{"id":5567,"date":"2009-09-05T11:08:02","date_gmt":"2009-09-05T17:08:02","guid":{"rendered":"http:\/\/oooorgle.com\/wordpress\/?p=5567"},"modified":"2016-09-05T04:27:46","modified_gmt":"2016-09-05T11:27:46","slug":"standing-cross-reference","status":"publish","type":"post","link":"https:\/\/oooorgle.com\/BeyondTheCorral\/standing-cross-reference\/","title":{"rendered":"Standing Cross-reference"},"content":{"rendered":"

\"\"MarcStevens.net<\/a> | Standing is the same wherever you go, the important elements are (1) the violation of a right, a legal injury; and (2) damage.\u00a0 The only \u201cauthority\u201d one should need is to look at the Declaration of Independence<\/a> for the only reason for the establishment of an American government:<\/p>\n

\u201cWe hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness. \u2014 That to secure these rights, Governments are instituted <\/strong>among Men, deriving their just powers from the consent of the governed\u2026\u201d (Emphasis mine)<\/p>\n

This of course is repeated in \u201cstate\u201d constitutions such as Arizona: \u201cgovernments \u2026 are established to protect and maintain individual rights.\u201d\u00a0 Arizona constitution article II \u00a7 2<\/span><\/a>. This is why standing and jurisdiction must always involve a plaintiff\u2019s rights.<\/p>\n

However, statists, especially attorneys, are not interested in the plain truth.\u00a0 That is why they claim everything I write is taken out of context.\u00a0 An example is standing.\u00a0 This incredibly simple issue is intentionally complicated by attorneys whose money is made arguing.\u00a0 Attorneys\u00a0 will claim because I provide quotes and citations from civil cases, that standing and jurisdiction only applies to civil cases, not criminal cases.\u00a0 One attorney in Arizona, Paula Burgess, acting as a judge, told me with a straight face article II \u00a7 2 did not apply to criminal cases.\u00a0 In Ms. Burgess\u2019s opinion the criminal court system was either not created by the Arizona constitution or is not a part of the government.\u00a0 It\u2019s absurd to claim standing and jurisdiction requirements do not apply in criminal cases.<\/p>\n

It\u2019s simple logic and common sense, juris doctorate<\/a> not required:<\/p>\n

(1) the government was established\/instituted for one purpose i.e., to secure\/protect rights;<\/p>\n

(2) the courts being a part of the government have the same singular purpose i.e., to secure\/protect rights;<\/p>\n

(3) the courts\u2019 jurisdiction has one purpose i.e., to secure\/protect rights;<\/p>\n

(4) Standing to invoke a court\u2019s jurisdiction requires the allegation a right is being violated.<\/p>\n

Standing applies in criminal cases.\u00a0 What attorneys probably don\u2019t like is it doesn\u2019t require a one-hundred thousand dollar education to know and understand it; all it requires is to know what the purpose of government is supposed<\/em> to be.\u00a0 Maybe one of the reasons attorneys don\u2019t like this is that it\u2019s a threat to their monopoly.<\/p>\n

Let\u2019s examine the heinous crime called the \u201cunauthorized practice of law\u201d, attorneys LOVE this.\u00a0 Their passionate enforcement is evidence enough (try to assist a friend in court and watch the attorneys come alive).\u00a0 In California it is \u201cpunishable by up to one year in a county jail or by a fine of up to one thousand dollars ($1000), or by both\u2026\u201d California Business and Professions Code \u00a7 6126(a)<\/a>.<\/p>\n

Government has one purpose \u201cgovernments \u2026 are established to protect and maintain individual rights.\u201d\u00a0 Arizona constitution article II \u00a7 2<\/span><\/a>.\u00a0 Whose rights am I accused of violating if I am accused of the \u201cunauthorized practice of law\u201d crime?\u00a0 If you have trouble identifying whose rights to life, liberty or property are violated, then don\u2019t despair because it violates no one\u2019s rights.\u00a0 It\u2019s the same if I am growing marijuana on my property, it violates no one\u2019s rights and injures no one.\u00a0 I wonder how many attorneys would be out of work if the \u201cdrug war\u201d ended tomorrow?\u00a0 Looks like a motive to me.<\/p>\n

Remember, attorneys are part of the system, their allegiance<\/a> is to that system because that system is where and how they get such high profits.\u00a0 Anything<\/em> that would take away fom their profits will be attacked.\u00a0 Therefore, anything that would take business away from the courts will be opposed by this aggression-drunk cult<\/a>.<\/p>\n

As designed by this cult, there will always be conflicting \u201cprecedents\u201d and there are probably \u201copinions\u201d out there that may appear to conflict, or actually conflict with, the cases I provide below.\u00a0 Do not let that discourage you, remember the cases I have cited are consistent with constitutions, enabling acts and the Declaration of Independence.\u00a0 When conflicting \u201copinions\u201d are brought forth, then take that as evidence that attorneys will say anything.\u00a0 It\u2019s one more reason not to give any credibility to an attorney.<\/p>\n

This cross-reference is a work in progress, so please check back often for updates.\u00a0 I will have each \u201cstate\u201d standing \u201cauthority\u201d posted.\u00a0 And remember, I, Marc Stevens, am not an attorney, so everything is for entertainment purposes only and if anything here resembles the truth, then it must have been taken out of context.<\/p>\n

\u201cDistinctions between crime and tort<\/strong>\u2026<\/p>\n

While the same act may constitute both a crime and a tort, the distinction between crimes and torts is based on the public nature of the criminal offense.<\/p>\n

The distinction with respect to the character of the rights affected and the nature of the wrong is this: \u00a0A tort is merely a private wrong in that it is an infringement of the civil rights of individuals, considered merely as individuals, while a crime is a public wrong in that it affects public rights and is an injury to the whole community, considered as a community in it\u2019s social aggregate capacity.<\/p>\n

The distinction between a tort and a crime lies in the difference between the methods by which the remedy for the wrong is pursued; a wrong for which the remedy is pursued by, and at the discretion of, the individual injured or his representative is a tort, and a wrong for which the wrongdoer is proceeded against by the sovereign or state for the purpose of punishment is a crime.\u201d \u00a0Corpus Juris Secundum<\/span>, Vol 22, page 26 (2006 ed). \u00a0Supporting citations from text:<\/p>\n

Ind-State ex rel Johnson v. White Circuit Court<\/span>, 225 Ind 602, 77 N.E.2d 298\u2026Mich.-People v. Veenstra<\/span>, 337 Mich. 427, 60 N.W.2d 309\u2026Pa.-Com. v. Malloy<\/span>, 304 Pa.Super. 297, 450 A.2d 689\u2026Ala.-Holland v. State, 440 So.2d 1236\u2026N.J.- Tomlin v. Hildreth, 65 N.J. L. 438, 47 A. 649\u2026N.C.-State Highway and Public Works Comm. v. Cobb, 215 N.C. 556, 2 SE2d 565\u2026<\/p>\n

Alabama<\/strong>:<\/p>\n

\u201cThere are only two elements in the corpus delecti of an offense: (1) That a certain result has been produced, and (2) that a person is criminally responsible for that result.\u201d\u00a0 Ex parte Slaton<\/span>, 680 So.2d 909, 925 (Ala. 1996).<\/p>\n

\u201c\u201cCorpus delecti\u201d consists of two elements: that a certain result has been produced that some person is criminally responsible for the act.\u201d\u00a0 Johnson v. State<\/span>, 473 So.2d 607, 609.<\/p>\n

\u201cThus, although a certain section of Amendment III appears on its face to be discriminatory, because \u201cplaintiff in this case alleged that he or she suffered an injury under this section, no case or controversy was ever presented to the trial court to invoke its jurisdiction\u2026\u201d<\/p>\n

\u201cUnder Alabama law, every action in tort consists of three elements: The existence of a legal duty by defendant to plaintiff; a breach of that duty; and damage as the proximate result.\u00a0 Alabama Power Co. v. Guy<\/em>, 281 Ala. 583, 206 So.2d 594, 599 (1967).\u201d\u00a0 Dobbs v. Alabama Power Co<\/span>., 549 So.2d 35, 36 (Ala. 1989).<\/p>\n

\u201cTo present a justiciable case or controversy, the individual plaintiff must have standing to sue; to have standing, the individual must allege an injury directly arising from or connected with the wrong alleged.\u00a0 The standing requirement applies whether the plaintiff sues individually or on behalf of a class.\u201d\u00a0 Ex Parte Blue Cross & Blue Shield of Alabama<\/em>, 582 So2d 469, 474\u2026<\/p>\n

\u201cWhen a party without standing purports to commence an action, the trial court acquires no subject matter jurisdiction.\u00a0 Barshop v. Medina County Underground Water Conservation District<\/em>, 925 S.W.2d 618, 626\u2026(\u2018standing is a necessary component of subject matter jurisdiction\u2019).\u00a0 See also Rames v. Bryd<\/a> <\/em>, 521 US 811\u2026(\u2018\u201cstanding is perhaps the most important of [the jurisdictional] doctrines\u2019\u201d); National Organization for Women, Inc., v. Scheidler<\/em><\/a> , 510 US 249\u2026(\u2018standing represents a jurisdictional requirement which remains open to review at all stages of the litigation\u2019)\u2026(\u2018standing is a jurisdictional prerequisite\u00a0 to every case and may be raised at any stage of the proceedings\u2019)\u2026\u201d\u00a0 Ex parte James<\/span>, 836 So2d 813, 871, 872-873.<\/p>\n

\u201cStanding requires an injury in fact\u2026When a party without standing puports to commence an action, the trial court acquires no subject matter jurisdiction\u2026If a named plaintiff has not been injured by the wrong alleged in the complaint, then no case or controversy is presented\u2026A party\u2019s injury must be \u201ctangible,\u201d\u2026\u201d\u00a0 Kid\u2019s Care, Inc. v. Ala. Dept\u2019 of Hum. Res<\/span>., 843 So.2d 164, 166-167 (Ala. 2002).<\/p>\n

\u201cStanding turns on whether the party has been injured in fact and whether the injury is to a legally protected right.\u201d\u00a0 Walters v. Stewart<\/span>, 838 So.2d 1047.<\/p>\n

\u201cJudicial power is authority vested in some court, officer or person, to hear and determine when the rights of person or property, or the propriety of doing an act, are the subject-matter of adjudication.\u201d\u00a0 State v. Jelks<\/span>, 35 So. 60, 62.<\/p>\n

Alaska<\/strong>:<\/p>\n

\u201cDegree of injury required under interest-injury standing need not be great; an \u201cidentifiable trifle\u201d is said to suffice to fight out a question of principal.\u201d\u00a0 Alaskans for a Common Language, Inc. v. Kritz<\/span>, 3 P.3d 906 (Alaska 2000).<\/p>\n

\u201cState courts grant standing to any person who can show injury-in-fact.\u201d\u00a0 In re Dissolution of Marriage of Alaback<\/span>, 997 P.2d 1181.<\/p>\n

\u201cthe duty of this court, as of every judicial tribunal<\/em><\/strong>, is limited to determining rights<\/em><\/strong> of persons or of property, which are actually controverted in the particular case before it.\u201d\u00a0 Tyler v. Judges of the Court of Registration<\/span>, 179 U.S. 405, 21 SCt. 206, 208.<\/p>\n

 <\/p>\n

Arizona<\/strong>:<\/p>\n

\u201cAll political power is inherent in the people, and governments derive their just powers from the consent of the governed, and are established to protect and maintain individual rights.\u201d\u00a0 Arizona constitution article II \u00a7 2<\/span><\/a>.<\/p>\n

\u201cit is declared that the public policy of this state and the general purposes of the provisions of this title [criminal code title 13] are: 1. To proscribe conduct that unjustifiably and inexcusably causes or threatens substantial harm to individual or public interests.\u201d\u00a0 Arizona criminal code \u00a7 13-101<\/a> .<\/p>\n

