Fourth Circuit overturns verdict based on uncorroborated extrajudicial confession

In United States v. Stephens, Stephens was convicted of one count of conspiracy to distribute cocaine, and one count of using, carrying, and discharging a firearm in relation to a drug trafficking crime. The basis of the conviction was Stephens' statement to the police that a drug dealer who Stephens' owed money was out to get him and that Stephens had exchanged gunfire with the dealer. The Fourth Circuit reversed the convictions because the government presented no evidence other than Stephens' own statement to law enforcement officers to establish his connection to a drug conspiracy or any drug trafficking crime. Because a criminal defendant’s conviction cannot rest entirely on an uncorroborated extrajudicial confession, the panel reversed and vacated the sentence.