2011-M-184             State of Minnesota, Respondent, vs. Samantha Anne Heiges, Appellant.

Samantha Heiges was arrested and charged with second-degree murder and first-degree manslaughter for allegedly drowning her baby daughter in a bathtub immediately  after the baby was born.  A Dakota County jury found Heiges guilty of second-degree murder and the Dakota County District Court convicted Heiges of this offense and sentenced her to 299 months in prison.  A divided court of appeals panel affirmed Heiges’s conviction.  Heiges petitioned our court for the review of several issues.  We granted review on two issues relating to her confessions to friends and others after the crime was committed.  We affirm.

First, the scope of the term “confession” in Minn. Stat. § 634.03 (2010) includes statements made to friends and acquaintances after the crime was committed but before the commencement of the police investigation. 

Second, the defendant’s conviction did not violate Minn. Stat. § 634.03 when the State established the trustworthiness of the defendant’s confessions by presenting sufficient evidence to corroborate the attendant facts and circumstances of those confessions.  

Third, Minnesota Statutes § 634.051 (2010) requires that the evidence that establishes the death of the victim be independent of the evidence that establishes the killing of the victim by the defendant.  

Fourth, the evidence at trial, including the defendant’s confessions, was sufficient to sustain the defendant’s conviction for second-degree murder.

               Paul Anderson (Gildea, Page, Meyer, Barry Anderson, Dietzen and Stras)

[MURDER] [DOMESTIC]