\u201cTwo elements comprise the corpus delecti of a crime: (1) the basic injury\u2026(2) the fact that the basic injury was the result of a criminal, rather than a natural or accidental, cause. \u00a0State v. Thomas<\/em>, 78 Ariz. 52, 59, 275 P.2d 408, 413 (1954).\u201d \u00a0State v. Atwood<\/span>, 832 P.2d 593, 614, 171 Ariz. 576.<\/p>\n

\u201cIn Arizona, both \u201cbut for\u201d causation and proximate cause must be established in a criminal case.\u201d \u00a0State v. Marty, 801 P.2d 468, 471, 166 Ariz. 233.<\/p>\n

\u201cIf such preliminary proof has been submitted the confession or statements may then be used to assist in proving the corpus delecti beyond a reasonable doubt, the degree necessary for conviction.\u201d\u00a0 State v. Hernandez<\/span>, 320 P.2d 476, 469, 83 Ariz. 279.<\/p>\n

\u201cIn order to establish corpus delecti, state must prove that a certain result has been produced and that someone is criminally responsible for that result.\u201d\u00a0 State v. Gerlaugh<\/span>, 654 P.2d 800, 134 Ariz. 164.<\/p>\n

\u201cTo establish corpus delecti, there must be some proof that a certain result has been produced and that someone is criminally responsible for the act.\u201d\u00a0 State v. Pineda<\/span>, 519 P.2d 41, 100 Ariz. 342.<\/p>\n

\u201c\u201cCorpus delecti\u201d of a crime is established by showing proof of result and that some one is criminally responsible therefore.\u201d\u00a0 State v. Flores<\/span>, 454 P.2d 172, 9 Ariz.App. 502.<\/p>\n

\u201c\u201cCorpus delecti\u201d has as its two elements that a certain result has been produced and that some person is criminally responsible for the act.\u201d\u00a0 State v. Wilson<\/span>, 548 P.2d 23, 113 Ariz. 145.
\n\u201cIn Sears, we denied standing to citizens seeking relief against the governor because they failed to plead and prove palpable injury personal to themselves.\u201d\u00a0 Bennet v. Napolitano<\/span>, 81 P3d 311, 315.<\/p>\n

\u201cTo gain standing to bring an action, a plaintiff must allege a distinct and palpable injury.\u00a0 Warth v. Seldin<\/em><\/a>, 422 U.S. 490, 501.\u201d\u00a0 Sears v. Hull<\/span>, 961 P.2d 1013, 1017 (1998).<\/p>\n

\u201cTo gain standing to bring an action, a plaintiff must allege a distinct and palpable injury.\u201d\u00a0 Fernandez v. Takata Seat Belts, Inc<\/span>., 108 P.3d 917.<\/p>\n

Arkansas<\/strong>:<\/p>\n

\u201cIt is a fundamental principal that the courts are instituted to afford relief to persons whose rights have been invaded\u2026by the defendant\u2019s conduct\u2026a court may and properly should refuse to entertain an action at the instance of one whose rights have not been invaded or infringed, as where he seeks to invoke a remedy in behalf of another who seeks no redress.\u201d\u00a0 Jag Consulting v. Eubanks<\/span>, 72 S.W.3d 549 556.<\/p>\n

\u201cthe duty of this court, as of every judicial tribunal<\/em><\/strong>, is limited to determining rights<\/em><\/strong> of persons or of property, which are actually controverted in the particular case before it.\u201d\u00a0 Tyler v. Judges of the Court of Registration<\/span>, 179 U.S. 405, 21 SCt. 206, 208.<\/p>\n

California<\/strong>:<\/p>\n

\u201cIn every prosecution for crime it is necessary to establish the \u201ccorpus delecti\u201d, i.e., the body or elements of the crime.\u201d\u00a0 People v. Lopez<\/span>, 62 Ca.Rptr. 47, 254 C.A.2d 185.<\/p>\n

\u201cIn every criminal trial, the prosecution must prove the corpus delecti, or the body of the crime itself-i.e., the fact of injury, loss or harm, and the existence of a criminal agency as its cause.\u201d\u00a0 People v. Sapp<\/span>, 73 P.3d 433, 467 (Cal. 2003) [quoting People v. Alvarez<\/span>, (2002) 27 Cal.4th 1161, 1168-1169, 119 Cal.Rptr.2d 903, 46 P.3d 372.].<\/p>\n

\u201cElements of \u201ccorpus delecti,\u201d injury or loss or harm and a criminal agency which causes such injury, loss or harm, need only be proven by a \u201creasonable probability,\u201d i.e., by slight or prima facie proof\u2026\u201d\u00a0 People v. Ramirez<\/span>, 153 Cal.Rptr. 789, 791, 91 C.A. 132.<\/p>\n

\u201c\u201cCorpus delecti\u201d of crime consists of fact of injury, loss, or harm, and existence of criminal agency as cause.\u201d\u00a0 People v. Daly<\/span>, 10 Cal.Rptr.2d 21, 28, 8 CA4th 47.<\/p>\n

\u201cGenerally, \u201ccorpus delecti\u201d of crime is (1) the fact of the loss or harm, and (2) the existence of a criminal agency as its cause.\u201d\u00a0 People v. Dorsey<\/span>, 118 Cal.Rptr. 362, 43 CA3d 953.<\/p>\n

\u201cThere\u00a0is no requirement of independent evidence \u2018of every physical act constituting an\u00a0element of an offense,\u2019 so long as there is some slight or prima facie showing of injury, loss, or harm by a criminal agency.\u201d\u00a0 In re I.M<\/span>., 23 Cal.Rptr.3d 375, 381 (2005).<\/p>\n

\u201cThe corpus delecti of a crime consists of two elements[:] the fact of the injury or loss or harm, and the existence of a criminal agency as its cause.\u201d \u00a0People v. Jones<\/span>, 949 P.2d 890, 902, 70 Cal.Rptr.2d 793, 17 Cal.4th 279.<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cWithout standing, there is no actual or justiciable controversy, and courts will not entertain such cases.\u00a0 (3 Witlen, Cal. Procedure (3rd ed. 1985) Actions \u00a7 44, pp 70-72.)\u00a0 \u201cTypically, \u2026 the standing inquiry requires careful judicial examination of a complaint\u2019s allegations to ascertain whether the particular plaintiff is entitled to an adjudication of the particular claims asserted.\u201d\u00a0 (Allen v. Wright<\/em><\/a>, (1984) 468 U.S. 737, 752\u2026Whether one has standing in a particular case generally revolved around the question whether that person has rights that may suffer some injury, actual or threatened.\u201d\u00a0 Clifford S. v. Superior Court<\/span>, 45 Cal.Rptr.2d 333, 335.<\/p>\n

\u201cAs a general principal, standing to invoke the judicial process requires an actual justiciable controversy as to which the complainant has a real interest in the ultimate adjudication because he or she has either suffered or is about to suffer an injury.\u201d\u00a0 People v. Superior Court<\/span>, 126 Cal.Rptr.2d 793.<\/p>\n

\u201cJudicial power generally is the power to adjudicate upon the legal rights of persons and property,\u00a0with reference to transactions or\u00a0occurrences existing or already had and closed\u2026The judicial\u00a0function is to \u2018declare the law and define the rights of the parties under it.\u2019\u00a0 Frasher v. Rader, 124 Cal. 133, 56 P. 797\u2026\u2019A determination of the rights of an individual\u00a0under the existing laws\u2019 is an exercise of judicial power\u2026An essential element of judicial power, distinguishing it from legislative power, is that it requires\u00a0\u201dthe ascertainment of existing rights.\u201d\u00a0 People v. Bird<\/span>, 300 P. 22, 26-27.
\nColorado<\/strong>:<\/p>\n

\u201cthe corpus delecti<\/em>\u00a0of a crime minimally requires two elements: \u201c(1) An injury which is penally proscribed\u2026and (2) The unlawfulness of some person\u2019s conduct in causing that injury.\u201d \u00a0People of the State of Colorado v. Smith<\/span>, 510 P.2d 893, 182 Colo. 31.<\/p>\n

\u201cGenerally, to subject a person to criminal liability, there must be concurrence of the actus reus, an unlawful act, and the mens rea, a culpable mental state.\u201d \u00a0Gorman v. State<\/span>, 19 P.3d 662.<\/p>\n

\u201cThe corpus delecti<\/em> ordinarily consists of a penally proscribed injury\u2026and unlawful conduct causing the injury.\u201d \u00a0People v. Trujillo<\/span>, 860 P.2d 542, 545.<\/p>\n

\u201cThe\u00a0corpus delecti<\/em>, or the fact that a crime occurred, must be proved in every case.\u201d \u00a0People v. Quinn<\/span>, 794 P.2d 1066, 1068.<\/p>\n

\u201cProperly understood the general principle is sound, for courts only adjudicate justiciable controversies\u2026 courts must look behind names that symbolize the parties to determine whether a justiciable case or controversy is presented.\u201d\u00a0 Friedrichs v. Goldy<\/span>, 387 P.2d 274, 277 [quoting United States v. Interstate Commerce Commission<\/span><\/a>, 337 U.S. 426 (1949]).<\/p>\n

\u201cThe Wimberly<\/em> standing inquiry requires a court to determine \u201c(1) whether the plaintiff was injured in fact, [and] (2) whether the injury was to a legally protected right.\u201d\u00a0 Wimberly<\/em>, 194 Colo. at 168\u2026The first prong of the standing test is a constitutional requirement since the judicial power granted \u201cby article VI of the Colorado constitution may be exercised only if an actual controversy exists, as demonstrated by real injury\u2026The second standing requirement, that the injury be to a legally protected right\u2026\u201d\u00a0 Maurer v. Young Life<\/span>, 779 P.2d 1317.<\/p>\n

\u201cThe judicial power of the state shall be vested in a supreme court, district courts, a probate court in the city and county of Denver, a juvenile court in the city and county of Denver, county courts, and such other courts or judicial officers with jurisdiction inferior to the supreme court, as the general assembly may, from time to time establish; provided, however, that nothing herein contained shall be construed to restrict or diminish the powers of home rule cities and towns granted under article XX, section 6 of this constitution to create municipal and police courts.\u201d\u00a0 Colorado constitution<\/a>, article VI, section 1.<\/p>\n

[Notice there is no distinction regarding criminal and civil jurisdictions, the “judicial power” comprehends both criminal and civil and each require a “real injury…to a…protected right…”]<\/p>\n

\u201cParties have standing if: (1) they have suffered an injury in fact; and (2) the harm is to a legally protected interest.\u201d\u00a0 Garhart ex rel. Tinsman v. Columbia\/Hathone, LLC<\/span>., 95 P.3d 571.<\/p>\n

\u201cA plaintiff has standing if he incurred an injury in fact-in-fact to a legally protected interest, as comtemplated by statutory or constitutional provisions.\u201d\u00a0 Brotman v. East Lake Creek Ranch, LLP<\/span>., 31 P.3d 886.<\/p>\n

\u201cthe legislature did not deprive the courts of judicial power which may be defined as the machinery by which persons have their rights determined\u2026\u201d\u00a0 Denver Local Union No. 13, etc. v. Perry Truck Lines<\/span>, 101 P.2d 436, 447.<\/p>\n

\u201cthe duty of this court, as of every judicial tribunal<\/em><\/strong>, is limited to determining rights<\/em><\/strong> of persons or of property, which are actually controverted in the particular case before it.\u201d\u00a0 Tyler v. Judges of the Court of Registration<\/span>, 179 U.S. 405, 21 SCt. 206, 208.<\/p>\n

Connecticut<\/strong>:<\/p>\n

\u201c\u201cCorpus delecti\u201d consists of occurrence of specific kind of loss or injury embraced in crime charged, rather than commission of crime charged by someone.\u201d\u00a0 State v. Vuilleumer<\/span>, 210 A.2d 673, 674, 3 Conn.Cir. 223.<\/p>\n

