that would have required that the jury find that the victim died from criminal means without considering Tiffany’s confession. The Court disagreed stating that “we have never required that the fact that a crime occurred must be proven independent of the defendant’s extrajudicial statements.” Id. at 918, 88 P.3d at 737. Thomas asserts that his trial and appellate attorneys performed deficiently by failing to argue that the corpus delicti rule in arson cases is distinct and requires proof that the fire is of incendiary origin. Other jurisdictions have held that corpus delicti in arson cases requires a showing that the fire was of incendiary origins before admitting a confession, or in order to sustain a finding of guilt. See, e.g., Thomas v. State, 295 Ark. 29, 746 S.W.2d 49, 51 (1988) (<HOLDING>); State v. White, 552 S.W.2d 33, 34
holding that in an arson case there must be other proof that the offense was committed to corroborate a confession by the defendant holding that the state failed to prove the corpus delicti of arson in that there was no evidence to corroborate the appellants confession establishing that the fire was caused by a criminal act holding state must prove every element of an offense beyond a reasonable doubt and a scheme that shifts the burden of proof to the defendant by presuming a fact upon proof of the other elements of the offense violates due process holding that admitting extrinsic evidence to corroborate the defendants confession to a cellmate was not reversible error holding that uncharged sexual acts committed upon the same victim are admissible to show the conduct of the defendant toward the victim and to corroborate the evidence of the offense charged in the indictment