed the conviction, holding that the Government’s case cannot rely on an uncorroborated admission by the defendant. The court rejected the Government’s argument that the internal inconsistencies in the defendant’s statements and the reiteration of his confession on a separate occasion sufficiently corroborated the confession. Instead, the court held, the corpus delicti – meaning the actual facts constituting the offense, which in this case the falsehood of the assertion that the guns were purchased for the defendant himself – must be corroborated by evidence outside of the defendant’s own confession. Without such evidence, the court held the Government did not prove its case beyond a reasonable doubt.
This decision is a significant reaffirmation of the corpus delicti rule: the Government cannot simply rely on a confession without more to obtain a conviction. This reduces the risk of wrongful convictions based on false confessions and helps ensure that investigations are thorough and not simply targeted at obtaining confessions.