\u201cUnder the Wigmore definition, the corpus delecti consists of the occurrence of the specific loss or injury embraced in the crime charged.\u00a0 We adopt this definition.\u201d\u00a0 State v. Tillman<\/span>, 202 A.2d 494, 496.<\/p>\n

\u201cCause of action is that single group of facts which is claimed to have brought about unlawful injury to plaintiff and which entitles plaintiff to relief.\u201d\u00a0 Gurliacci v. Mayer<\/span>, 590 A.2d 914 (Conn. 1991).<\/p>\n

\u201cStanding is the legal right to set judicial machinery in motion.\u00a0 One cannot rightfully invoke the jurisdiction of the court unless he [or she] has, in an individual or representative capacity, some real interest in the cause of action, or a legal or equitable right, title or interest in the subject matter of the controversy\u2026\u201d\u00a0 West Farms Mall, LLC v. West Hartford<\/span>, 901 A.2d 649, 655-656 (Conn. 2006).<\/p>\n

\u201cIf a party is found to lack standing, the court is without subject matter jurisdiction to determine the cause\u2026[A] court lacks discretion to consider the merits of a case over which it is without jurisdiction\u2026\u201d\u00a0 Missionary Soc. v. Bd. of Pardons & Paroles<\/span>, 896 A.2d 809, 812 (Conn. 2006).<\/p>\n

\u201cOnce the question of subject matter jurisdiction has been raised, cognizance of it must be taken and the matter passed upon before [the court] can move one further step in the cause\u2026We accordingly address this issue, the question is whether the person who standing is challenged is a proper party to request an adjudication of the issue\u2026Standing requires no more than a colorable claim of injury; a [party] ordinarily establishes standing by allegations of injury.\u201d\u00a0 Wesley v. Schaller Subaru, Inc<\/span>., 893 A.2d 389, 397 (Conn. 2006).<\/p>\n

\u201cIf a party is found to lack standing, the court is wihtout subject matter jurisdiction to determine the cause.\u201d\u00a0 Cadle Co. v. D\u2019Addario<\/span>, 844 A.2d 836.<\/p>\n

\u201cThe general rule is that one party has no standing to raise another\u2019s rights.\u201d\u00a0 Security Ins. Co. of Hartford v. Lumbermens Mut. Ca. Co<\/span>., 826 A.2d 107.<\/p>\n

\u201cA party cannot rightfully invoke the jurisdiction of the court unless he has, in an individual or representative capacity, some real interest in the cause of action, or a legal or equitable right, title or interest inthe subject matter of the controversy.\u00a0 The burden rests with the party who seeks the exercise of jurisdiction in his favor to allege facts demonstrating that he is a proper party to invoke judicial resolution of the dispute and, has standing.\u201d\u00a0 Goodyear v. Discala<\/span>, 849 A.2d 791.<\/p>\n

Delaware<\/strong>:<\/p>\n

\u201cThough questioned by Wigmore, the prevailing American rule is that proof of the corpus delecti requires (1) proof of the injury, death or loss, according to the nature of the crime, and (2) proof of criminal means as the cause.\u00a0 7 Wigmore on Evidence, [section] 2072.\u00a0 This is the rule in Delaware.\u201d\u00a0 Nelson v. State<\/span>, 123 A.2d 859, 861.<\/p>\n

\u201cIn criminal prosecutions, the State need only show a \u201cbut for\u201d relationship between an action and a result to establish causation.\u201d \u00a0Bolluck v. State<\/span>, 775 A.2d 1043, 1049 (2001.<\/p>\n

\u201cThe party invoking the jurisdiction of a court bears the burden of establishing the elements of standing. The degree and manner of evidence that is required to establish standing varies as the successive of any litigation proceeds.\u00a0 At the pleading stage, general allegations of injury are sufficient to withstand a motion to dismiss\u2026When a motion for summary judgment is filed however, the plaintiff can no longer rest on such \u201cmere allegations.\u201d \u2026 The term \u201cstanding\u201d refers to the right of a party to invoke the jurisdiction of a court to enforce a claim or to redress a grievance.\u00a0 Standing is a threshold question that must be answered by a court affirmatively to ensure that the litigation before the tribunal is a \u201ccase or controversy\u201d that is appropriate for the exercise of the court\u2019s judicial powers.\u00a0 The issue of standing is concerned \u201conly with the question of who is entitled to mount a legal challenge and not with the merits of the subject matter in controversy.\u201d\u00a0 To establish standing, a plaintiff must demonstrate first, that he or she sustained an \u201cinjury-in-fact\u201d; and second, that the interests he or she seeks to be protected are within the zone of interests to be protected.\u201d\u00a0 Dover Hist. Soc. v. Dover Planning Com\u2019n<\/span>., 838 A.2d 1103, 1109-1110 ( Del.2003).<\/p>\n

Florida<\/strong>:<\/p>\n

\u201cCausation consists of two distinct subelements.\u00a0 As legal scholars have recognized, before a defendant can be convicted of a crime that includes an element of causation, the State must prove beyond a reasonable doubt that the defendant\u2019s conduct was (1) the \u201ccause in fact\u201d and (2) the \u201clegal cause\u201d (often called \u201cproximate cause\u201d) of the relevant harm\u2026In order to establish that a defendant\u2019s conduct was the \u201ccause in fact\u201d of a particular harm, the State usually must demonstrate that \u201cbut for\u201d the defendant\u2019s conduct, the harm would not have occurred.\u201d\u00a0 Eversly v. State<\/span>, 748 So.2d 963, 966-967 (Fla. 1999).<\/p>\n

\u201c\u201dA Cause of action is some particular legal right of plaintiff against defendant, together with some definite violation thereof which occasions loss or damage.\u201d\u00a0 Luckie v. McCall Manufacturing Co., 152 So.2d 311, 314\u2026\u201d\u00a0 Soowal v. Marden<\/span>, 452 So.2d 625, 626.<\/p>\n

\u201cIt is a fundamental principle of law that no person be adjudged guilty of a crime until the state has shown that a crime has been committed.\u00a0 The state therefore must show that a harm has been suffered of the type contemplated by the charges (for example, a death in the case of a murder charge or a loss of property in the case of a theft charge), and that such harm was incurred due to the criminal agency of another.\u00a0 Thus, it is sufficient if the elements of the underlying crime are proven rather than those of the particular degree or variation of that crime which may be charged.\u201d\u00a0 State v. Allen<\/span>, 335 So. 2d 823,825 (Fla. 1976).<\/p>\n

\u201cA party has standing when he or she has a sufficient stake in a justiciable controversy.\u00a0 Sierra Club v. Morton<\/em><\/a>, 405 U.S. 727, 731\u2026To establish standing it must be shown that the party suffered injury in fact (economic or otherwise) for which relief is likely to be addressed.\u00a0 See Warth v. Seldin<\/a> <\/em>, 422 U.S. 490, 501\u2026it may not be abstract, conjectural or hypothetical.\u00a0 Allen v. Wright<\/em><\/a>, 468 U.S. 737, 791\u2026\u201d\u00a0 Peregard v. Cosmides<\/span>, 663 So.2d 665, 668.<\/p>\n

\u201cA litigant must assert his or her own legal rights and interests, and cannot rest claim to relief on the legal rights or interests of third paries.\u201d\u00a0 Alterra Healthcare Corp. v. Estate of Shelley<\/span>, 827 So.2d 936.<\/p>\n

\u201cGenerally, to have standing to bring an action the plaintiff must allege that he has suffered or will suffer a special injury.\u201d\u00a0 Alachua County v. Scharps<\/span>, 855 So.2d 195.<\/p>\n

Georgia<\/strong>:<\/p>\n

\u201cIn defining \u2018corpus delecti\u2019 Wharton says: \u2018It is made up of two elements: (1) That a certain result has been produced\u2026(2) That some one is criminally responsible for the result\u2026\u201d\u00a0 McVeigh v. State<\/span>, 53 S.E.2d 462, 469.<\/p>\n

\u201cA cause of action is some particular right of the plaintiff against the defendant, together with some definite violation of that right which occasions damage, whether the right arises by contract or tort.\u00a0 Ellison v. Ga. R. Co.<\/em>, 87 Ga. 691, 13 S.E. 809 (1891); City of Columbus v. Anglin<\/em>. 120 Ga. 785(4), 48 S.E. 318 (1904).\u00a0 It may also be defined from the standpoint of duties, provided the complainant has proven a duty owed by the defendant to him, and a breach of that duty shown which results in loss to the complainant.\u00a0Ellison v. Ga. R. Co.<\/em>,\u00a0supra.\u00a0 There can be no right of action until there has been a wrong, that is, a violation of a legal right or breach of a legal duty\u2026\u201d\u00a0 Bryant v. Randall<\/span>, 261 S.E.2d 602,\u00a0605-606.<\/p>\n

\u201cParticular remedy is not available to party who has no entitlement to right sought to be secured.\u201d\u00a0 Ragsdale v. New England Land and Development Corp<\/span>., 297 S.E.2d 31.<\/p>\n

\u201cStanding deals with question of whether party may assert right even presuming it exists.\u201d\u00a0 Nationwide Mortg. Resources, Inc. v. Stalzer<\/span>, 455 S.E.2d 402.<\/p>\n

Hawaii<\/strong>:<\/p>\n

\u201cIn order to prove that a crime occurred, the State must prove beyond a reasonable doubt: (1) the basic injury \u2026, (2) the fact that the basic injury was the result of a criminal, rather than a natural or accidental\u00a0cause\u2026\u201d\u00a0 State v. Libero<\/span>, 83 P.3d 753, 763 (2003), [quoting State v. Dudoit<\/span>, 55 Haw. 1, 2, 514 P.2d 373, 374 (1973)].<\/p>\n

\u201c\u201cCorpus delecti\u201d of any particular crime means actual commission of crime by someone and it made up of two elements; that is, certain result has been produced and some person is criminally responsible for the act.\u201d\u00a0 State v. Hale<\/span>, 367 P.2d 81, 85, 45 Haw. 269.<\/p>\n

\u201cPlaintiff without standing is not entitled to invoke a court\u2019s jurisdiction.\u201d\u00a0 Mottle v. Miyahira<\/span>, 23 P.3d 716.<\/p>\n

\u201cPetitioner must satisfy all three prongs of the three-part \u201cinjury-in-fact\u201d test to establish its standing.\u201d\u00a0 Sierra Club v. Hawai\u2019I Tourism Authority ex rel Board of Directors<\/span>, 59 P.3d 877.<\/p>\n

Idaho<\/strong>:<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cIn Miles v. Idaho Power Co<\/em>, 116 Idaho 635, 778 P.2d 757 (1989), the court stated three basic propositions concerning standing that guide our decision here: 1. \u201cThe doctrine of standing focuses on the party seeking relief and not on the issues the party wishes to have adjudicated.\u201d 2. \u201c[T]o satisfy the case or controversy requirement of standing, litigants generally must allege or demonstrate an injury in fact and a substantial likelihood that the judicial relief requested will prevent or redress the claimed injury.\u201d\u00a0 Boundary Backpackers v. Boundary County<\/span>, 913 P.2d 1141, 1145.<\/p>\n

\u201cPerson wishing to invoke a court\u2019s jurisdiction must have standing\u2026Doctrine of standing focuses on the party seeking relief and not on the issues the party wishes to have adjudicated\u2026To satisfy the requirement of standing, the petitioners must allege or demonstrate an injury in fact and a substantial likelihood that the judicial relief requested will prevent or redress the claimed injury.\u201d\u00a0 Schneider v. Howe<\/span>, 133 P.3d 1232.<\/p>\n

