The following excerpt is from U.S. v. Irving, 432 F.3d 401 (2nd Cir. 2005):
In applying Opper, we have held: "[T]he modern corroboration rule requires only that there be `substantial independent evidence which would tend to establish the trustworthiness of the statement.'" United States v. Bryce, 208 F.3d 346, 354 (2000). The corroboration rule thus serves a "gatekeeping function" in that it prevents juries from convicting on unreliable evidence. Id.
For purposes of the corroboration rule, there are two types of confessions or admissions:
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