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Downey (D) was convicted of murdering his wife. The autopsy stated that the death was caused by strangulation. The body of his wife was in such a position that the cause of death could not have been accidental D had guided the witnesses to where the body was found and made a number of incriminating statements (the blood in his shirt was his wife's). D eventually confessed that he killed his wife. At trial, it was proven that the body was not in disarray and that the cause of death was strangulation. D moved for a directed verdict of acquittal because corpus delicti had not been established. D's motion was denied, and D appealed.

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