\u201cThe issue of standing is jurisdictional and may be raised at any time.\u201d\u00a0 Beach lateral Water Users Ass\u2019n v. Harrison<\/span>, 130 P.3d 1138.<\/p>\n

\u201cThe doctrine of standing focuses on the party seeking relief and not the issues the party wishes to have adjudicated.\u201d\u00a0 Troutner v. Kempthorn<\/span>, 128 P.3d 926.<\/p>\n

\u201cStanding is a fundamental prerequisite to invoking a court\u2019s jurisdiction.\u201d\u00a0 Noh v. Cenarrusa<\/span>, 53 P.3d 1217.<\/p>\n

Illinois<\/strong>:<\/p>\n

\u201cOccurrence of injury or loss, and its causation by criminal conduct, are termed the \u201ccorpus delecti.\u201d\u00a0 People v. Assenato<\/span>, 586 N.E.2d 445, 448, 166 Ill.Dec. 487, 490.<\/p>\n

\u201c\u201cCorpus delecti\u201d of an offence consists of fact that injury occurred and fact that injury was caused by a criminal act.\u201d\u00a0 People v. Lewis<\/span>, 498 N.E.2d 1169, 1174, 101 Ill.Dec. 661, 666.<\/p>\n

\u201cIt is elementary that the corpus delecti<\/em> constitutes an essential element of a criminal prosecution\u2026\u201d\u00a0 People v. O\u2019Neil<\/span>, 165 N.E.2d 319, 320.<\/p>\n

\u201cRather, we understand the rule to be that the corpus delecti<\/em>, like every essential element of a criminal case, must be proved by competent evidence beyond a reasonable doubt.\u201d\u00a0 People v. Jones<\/span>, 177 N.E.2d 112, 114.<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cIn Illinois, standing requires only some injury in fact to a legally cognizable interest and the injury, whether actual or threatened, must be distinct and palpable, fairly traceable to the defendant\u2019s actions, and substantially likely to be prevented or redressed by the\u2026relief requested.\u201d\u00a0 In re D.W.<\/span>, 799 N.E.2d 410.<\/p>\n

\u201cStanding requries only some injury in fact to a legally cognizable interest.\u201d \u00a0 In re County Treasurer and Ex Officio County Collector of Cook County<\/span>, 775 N.E.2d 86.<\/p>\n

\u201cThis court has repeatedly held that standing requires some injury in fact to a legally recognized interest.\u201d\u00a0 In re Estate of Wellman<\/span>, 673 N.E.2d 272, 276 (Ill. 1996).<\/p>\n

\u201cThe definition of judicial power given by Judge Cooley in his work on Constiutional Limitations, held by this court to be sufficiently accurate\u00a0 for the purposes of the question then before the court, which was in substance the same as that now under consideration, is as follows: \u201cThe power which adjudicates upon and protects the rights and interests of individual citizens, and to that end construes and applies the laws.\u201d\u00a0 Owners of Lands v. People, 113 Ill. 309.\u201d\u00a0 People v. Chase<\/span>, 46 N.E. 454, 458.\u00a0 Also quoted in People v. Bruner<\/span>, 175 N.E. 400, 404<\/p>\n

\u201c\u201dJudicial power\u201d implies the construction of laws and the adjudication of legal rights\u2026[note 6] No law is construed by the board, and no legal rights are submitted to and adjudicated by it, without which, we have seen, judicial power is not exercised.\u201d\u00a0\u00a0People v. Appelbaum<\/span>, 95 N.E. 995, 997.<\/p>\n

\u201cJudicial power is the power which adjudicates upon the rights of citizens, and to that end construes and applies the law.\u201d\u00a0\u00a0People v. Hawkinson<\/span>, 155 N.E. 318, 319.<\/p>\n

Indiana<\/strong>:<\/p>\n

\u201cCorpus delecti consists of a showing of \u201c1) the occurrence of the specific kind of injury and 2) someone\u2019s criminal act as the cause of the injury.\u201d”\u00a0 Johnson v. State<\/span>, 653 N.E.2d 478, 479 (Ind. 1995).<\/p>\n

\u201cState must produce corroborating evidence of \u201ccorpus delecti,\u201d showing that injury or harm constituting crime occurred and that injury or harm was caused by someone\u2019s criminal activity.\u201d\u00a0 Jorgensen v. State<\/span>, 567 N.E.2d 113, 121.<\/p>\n

\u201cTo establish the corpus delecti, independent evidence must be presented showing the occurrence of a specific kind of injury and that a criminal act was the cause of the injury.\u201d\u00a0 Porter v. State<\/span>, 391 N.E.2d 801, 808-809.<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cThe distinction between torts and\u00a0crimes is\u00a0based upon the public nature of the criminal offense.\u00a0 \u201cAlthough the same act may constitute both a crime and\u00a0a tort, the crime is an offense against the public pursued by the sovereign, while the tort is a private injury which is pursued by the injured party.\u201d\u00a0 14 Am.Jur. 755, [section] 3.\u00a0 The same distinction has been noted by another authority in the following language:\u00a0 \u201cThe real distinction between a tort and a crime is to be sought for, not in a difference between their tendencies, but in the\u00a0difference between the methods by\u00a0which\u00a0the remedy for\u00a0the wrong is pursued, a wrong for\u00a0which the remedy is pursued by and at the discretion of the individual injured or his representative being a tort, and a wrong for which the wrongdoer is proceeded against by the sovereign or state for the purpose of punishment being a crime.\u201d\u00a0 State v. White Circuit Court<\/span>, 77 N.E.2d 298, 300-301.<\/p>\n

\u201cStanding is a fundamental, threshold, constitutional issue that must be addressed by this, or any, court to determine if it should exercise jurisdiction in the particular case before it.\u00a0 The issue of standing focuses on whether the complaining party is the proper one to invoke the court\u2019s power.\u00a0 Scott v. Randell<\/em>, 736 N.E.2d 308 (Ind.Ct.App.2000)\u2026To establish standing, therefore, a plaintiff must demonstrate a personal stake in the outcome of the lawsuit and that the injury is a result of the defendant\u2019s conduct [citation omitted].\u00a0 If properly challenged, when a plaintiff fails to establish standing in the pleadings, the court must dismiss the complaint.\u00a0 Shulz v. State<\/span>, 731 N.E.2d 1041.\u00a0 Moreover:<\/p>\n

Although the Indiana constitution contains no \u201ccase or controversy\u201d requirement, the federal limits on justiciability are instructing because the standing requirement under both federal and state constitutional law fulfills the same purpose; ensuring that the litigant is entitled to have the court decide the merits of the dispute or of the particular issues.\u00a0 Id. at 1044.\u00a0 Under the federal test, to establish standing a plaintiff must allege a personal injury that is fairly traceable to the defendant\u2019s allegedly unlawful conduct and is likely to be redressed by the requested relief.\u00a0 Id. citing Allen v. Wright<\/em><\/a>, 768 U.S. 737\u2026\u201d\u00a0 Alexander v. PSB Lending Corp<\/span>, 800 N.E.2d 984, 989.<\/p>\n

\u201cUnder the general rule of standing, only those persons who have a personal stake in the outcome of the litigation and who show that they have suffered or were in immediate danger of suffering a direct injury as a result of the complained-of conduct will be found to have standing; absent this showing, complainants may not invoke the jurisdiction of the court.\u201d\u00a0 State ex rel Citidine v. Indiana Dept. of Trans<\/span>.,790 N.E.2d 978.<\/p>\n

Iowa<\/strong>:<\/p>\n

While the corpus delecti must be proved beyond all reasonable doubt, yet it may be established by circumstantial as well as direct evidence.\u00a0 State v. Wescott<\/span>, 104 N.W. 341, 130 Iowa 1; State v. Kelly<\/span>, 186 N.W. 834, 193 Iowa 62.<\/p>\n

\u201cThe principals of causation\u00a0normally associated with civil tort litigation are pertinent in\u00a0criminal cases.\u00a0 State v. Murray<\/em>, 512 N.W.2d 547, 550 (Iowa 1994).\u201d\u00a0 State v. Garcia<\/span>, 616 N.W.2d 594, 596 (Iowa 2000).<\/p>\n

\u201cIn order for there to be a \u201cright of action\u201d or \u201ccause of action,\u201d there must be a legal right in plaintiff corresponding duty on part of the defendant and attendant breach of that duty with resultant harm to plaintiff\u2026\u201d\u00a0 Giltner v. Stark<\/span>, 252 N.W.2d 743.<\/p>\n

\u201cTo have standing, complaining party must have specific, personal, and legal interest in the litigation and be injuriously affected.\u201d\u00a0 In re Marriage of Mitchell<\/span>, 531 N.W.2d 132.<\/p>\n

\u201cone should bear in mind the fundamental principal that courts are instituted to afford relief to persons whose rights have been invaded, or are threatened with invasion by the defendant\u2019s act or conduct\u2026\u201d\u00a0 Bowers v. Bailey<\/span>, 21 N.W.2d 773, 776.<\/p>\n

\u201cCorpus delecti is made up of two element: (1) a result has been produced\u2026(2) some one is criminally responsible for the result.\u201d\u00a0 State v. Stamper<\/span>, 195 N.W.2d 110, 112-113.<\/p>\n

\u201cIn our opinion, the term [corpus delecti] means, when applied to any particular offense, that the particular crime charged has actually been committed by some one.\u00a0 It is made up of two elements: First, that a certain result has been produced\u2026second, that some one is criminally responsible for the result.\u201d\u00a0 State v. Whisler<\/span>, 3 N.W.2d 525, 528.<\/p>\n

Kansas<\/strong>:<\/p>\n

\u201cWe first note that standing is a jurisdictional issue in Kansas\u2026As a result, standing is not waivable.\u201d\u00a0 Midcontinental Specialists v. Capital Homes<\/span>, 106 P.3d 483.<\/p>\n

\u201cStanding is a question of whether the plaintiff has alleged such a personal stake in he outcome of a controversy as to warrant invocation of jurisdiction and to justify\u00a0 exercise of the courts\u2019 remedial powers on his behalf\u2026The party must have personally suffered some injury and there must be a causal connection between the injury and the challenged conduct.\u201d\u00a0 Moorhouse v. City of Wichta<\/span>, 913 P.2d 172, 176.<\/p>\n

\u201cGenerally, \u201cstanding\u201d requires that a plaintiff have a personal interest in the court\u2019s decision, and that he or she personally has suffered some actual or threatened injury as a result of a putatively illegal conduct of the defendant.\u201d\u00a0 Lower v. Bd. of Directors of Haskell County Cemetary Dist<\/span>., 56 P.3d 235.<\/p>\n

\u201cStanding is a jurisdictional issue.\u201d\u00a0 Nichols v. Kansas Governmental Ethics Com\u2019n<\/span>., 18 P.3d 270.<\/p>\n

\u201cIt is the primary duty of the courts to safeguard the declaration of right and remedy guaranteed by the constitutional provision insuring a remedy for all injuries.\u201d\u00a0 Noel v. Menninger Foundation<\/span>, 267 P.2d 934, 943.<\/p>\n

Kentucky<\/strong>:<\/p>\n

\u201cBefore a party can have a controversy judicially determined, he must have an interest in the subject matter\u2026Generally, a defect in parties or objections based upon the absence of a legal right to maintain\u00a0an action should be raised\u00a0by a demurrer, plea in abatement or in bar.\u201d\u00a0 Thompson-Starrett Co. v. Mason\u2019s Adm\u2019rs<\/span>., 201 S.W.2d 786, 883.<\/p>\n

Louisiana:<\/strong><\/p>\n

<\/a><\/strong>All government, of right, originates with the people, is founded on their will alone, and is instituted to protect the rights of the individual and for the good of the whole. Its only legitimate ends are to secure justice for all, preserve peace, protect the rights, and promote the happiness and general welfare of the people. The rights enumerated in this Article are inalienable by the state and shall be preserved inviolate by the state. \u201c\u00a0 Article I \u00a7 1, Louisiana constitution<\/a>.<\/a><\/strong><\/p>\n

