A high school gymnastics coach was accused of having an improper relationship with a student, PV. The coach denied the allegation and wrote a statement in which he discussed his interactions with PV and another student, KR. The district began an investigation and spoke with PV and KR before meeting again with the coach.
During the second meeting with the coach, he told the district investigator that "other things had also occurred" and confessed to having a sexual relationship with PV, KR and a third student, IG. The coach's confession regarding IG was new and unsolicited. He submitted a new statement to the district in which he confessed to a sexual relationship with PV and KR and stated that he had "gone out a few times" with IG, but they only had a "kissing relationship."
The coach was arrested and charged with various crimes related to all three students. At the trial, PV and IG did not testify. IG's father testified about a letter the coach had written to IG in which he stated "most people would think that finding love between a teacher and a student should be forbidden. I would not have it any other way though. I really do feel that I can spend the rest of my life with you." The letter then proceeded to ask her to accompany him to homecoming the following year.
KR testified extensively at trial that she and the coach had a sexual relationship.
The jury convicted the coach of crimes related to his relationships with KR and PV and acquitted him of any sexual crime with IG. The coach appealed, arguing that his confession to the school district had been improperly admitted and that there was no corroborating evidence to back up his confession.
The Court of Criminal Appeals noted that there is a requirement that when a defendant is convicted based on a defendant's confession to someone other than law enforcement, that confession is not legally sufficient to prove guilt unless there is corroborating evidence independent of that confession tending to show that the crime probably did happen. This requirement is intended to protect people who make false confessions. The coach argued that this requirement to provide corroborating evidence applied because his confession had been given to the school district, not the police. However, there is an exception to this requirement that applies when a defendant is charged with multiple, closely-related offenses.
In this case, the Court of Criminal Appeals found that the exception did apply. Although PV and IG did not testify, the evidence introduced at trial showed that the coach engaged in a similar course of conduct with all three students, grooming them and using his position of authority as a teacher and coach to convince them to participate in a sexual relationship.
Given the identical nature of the offenses, the similar pattern of behavior and the fact that much of the underlying conduct was proven by the evidence introduced at trial, the court concluded that the offenses were sufficiently related to tend to show that a crime against PV had been committed, consistent with the coach's confession. Therefore, the Court of Criminal Appeals upheld the conviction imposed by the jury.
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