\u201c\u201cCorpus delecti,\u201d the body or substance of a crime, is composed of two elements: occurrence of an unlawful injury, and illegal conduct causing that injury.\u201d\u00a0 State v. Outlaw<\/span>, 485 So.2d 217, 221.<\/p>\n

\u201cCorpus delecti, the body or substance of a crime, has two elements: (1) an unlawful injury has occurred; and (2) some person\u2019s illegal conduct caused that injury.\u201d\u00a0 State v. Reed<\/span>, 420 So.2d 950, 951.<\/p>\n

Maine:<\/strong><\/p>\n

\u201cThe United States Supreme Court as stated that standing requires one who as suffered an injury to show that the injury in fact is fairly traceable to the challenged action and that such injury is likely to be redressed by the judicial relief sought.\u00a0\u00a0 Allen v. Wright<\/em><\/a> , 468 U.S. 737\u2026We have previously held that to have standing a litigant must have suffered a particularized injury that is distinct from the harm suffered by the public at large\u2026We have construed particularized injury as an injury resulting from an action adversely and directly affecting the party\u2019s property, pecuniary or personal rights.\u00a0 New England Herald Dev. Group v. Town of Falmouth<\/em>, 521 A.2d 693, 695 (Me. 1987).\u201d\u00a0 Proctor v. County of Penobscot<\/span>, 651 A.2d 355, 357.<\/p>\n

You\u2019ll notice that the attorney for the County wrote: a plaintiff \u201cgenerally must assert his own legal rights and interest and cannot rest his claim to relief on the legal rights or interest of third parties.\u201d\u00a0 Also at page 357.<\/p>\n

\u201cThe requirement for standing that a party suffer an injury that is fairly traceable to the challenged action is met when a defendant\u2019s actions have adversely affected and directly affected the party\u2019s property, pecuniary or personal rights.\u201d\u00a0 Collins v. State<\/span>, 750 A.2d 1257, 1260.<\/p>\n

Maryland<\/strong>:<\/p>\n

\u201cWhile the corpus delecti<\/em> must be proved beyond a reasonable doubt\u2026it may be established by circumstantial evidence\u2026\u201d\u00a0 James v. State<\/span>, 248 A.2d 910, 912.<\/p>\n

\u201cProperly understood the general principle is sound, for courts only adjudicate justiciable controversies\u2026 courts must look behind names that symbolize the parties to determine whether a justiciable case or controversy is presented.\u201d\u00a0 Blind Industries v. D.G.S<\/span>., 808 A.2d 782, 784 (Md. 2002) [quoting United States v. Interstate Commerce Commission<\/span><\/a>, 337 U.S. 426 (1949)].<\/p>\n

Massachusetts<\/strong>:<\/p>\n

\u201cThe end of the institution, maintenance, and administration of government is to secure the existence of the body-politic, to protect it, and to furnish the individuals who compose it with the power of enjoying, in safety and tranquillity, their natural rights and the blessings of life\u2026\u201d\u00a0 Preamble<\/a>, Massachusetts Constitution 1780, still in current constitution<\/a> .<\/p>\n

\u201cCriminal responsibility is imposed on the basis of the intentional doing of an act with awareness of the probability that the act will result in substantial damage, regardless of whether the injury turns out to be minor or insignificant.\u201d\u00a0 Com. v. Ruddock<\/span>, 520 N.E.2d 501.<\/p>\n

\u201cThe issue of standing may be raised at any time.\u201d\u00a0 In re Harvard Pilgrim Healthcare, Inc.<\/span>, 746 N.E.2d 513.<\/p>\n

\u201cTo have standing in any capacity, a litigant must show that the challenged action has caused litigant injury.\u201d\u00a0 Perella v. Massachusetts Turpike Auth<\/span>., 772 N.E.2d 70.<\/p>\n

\u201cCourts are not established to enable parties to litigate in which they have no interest affecting their liberty, rights or property.\u201d\u00a0 Razin v. Razin<\/span>, 124 N.E.2d 269, 270.<\/p>\n

Michigan<\/strong>:<\/p>\n

\u201cLack of license to carry a concealed weapon established that crime had been committed and therefore was part of the \u201ccorpus delecti.\u201d\u00a0 People v. Autry<\/span>, 152 N.W.2d 55, 56, 7 Mich.App.480.<\/p>\n

\u201c\u201cCorpus delecti\u201d includes fact of specific loss or injury and someone\u2019s criminality.\u201d\u00a0 People v. Randall<\/span>, 201 N.W.2d 292, 293, 42 Mich.App. 187.<\/p>\n

\u201c\u201cCorpus delecti,\u201d meaning body or substance of crime charged, involves two elements: injury which is penally proscribed and unlawfulness of some person\u2019s conduct in causing injury.\u201d\u00a0 People v. Swift<\/span>, 470 N.W.2d 491, 492, 188 Mich.App. 619.<\/p>\n

\u201cFor there to be criminal responsibility, defendant\u2019s acts must have caused harm.\u201d\u00a0 People v. Zak<\/span>, 457 N.W.2d 59.
\n\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cAlthough the same act may constitute both a crime and\u00a0a tort, the crime is an offense against the public pursued by the sovereign, while the tort is a private injury which is pursued by the injured party.\u201d\u00a0 People v. Veenstra<\/span>, 60 N.W.2d 309, 310-311.<\/p>\n

\u201cStanding relates to civil as well as criminal matters.\u201d\u00a0 People v. Smith<\/span>, 360 N.W.2d 841, 844-845 (Mich. 1984).<\/p>\n

\u201cIn order to have standing, a party must have a legally protected interest that is in jeopardy of being adversely affected.\u201d\u00a0 In re Foster<\/span>, 573 N.W.2d 324, 328.<\/p>\n

\u201cPlaintiff must assert his own legal rights and interests and cannot rest his claim to relief on legal rights or interests of third parties.\u201d\u00a0 Fieger v. Commissioner of Ins<\/span>., 437 N.W.2d 271.<\/p>\n

\u201cTo adjudicate upon and protect the rights and interests of individual citizens, and to that end to construe and apply the laws, is the peculiar province of the judicial department\u2026The primary functions of the judiciary are to declare what the law is and to determine the rights of parties conformably thereto.\u201d\u00a0 Johnson v. Kramer Bros. Freight Lines, Inc.<\/span>, 98 N.W.2d 586, 588.<\/p>\n

Minnesota<\/strong>:<\/p>\n

\u201cOBJECT OF GOVERNMENT. Government is instituted for the security, benefit and protection of the people, in whom all political power is inherent, together with the right to alter, modify or reform government whenever required by the public good.\u201d\u00a0 Minnesota constitution Article I \u00a7 1<\/a>.<\/p>\n

\u201cJUDICIAL POWER<\/strong>\u2026Power that adjudicates upon and protects the rights and interests of persons or property, and to that end declares, construes and applies the law, In re Hungstiger, 130 Minn. 474, 153 N.W. 869, 870; People ex rel. Rusch v. White 334 Ill. 465, 166 N.E. 100, 106, 64 A.L.R. 1006; In re Assessment of Kansas City Southern Ry. Co., 168 Okl. 495, 33 P.2d 772, 775\u2026\u201d\u00a0 Black\u2019s Law Dictionary, Rev. 4th Ed<\/span>., page 986.\u00a0 [Could be used anywhere]<\/p>\n

The corpus delecti must be proven beyond a reasonable doubt.\u00a0 State v. Lalizer<\/span>, 4 Minn. 368.<\/p>\n

\u201cA \u201ccause of action\u201d is a violation of a legal right.\u201d\u00a0 Halliwill v. Mutual Service Ca. Ins. Co<\/span>., 100 N.W.2d 817.<\/p>\n

\u201cTo have standing to bring claim, a person must have suffered some injury in fact as a result of the alleged actions.\u201d\u00a0 Epland v. Meade Ins. Agency Associates<\/span>, 564 N.W.2d 203, 208 (Minn. 1997).<\/p>\n

\u201cJudicial power is the power that adjudicates upon the rights or persons or property, and to that end declares, construes and applies the law.\u201d\u00a0 In re Hunstiger<\/span>, 153 N.W. 869, 870.<\/p>\n

Mississippi<\/strong>:<\/p>\n

\u201cThe Latin words \u201ccorpus\u00a0delecti\u201d mean literally, \u201cthe body of the crime\u201d.\u00a0 In order to prove the corpus delecti, there are two elements which must be proved beyond a reasonable doubt:\u00a0 One, the existence of a\u00a0certain act or result forming the basis of that criminal charge; and, two, the existence of criminal agency as the cause of this act or result\u2026It is a well-settled principal of criminal law that a conviction for crime cannot be had unless the corpus delecti-that is, the fact that a crime has actually been perpetrated (the fact of injury or harm and the existence of some person criminally responsible therefore)-is first established by the prosecution.\u00a0 In other words, the prosecution must establish the actual commission, by someone, of the particular offense charged.\u00a0 The accused is not required in any case to answer a charge against him in the absence of evidence upon the part of the prosecution sufficient to establish the corpus delecti; and if an accused is found guilty despite the failure of the prosecution to establish the corpus delecti, the verdict may be set aside and a new trial ordered\u2026the reason the state is requried to prove the corpus delecti is to satisfy the mind that there is a real and not an imaginary crime for which the accused stands charged.\u201d\u00a0 Kirtkland v. State<\/span>, 371 So.2d 402, 404.<\/p>\n

\u201cIt [corpus delecti] has two elements which must be proven beyond a reasonable doubt in order to show that a crime has actually been committed [citations omitted].\u00a0 First, it is necessary to prove the existence of a certain act or result forming the basis of the criminal charge\u2026Moreover, the State must prove the existence of criminal agency as the cause of this act or result\u2026However, \u201c[e]very element, criminal charge, and criminal agency myst be proved beyond a reasonable doubt.\u201d”\u00a0 Parks v. State<\/span>, 884 So.2d 738, 743 (Miss. 2004).<\/p>\n

\u201cThe United States Supreme Court has stated the concept of standing generally embraces \u201cthe general prohibition on a litigant raising another person\u2019s legal rights\u2026\u201d\u00a0 Mount v. Mount<\/span>, 624 So2d. 997, 1001.<\/p>\n

\u201cA suit cannot be maintained where it appears from the declaration itself the right of action is not in the party suing, but in another.\u201d\u00a0 Haynes v. Ezell<\/span>, 25 Miss. (3 Cushm.) 242.<\/p>\n

Missouri<\/strong>:<\/p>\n

\u201cTo prove guilt of any crime, State must first demonstrate the crime\u2019s corpus delecti, or body of crime, consisting of two elements \u2013 that loss or injury charged has occurred and that someone\u2019s criminal agency caused loss or injury.\u201d\u00a0 State v. Davis<\/span>, 797 S.W.2d 560.<\/p>\n

\u201c\u201dCorpus delecti\u201d consists of proof, direct or circumstantial, the specific loss or injury occurred and criminal behavior by someone as cause of loss or injury.\u201d\u00a0 State v. Frentzel<\/span>, 730 S.W.2d 554.<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201c\u201cCorpus delecti\u201d consists of two elements: proof, direct or circumstantial, that specific loss or injury occurred, and that someone\u2019s criminality is cause of loss or injury; proof need not include proof of defendant\u2019s connection with crime charged.\u201d\u00a0 State v. Friesen<\/span>, 725 SW2d 638, 639.<\/p>\n

\u201cLack of standing cannot be waived.\u201d\u00a0 In re Ancillary Adversary Proceeding Questions<\/span>, 89 S.W.3d 460.<\/p>\n

\u201cA party seeking relief must have a legally cognizable interest in the subject matter and a threatened or actual injury to have standing.\u201d\u00a0 Meyer v. Meyer<\/span>, 77 S.W.3d 40.<\/p>\n

\u201cA party is \u201cinjured\u201d for purposes of determining whether a party has standing to sue, if a legal right of that party is violated.\u201d\u00a0 R.J.S. Sec., Inc. v. Command Sec. Services, Inc<\/span>., 101 S.W.3d 1.<\/p>\n

\u201cRegardless of the action\u2019s merits, unless the parties to the action have proper standing, a court may not entertain the action\u2026Standing requires that a party seeking relief have a legally cognizable interest in the\u00a0subject matter and that\u00a0he has a threatened or actual injury.\u201d\u00a0 E. Mo. Laborers D. Coun. v. St. Louis Cty<\/span>., 781 S.W.2d 43, 45-46\u00a0(Mo.banc 1989).<\/p>\n

Montana<\/strong>:<\/p>\n

\u201cGenerally speaking, the term \u201ccorpus delecti,\u201d when applied to any particular offense, means that the specific crime charged has actually been committed by some one, and it is made up of two elements: First, that a certain result has been produced\u2026second, that some one is criminally responsible for the result\u2026\u201dState v. Kindle<\/span>, 227 P. 65, 67.<\/p>\n

\u201cWe have previously stated that the following criteria must be satisfied to establish standing: (1) The complaining party must clearly allege past, present or threatened injury to a property or civil right; and (2) the alleged injury must be distinguishable from the injury to the public generally, but the injury need not be exclusive to the complaining party.\u201d\u00a0 Gryczan v. State<\/span>, 942 P.2d 112, 118.<\/p>\n

\u201cStanding is a threshold requirement of every case.\u201d\u00a0 Palmer v. Bahm<\/span>, 128 P.3d 1031.<\/p>\n

\u201c\u2018Standing\u2019 is a person\u2019s right to make a legal claim or seek judicial enforcement of a duty or right.\u201d\u00a0 In re Parenting of D.A.H<\/span>., 109 P.3d 247.<\/p>\n

\u201cStanding is part of the larger question whether a controversy is justiciable.\u201d Stroebe v. State<\/span>, 127 P.3d 1051.<\/p>\n

\u201cIt is axiomatic and this court has consistently held that the existence of a justiciable controversy is a threshold requirement in order for a court to grant relief\u2026To maintain an action the plaintiff must show that he has a right to be enforced or a wrong to be prevented or redressed\u2026but he is is without standing where it is not shown that his rights have been, or are about to be, invaded.\u201d\u00a0 Powder River County v. State<\/span>, 60 P.3d 357, 379 (Mont. 2002).<\/p>\n

\u201cStanding to sue refers to a \u201cparty\u2019s right to make a legal claim or seek judicial enforcement of a duty or right\u2026A threshold requirement of every case is that a party have standing to bring the action\u2026The mere fact that a person is entitled to bring an action under a given statute is insufficient to establish standing; the party must allege some past, present, or threatened injury which would be alleviated by successfully maintaining the action\u2026Since the general rule is that \u2018a litigant may only assert his own constitutional rights or immunities\u2026\u2019\u201d\u00a0 In re B.F<\/span>., 87 P.3d 427, 430-431.<\/p>\n

Nebraska<\/strong>:<\/p>\n

\u201cTo sustain a conviction, the corpus delecti must be proved beyond a reasonable doubt.\u201d\u00a0 State v. George<\/span>, 424 N.W.2d 350, 351.<\/p>\n

The corpus delecti must be proven beyond a reasonable doubt.\u00a0 Chezem v, State<\/span>, 76 N.W. 1056, 56 Neb. 496; McCue v. State<\/span>, 198 N.W. 163, 112 Neb. 9<\/p>\n

\u201cTo establish standing to being suit it is necessary to show that party is in danger of sustaining direct injury as result of anticipated action\u2026\u201d\u00a0 First Federal Sav. & Loan Assn. of Lincoln v. Department of Banking<\/span>, 192 N.W.2d 736.<\/p>\n

\u201d To have standing to invoke a tribunal\u2019s jurisdiction, one must have some legal or equitable right, title or interest in the subject of the controversy.\u201d\u00a0 Douglas County Bd. of Com\u2019rs v. Civil Service Com\u2019n, Douglas County<\/span>, 641 N.W.2d 55.<\/p>\n

\u201cIn order to have standing, a litigant must assert the litigant\u2019s own legal rights and interests and cannot rest his or her claim on the legal rights or interests of third parties\u2026\u201d\u00a0 Adam v. City of Hastings<\/span>, 676 N.W.2d 710.<\/p>\n

\u201cStanding is the legal or equitable right, title or interest in the subject of the controversy\u2026Standing relates to the court\u2019s power, that is, jurisdiction, to address the issues presented and serves to indentify those disputes which are appropriately resolved through the judicial process\u2026Standing is a jurisdictional component of a party\u2019s case because only a party who has standing may invoke the jurisdiction of a court\u2026The purpose of an inquiry as to standing is to determine whether one has a legally protectable interest or right in the controversy\u2026In order to have standing, a litigant must assert the litigant\u2019s own legal rights and interests and cannot rest his or her claim on the legal rights or interests of third parties.\u201d\u00a0 County of Sarpy v. City of Gretna<\/span>, 678 N.W.2d 740 (Neb. 2004).<\/p>\n

\u201cA cause of action is judicial protection of one\u2019s recognized right or interest, when another, owing a corresponding duty not to invade or violate such right or interest, has caused a breach of that duty.\u201d\u00a0 Millman v. County of Butler<\/span>, 458 N.W.2d 207, 214.<\/p>\n

\u201cgenerally judicial power is the authority to hear and determine a controversy as to rights and upon such determination to render a judgment binding upon the disputants.\u201d\u00a0 Laverty v. Cochran<\/span>, 271 N.W. 354, 357.<\/p>\n

New Hampshire<\/strong>:<\/p>\n

\u201cTo establish causation, the State needed to prove not only that the prohibited result would not have occurred but for the conduct of the defendant, but also that the defendant\u2019s conduct was the legal (or proximate) cause of the prohibited result.\u201d \u00a0State v. Lamprey<\/span>, 821 A.2d 1080, 1082 (N.H. 2003)<\/p>\n

\u201cIn evaluating whether a party has standing to sue, we focus on whether the plaintiff suffered a legal injury against which the law was designed to protect.\u201d\u00a0 Roberts v. General Motors Corp<\/span>., 643 A.2d 956, 958 (N.H. 1994).<\/p>\n

\u201cIn evaluating whether a party has standing to sue, we focus on whether the plaintiff suffered a legal injury against which the law was\u00a0designed to protect\u2026Here, the plaintiffs suffered no injury\u2026They therefore lack standing\u2026\u201d\u00a0 Malnati v. State<\/span>, 803\u00a0A.2d 587, 590 (N.H. 2002).<\/p>\n

\u201cthe duty of this court, as of every judicial tribunal<\/em><\/strong>, is limited to determining rights<\/em><\/strong> of persons or of property, which are actually controverted in the particular case before it.\u201d\u00a0 Tyler v. Judges of the Court of Registration<\/span>, 179 U.S. 405, 21 SCt. 206, 208.<\/p>\n

New Jersey<\/strong>:<\/p>\n

The term \u201ccorpus delecti\u201d embraces occurrence of loss or injury and criminal causation thereof.\u201d\u00a0 State v. Hill<\/span>, 221 A.2d 725, 728, 47 N.J. 490.<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cProof of the corpus delecti<\/em> \u2013 the fact of injury or, in a homicide case, of death, by a criminal agency \u2013 may be supplied by direct or circumstantial evidence.\u00a0 State v. Zarinsky<\/span>, 362 A.2d 611, 621.<\/p>\n

\u201cProof of the corpus delecti<\/em> is required in all criminal cases\u2026There are three basic elements in the proof of a crime: (1) the occurrence of loss or injury, (2) criminal causation of that loss or injury and (3) the identity of the defendant as the perpetrator of the crime.\u00a0 However, it is firmly established in this State that the term corpus delecti<\/em> embraces only the first two of these elements-loss or injury and criminal causation.\u201d\u00a0 State v. Hill<\/span>, 221 A.2d 725, 728.<\/p>\n

\u201cIt is true that the above care all cases of felonious homicide, but the doctrine [of corpus delecti] is in nowise peculiar to such cases; it is equally applicable to all criminal cases.\u201d\u00a0 State v. Gelzeiler<\/span>, 128 A. 240.<\/p>\n

\u201cStanding in no way depends on the merits of the plaintiff\u2019s contention that particular conduct is illegal.\u201d\u00a0 Watkins v. Resorts Intern. Hotel & Casino<\/span>, 591 A.2d 592, 601 (N.J. 1991).<\/p>\n

\u201cNormally, an individual will only be permitted to seek judicial vindication of his own rights.\u201d\u00a0 State v. Norflett<\/span>, 337 A.2d 609.<\/p>\n

\u201cStanding requires only a substantial likelihood of some harm visited upon the plaintiff in the event of an unfavorable decision.\u201d In re Camden County<\/span>, 790 A.2d 158.<\/p>\n

New Mexico<\/strong>:<\/p>\n

\u201c\u2018Standing\u2019 is a doctrine requiring that the claimant must have a personal stake in the outcome of the case; the claimant must allege both injury in fact and a traceable causal connection between the claimed injury and the challenged conduct.\u00a0 Dona Ana County Clerk v. Martinez<\/span>, 124 P.3d 210.<\/p>\n

\u201cStanding requires injury in fact, causation, and likelihood of redress.\u201d\u00a0 Williams v. Stewart<\/span>, 112 P.3d 281.<\/p>\n

\u201cLack of standing is a potential jurisdictional defect, which may not be waived and may be raised at any stage of the proceedings, even sua sponte by the appellate court.\u201d\u00a0 Gunaji v. Macias<\/span>, 31 P.3d 1008.<\/p>\n

New York<\/strong>:<\/p>\n

\u201cWe hold these truths to be self-evident, that all men are created equal; that they are endowed by their Creator with certain unalienable rights; that among these are, life, liberty, and the pursuit of happiness; that to secure these rights, governments are instituted among men\u201d\u00a0 New York constitution, April 20, 1777<\/a>.<\/p>\n

\u201cA crime is an inexcusable act committed by an individual in excess of his personal liberties and injures person or property within the victim\u2019s personal freedom or property right.\u201d<\/p>\n

\u201cWhat is liberty or freedom?\u201d<\/p>\n

\u201cThis freedom and liberty of man should be absolute with the one exception-that when the exercise of that liberty infringes upon the liberty of another, the actor invading another\u2019s liberty commits a wrong and to protect individuals from that invasion, society may class such invasion as crime, and provide for punishment.\u201d \u00a0People v. Douglas<\/span>, 202 N.Y.S.2d 160, 162-163.<\/p>\n

\u201cMere legislataive fiat may not take the place of fact in the determination of issues involving life, liberty and property.\u00a0 Manley v. State of Georgia, 279 U.S. 1, 49 S.Ct. 215, 73 L.Ed. 575\u2026The ultimate fact to be established here, is illegal possession of a gun.\u00a0 The fact proven would be merely the legislative presumption.\u00a0 There would be no actual proof\u2026Under our law the corpus delecti must be proved; here it is presumed\u2026The Legislature has no power to declare one guilty of a crime; that is the function of the court after due proof.\u00a0 It is unconstitutional for the Legislature to presume the guilt of the accused.\u00a0 Under this section there is nothing against which to defend, because no crime has been proved.\u201d\u00a0 People v. Pinder<\/span>, 9 N.Y.S.2d 311, 310-311.<\/p>\n

\u201cThe jurisdiction of this Court extends only to live controversies (see Matter of Grand Jury Subpoenas for Locals 17, 135, 257 & 608, 72 N.Y.2d 307, 311, 532 N.Y.S.2d 722, 528 N.E.2d 1195 [1988]; \u2009Matter of Hearst Corp. v. Clyne, 50 N.Y.2d 707, 713-714, 431 N.Y.S.2d 400, 409 N.E.2d 876 [1980]\u2009).\u201d<\/p>\n

\u201cStanding to sue is critical to the proper functioning of the judicial system. \u2002 It is a threshold issue. \u2002 If standing is denied, the pathway to the courthouse is blocked. \u2002 The plaintiff who has standing, however, may cross the threshold and seek judicial redress. It is difficult to draw an exquisitely sharp line separating the worthy litigant from one who would generate a lawsuit to advance someone else\u2019s cause. \u2002 The rules governing standing help courts separate the tangible from the abstract or speculative injury, and the genuinely aggrieved from the judicial dilettante or amorphous claimant.<\/p>\n

\u201cFor generations, New York courts have treated standing as a common-law concept,<\/a> requiring that the litigant have something truly at stake in a genuine controversy.\u201d\u00a0 Saratoga County Chamber of Commerce v. Patak<\/a>i (2003)<\/p>\n

\u201cAn analysis of standing begins with a determination of whether the party seeking relief has sustained an injury (see Society of Plastics Indus. v. County of Suffolk<\/em>, 77 N.Y.2d 761, 772-773, 570 N.Y.S.2d 778, 573 N.E.2d 1043 [1991]).\u201d\u00a0 Mahoney v. Pataki<\/span>, 772 N.E.2d 1118, 1122 (N.Y. 2002).<\/p>\n

\u201cA plaintiff has standing to maintain an action upon alleging an injury in fact that falls within his or her zone of interest.\u201d\u00a0 Silver v. Pataki<\/span>, 755 N.E.2d 842, 847 (N.Y. 2001).<\/p>\n

\u201cAs we have has on occasion to observe in recent years, \u201c[o]nly where there is a clear legislative intent negating review * * * or lack of injury in fact * * * will standing be denied\u2026\u201d\u00a0 Matter of Dist. Atty. of Suffolk County<\/span>, 448 N.E.2d 440, 443 (N.Y. 1983).<\/p>\n

\u201cTo adjudicate upon, and protect the rights and interests of individual citizens, and to that end to construe and apply the laws, is the peculiar province of the judicial department\u2026The judicial power \u201cis the power to hear and determine those matters which affect the life, liberty, or property of the citizens of the state.\u201d\u00a0 (City of Sapulpa v. Land, 101 Okl. 22, 223 P. 640, 644, 35 A.L.R. 872, 878.)\u201d\u00a0 Nash v. Brooks<\/span>, 297 N.Y.S. 853, 855-856.<\/p>\n

Nevada<\/strong>:<\/p>\n

\u201cTo establish standing, Kirkpatrick must show that he suffered an injury in fact, that there is a causal connection between the injury and the conduct complained of, and that it is likely that the injury will be redressed by a favorable decision.[Footnote] Allen v. Wright<\/em><\/a>, 468 U.S. 731, 751\u2026See also Elley v. Stephens<\/em>, 104 Nev. 413, 416, 760 P.2d 768, 770 (1998).\u201d\u00a0 Kirkpatrick v.Dist. Ct<\/span>., 43 P.3d 998, 1005 (Nev. 2002).<\/p>\n

North Dakota<\/strong>:<\/p>\n

\u201cTo have standing to bring action, plaintiff must have suffered some threatened or actual injury resulting from putatively illegal action, asserted harm must not be specialized grievances shared by all or large class of citizens.\u201d\u00a0 Trinity Medical Center v. North Dakota Bd. of Nursing<\/span>, 399 N.W.2d 835.<\/p>\n

\u201cAnd a definition which we consider appropriate and fully sustained is that judicial power is authority vested in some court, officer, or person to hear and determine when the rights of persons or property, or the propriety of doing an act, are the subject-matter of adjudication.\u201d\u00a0 State v. Blaisdell<\/span>, 132 N.W. 769, 773.<\/p>\n

North Carolina<\/strong>:<\/p>\n

\u201cconstitutionally, a plaintiff can only have standing if it satisfies the \u201ccase or controversy\u201d requirement of Article III of the Constitution of the United States.\u00a0 See Linda R.S. v. Richard D<\/a><\/em>., 410 US 614, 617\u2026Under Supreme Court precedent, a plaintiff satisfies the Article III requirement if it meets a three-pronged test: (1) the plaintiff must have suffered \u201cinjury in fact\u2019; (2) there must be a causal connection between the injury and the conduct complained of; and (3) it must be likely that the injury will be redressed by a favorable decision.\u00a0 See Lujan v. Defenders of Wildlife<\/a><\/em>, 504 U.S. 555, 559\u2026The plaintiff bears the burden of establishing these three elements.\u00a0 See Burten v. Central Interstate URWC Comm\u2019n<\/em>., 23 F3d 208, 209 (8th Cir. 1994).\u00a0 Additionally, the Supreme Court as articulated three prudential limits on standing\u2026lastly, the plaintiff must assert his own legal rights and interests, and cannot rest his claim on the legal rights of others [citing Valley Forge v. Americans United<\/em><\/a>, 454 US 464, 474].\u00a0 Transco v. Calco Enterprises<\/span>, 511 S.E.2d 671, 678.<\/p>\n

\u201cA \u201cperson aggrieved\u201d for standing purposes, is one adversly affected in respect to legal rights, or suffering from an infringement or denial of legal rights.\u201d\u00a0 County of Johnston v. City of Wilson<\/span>, 525 S.E.2d 425.<\/p>\n

\u201cStanding is an aspect of subject matter jurisdiction.\u201d\u00a0 Transcontinental Gas Line Corp. v. Calco Enterprises<\/span>, 511 S.E.2d 671.<\/p>\n

Ohio<\/strong>:<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cA plaintiff must show the injury to himself caused by the defendant, the injury having a remedy in law or equity.\u00a0 The injury need not be either large or economic, but it must be palpable.\u00a0 Warth<\/em><\/a> , 422 U.S. at 498\u2026Finally, plaintiff\u2019s injury cannot be merely speculative.\u00a0 A bare allegation that plaintiff fears that some injury will or may occur is insufficient to confer standing.\u00a0 Los Angeles v. Lyons<\/em><\/a>, (1983), 461 U.S. 95, 103\u2026\u201d\u00a0 Tieman v. Univ. of Cincinnati<\/span>, 712 N.E.2d 1258, 1267.<\/p>\n

\u201cThe United States Supreme Court has held that an association has standing on behalf of its members when \u201c(a) its members would otherwise have standing to sue in their own right; (b) the interests it seeks to protect are germane to the organization\u2019s purpose\u2026However, to have standing, the association must establish that its members have suffered an actual injury.\u201d\u00a0 Ohio Contractors Assn. v. Bicking<\/span>, 643 N.E.2d 1088, 1089 (Ohio 1994).<\/p>\n

\u201cJudicial power, on the other hand, is authority to hear and determine where the rights of persons or property, or the propriety of doing an act, are the subject-matter of adjudication and the judicial act involves the exercise of judgmentor discretion.\u00a0 Ward v. Board of Commissioners of Okfuskee County, 114 Okl. 246, 246 P. 376.\u201d\u00a0 Geauga Lake Improvement Ass\u2019n v. Lozier<\/span>, 182 N.E. 489, 491.<\/p>\n

Oklahoma<\/strong>:<\/p>\n

\u201cCorpus delecti<\/strong> means the body or substance of the crime charged.\u00a0 27 Wharton\u2019s Criminal Law<\/em> 142 (14th ed. 1978).\u00a0 It consists of two elements: a criminally prohibited injury and a criminally prohibited act as its cause.\u201d\u00a0 Fontenot v. State<\/span>, 881 P.2d 69, 77 (Okl.Cr. 1994).<\/p>\n

\u201c\u201dCorpus delecti\u201d means body or substance of crime charge, and it consists of criminally prohibited injury and criminally prohibited act as it\u2019s cause.\u201d \u00a0Fontenot v. State, 881 P.2d 69.<\/p>\n

\u201cThe judicial power here conferred by the Constitution is the power to hear and determine those matters which affect the life, liberty, or property of the citizens of the state\u2026\u201d\u00a0 City of Sapulpa v. Land<\/span>, 223 P. 640, 644, 101 Okl 22.<\/p>\n

\u201cAt a minimum standing is composed of three elements.\u00a0 These components are: (1) a legally protected interest which must have been injured in fact-i.e<\/em>., an injury which is actual, concrete and not conjectural in nature, (2) a causal<\/em> nexus between the injury and the complained conduct, and (3) a likelihood as opposed to mere speculation, that the injury will be redressed by a favorable decision<\/em>\u2026Finally, assessment of standing is not a decision on the merits.\u00a0 Rather, it is a determination whether the plaintiff is the proper party to seek adjudication of the asserted issue.\u201d\u00a0 Cities Servies Co. v. Gulf Oil Corp<\/span>., 976 P.2d 545, 547.<\/p>\n

\u201cAt minimum, \u201cstanding\u201d contains three elements: plaintiff have separate injury in fact, there must be causal connection between injury and condict complained of, and it must be likely, as opposed to merely speculative, that injury will be redressed by favorable decision.\u201d\u00a0 Toxic Waste Impact Group, Inc. v. Leavitt<\/span>, 890 P.3d 906.<\/p>\n

\u201cparty must assert his\/her own legal rights and interests and cannot rest claim for relief on the rights or interests of third parties.\u201d\u00a0 Independent School Dist. NO. 9 v. Glass<\/span>, 639 P.2d 1233, 1237.<\/p>\n

\u201cJudicial power is authority to hear and determine, where the rights or persons or property, or the propriety of doing an act, are the subject-matter of adjudication\u2026\u201d\u00a0 Ward v. Board of Com\u2019rs<\/span>, 246 P. 376, 378 [quoting In re Courthouse of Okmulgee County<\/span>, 161 P. 200.<\/p>\n

Oregon<\/strong>:<\/p>\n

“Literally, the phrase means the `body of the crime.’ To establish guilt, it is generally necessary for the prosecution to show that (a) the injury or harm specified in the crime occurred, (b) [that] injury or harm was caused by someone\u2019s criminal activity, and (c) the defendant was the guilty party. To sustain a conviction, the requirement of independent proof of the\u00a0corpus delicti<\/em>demands only that the prosecution have introduced independent evidence tending to show (a) and (b). It is not necessary that the independent proof tend to connect the defendant with the crime.\u201d \u00a0State v. Chatelain<\/a><\/span>, 220 P. 3d 41. \u00a0[The court here does try to confuse the two thing, the injury, the element of the crime, with a procedural rule.]<\/p>\n

\u201cStanding is an aspect of justiciability which may not be waived.\u201d\u00a0 Strank v. Public Employees Retirement Board<\/span>, 108 P.3d 1058.<\/p>\n

\u201cA person has standing if resolution of the issues presented will have a practical effect on his or her rights.\u201d\u00a0 Generaux v. Dobyns<\/span>, 134 P.3d 983, 986.<\/p>\n

\u201cAt least in the absence of a statute, a party has standing to assert only its own legal rights.\u201d\u00a0 Estate of Selmar A. Hutchins v. Fargo<\/span>, 72 P.3d 638, 640.<\/p>\n

\u201c[r]egardless of what the legislature provides regarding the standing of litigants to obtain judicial relief, the courts always<\/em> must determine that the constitutional requirements of justiciability are satisified. [citation omitted] Specifically, we reasoned that (1) the party that invokes the jurisdiction of the court has the \u201cobligation to establish the justiciability of the claim\u2026(2) to establish that the claim is justiciable, the party \u201cmust demonstrate that a decision in this\u00a0case will have a practical effect on its rights.\u201d\u00a0 Barton v. City of Lebanon<\/span>, 88 P.3d 323, 326.<\/p>\n

Pennsylvania<\/strong>:<\/p>\n

\u201cThe \u201ccorpus delecti<\/em> consists of the occurrence of a loss or injury resulting from some person\u2019s criminal conduct.\u201d\u00a0 Commonwealth v. McMullen<\/em>, 545 Pa. 361, 681 A.2d 717, 721 (1996).\u00a0 The corpus delecti<\/em> rules requires the Commonwealth to present evidence that: (1) a loss has occurred; and (2) the loss occurred as a result of a criminal agency.\u00a0 Commonwealth v. May<\/em>, 451 Pa. 31, 301 A.2d 368, 369 (1973).\u201d\u00a0 Commonwealth v. Taylor<\/span>, 831 A.2d 587, 591 (Pa. 2003).<\/p>\n

\u201cIt has long been fundamental to the criminal jurisprudence of this Commonwealth that a necessary predicate to any conviction if proof of the corpus delecti, i.e., the occurrence of any injury or loss and someone\u2019s criminality as the source of this injury or loss.\u00a0 See Commonwealth v. Burns, 490 Pa. 619, 627, 187 A.2d 552, 556-557 (1963); Commonwealth v. Turza, 340 Pa. 128, 133, 16 A.2d 401, 404 (1940).\u201d\u00a0 Commonwealth v. Maybee<\/span>, 239 A.2d 332, 333.<\/p>\n

\u201cThe two elements of \u201ccorpus delecti\u201d are that loss or injury has occurred and that loss or injury occurred through criminal agency; identity of party responsible for act is not element of corpus delecti.\u201d\u00a0 Com. v. Rieland<\/span>, 471 A.2d 490, 491.<\/p>\n

\u201c\u201cCorpus delecti\u201d consists of occurrence of injury or loss consistent with commission of crime by someone.\u201d\u00a0 Com. v. Daniels<\/span>, 422 A.2d 196, 199.<\/p>\n

\u201c\u201cCorpus delecti,\u201d meaning the body of the crime, consists of an occurrence of a specified type of loss or injury and someone\u2019s criminal activity as a source thereof.\u201d\u00a0 Com. v. Ware<\/span>, 329 A.2d 258, 274, 459 Pa. 334.
\n\u201cThe corpus delecti is established upon evidence of (1) the occurence of the specific\u00a0 kind of injury or loss; and,\u00a0(2) someone\u2019s criminality as\u00a0the source of loss.\u201d\u00a0 Com. Kasunic<\/span>, 620 A.2d 525, 529.<\/p>\n

\u201cPennsylvania appellate courts have repeatedly held that corpus delecti consists of the occurrence of injury or loss consistent with commission of a crime by\u00a0someone.\u201d\u00a0 Commonwealth v.\u00a0Daniels<\/span>, 422\u00a0A.2d 196, 199.<\/p>\n

\u201cIt is a well-settled principal of law that a crime is an offense against the sovereignty, a wrong which the government deems injurious not only to the victim but to the public at large, and which it punishes through a judicial proceeding in the Commonwealth\u2019s name.\u00a0 21 Am.Jur.2d 61, pp. 115-116.\u00a0 Though the same wrongful act may consititute both a crime and a tort, the tort is a private injury which is to be pursued by the injured party.\u00a0 Id<\/em>., at [section] 2, p. 116.\u00a0 Criminal prosecutions are not to settle private grievances but are to rectify the injury done to the Commonwealth.\u201d\u00a0 Com. v. Malloy<\/span>, 450 A.2d 689, 691.<\/p>\n

\u201cThe requirement of standing arises from the principal that judicial intervention is appropriate only when the underlying controversy is real and concrete.\u201d\u00a0 Pittsburg Palisades Park, LLC v. Com<\/span>., 888 A.2d 655.<\/p>\n

\u201cFor standing purposes, a \u201cdirect interest\u201d in the litigation requires a showing that the matter complained of caused harm to the party\u2019s interest\u2026for standing purposes, an \u201cimmediate interest\u201d in the outcome of the litigation involves the nature of the causal connection between the action complained of and the injury to the party challenging it.\u201d\u00a0 In re Hickson<\/span>, 821 A.2d 1238.<\/p>\n

\u201cStanding is not conferred via a party\u2019s relationship to the proceedings, but is conferred by a direct connection to a substantive injury, and by a causal connection between the action complained of and the injury to the person challenging it.\u201d\u00a0 Com v. J.H<\/span>., 759 A.2d 1269.<\/p>\n

Rhode Island<\/strong>:<\/p>\n

\u201cBefore it may obtain\u00a0a conviction for a\u00a0criminal offense, the state must prove corpus delecti beyond a reasonable doubt.\u00a0 In re Pereira<\/em>, 111 R.I. 712, 714, 306 A.2d 821, 823 (1973); State v. Maloney<\/em>, 111 R.I. 133, 138 n.1, 300 A.2d 259, 262 n.1 (1973).\u00a0 The corpus delecti comprises two elements: a penally proscribed act or injury and the unlawfullness of some person in causing the injury.\u201d\u00a0 State v. Halstead<\/span>, 414 A.2d 1138, 1143\u00a0(R.I. 1980).<\/p>\n

\u201cTo have standing, the plaintiff must allege to the court\u2019s satisfaction that the challenged action has caused him injury in fact, economic or otherwise.\u201d\u00a0 McKenna v. Williams<\/span>, 874 A.2d 217.<\/p>\n

\u201cStanding is not determined by whether injury caused by challenged action is substantial or insubstantial, but only whether there is some injury as opposed to no injury.\u201d\u00a0 Weybosset Hill Investments, LLC v. Rossi<\/span>, 857 A.2d 231.<\/p>\n

\u201cBy definition, a justiciable controversy must contain a plaintiff who has standing to pursue the action; that is to say, a plaintiff who has suffered \u201cinjury in fact\u2026Injury in fact maybe characterized as \u201can invasion of a legally protected interest which is (a) concrete and particularized * * * and (b) actual or immenent, not \u2018conjectural\u2019 or \u2018hypothetical.\u2019\u201d\u00a0 Meyer v. City of Newport<\/span>, 844 A.2d 148, 151 (R.I. 2004).<\/p>\n

South Carolina<\/strong>:<\/p>\n

\u201cin order to authorize a conviction, the state must prove these [corpus delecti] elements beyond a reasonable doubt\u2026\u201d\u00a0State v. Thomas<\/span>, 73 S.E.2d 722, 723.<\/p>\n

\u201cBefore any action can be maintained, a justiciable controversy must be present\u2026(A justiciable controversy exists when a concrete issue is presented, there is a definite assertion of legal rights and a positive legal duty which is denied by the adverse party.\u201d)\u2026A plaintiff must have standing to institute an action.\u00a0 Joytime Distrbs. & Amusement Co., Inc. v. State<\/em>, 338 S.C. 634, 639, 528 S.E.2d 647, 649.\u201d\u00a0 Sloan v. Greenville County<\/span>, 590 S.E.2d 338, 346, 347.<\/p>\n

\u201c\u201dA Court of law can know no other persons as parties, than those whose rights are made to appear by the record\u2026\u201d\u00a0 M\u2019Elwee v. House<\/em>, 17 S.C.L. (1 Bail.) 108, 109 (1828).\u201d\u00a0\u00a0Nelson v. QHG of South Carolina Inc.<\/span>, 580 S.E.2d 171, 178 (2003).<\/p>\n

South Dakota<\/strong>:<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cGenerally, for a litigant to have standing to bring an action before the court, litigant must show that he personally as suffered some actual or threatened injury as a result of putatively illegal conduct of defendant.\u201d\u00a0 Parsons v. South Dakota Lottery Com\u2019n<\/span>., 504 N.W.2d 593, 595.<\/p>\n

\u201c\u2018Generally, for a litigant to have standing to bring an action before the court, litigant must show that he personally as suffered some actual or threatened injury as a result of putatively illegal conduct of defendant.\u2019\u201d\u00a0 Parsons v. South Dakota Lottery Commissioner<\/em>., 504 N.W.2d 593, 595 (S.D. 1993) (quoting Gladstone, Realtors v. Bellwood<\/em>, 441 U.S. 91, 99\u2026\u201d\u00a0 Mahan v. Avera St. Luke\u2019s<\/span>, 621 N.W.2d 150, 154 (S.D. 2001).<\/p>\n

Tennessee<\/strong>:<\/p>\n

\u201cIn order to establish the corpus delecti of\u00a0a crime, the State must establish beyond a reasonable\u00a0doubt (1) that a certain result has been produced and (2) that someone is criminally responsible for the act.\u00a0 State v. Jones<\/em>, 15 S.W.3d 880, 890-891.\u201d\u00a0 State v. Ellis<\/span>, 89 S.W.3d 584, 600.<\/p>\n

\u201cCorpus delecti of crime requires showing that certain result has been produced and that result was created through criminal agency.\u201d\u00a0 State v. Ervin<\/span>, 731 S.W.2d 70.<\/p>\n

\u201cFirst we must address the issue of standing, a judge-made doctrine based on the idea that \u2018[a] court may and properly should refuse to entertain an action at the instance of one who rights have not been involved or infringed.\u2019 59 AmJur.2d Parties \u00a7 30 (1987).\u00a0 In state law it parallels the constitutional restriction on federal court jurisdiction to \u201ccases and controversies.\u201d U.S. Const. Art. 3 \u00a7 2.\u00a0 It has been said that no case or controversy is presented where the plaintiff lacks standing to sue.\u00a0 Gilligan v. Morgan<\/em>, 413 U.S. 1\u2026\u201cIn determining whether the plaintiff has a personal stake sufficient to confer standing, the focus should be on whether the complaining party has alleged an injury in fact, economic or otherwise\u2026\u201d\u00a0 Mayhew v. Wilder<\/span>, 46 S.W.3rd 760, 767.<\/p>\n

\u201cIn order to establish standing, a party must demonstrate three essential elements.\u00a0 Metropolitan Air Research Testing Auth. Inc., v. Metropolitan Gov\u2019t of Nashville and Durston County<\/em>, 842 S.W.2d 611, 615\u2026First, the party must demonstrate that it has suffered an injury which is \u2018distinct and palpable,\u2019\u2026and not conjectural or hypothetical\u2026Second, the party must establish a causal connection between the injury and the conduct of which he complains\u2026Third, it must be likely that a favorable decision will redress the injury\u2026These elements are indispensable to the plaintiff\u2019s case, and must be supported by the same degree of evidence at each stage of litigation as other matters on which plaintiff bears the burden of proof.\u00a0 Lujan<\/em><\/a>, 504 U.S. at 560\u2026\u201d\u00a0 Petty v. Daimler\/Chrysler Corp<\/span>., 91 S.W.3d 765.<\/p>\n

\u201cTo establish one\u2019s\u00a0standing to bring an action, \u201ca party must demonstrate (1) that it has sustained a distinct and palpable injury, (2) that the injury was caused by the challenged conduct, and (3) that the injury is apt to be redressed by a remedy the court is prepared to give.\u201d\u00a0 City of Chattanooga v. Davis<\/span>, 54 S.W.3d 248, 280 (Tenn. 2001).\u00a0 [By the way, this is a criminal case, Marc Stevens]<\/p>\n

Texas<\/strong>:<\/p>\n

\u201cWigmore explains the American concept of the corpus delecti<\/em> rule thus:<\/p>\n

[Every crime] reveals three component parts, first<\/em>, the occurrence<\/em>\u00a0 of the specific kind of injury or loss (as in homicide, a person deceased; in arson, a house burnt; in larceny, property missing); secondly<\/em>, somebody\u2019s criminality (in contrast, e.g., to accident) as the\u00a0source of the loss,\u2013these two together involving the commission of a crime by somebody<\/em>; and thirdly<\/em>, the accused\u2019s identity<\/em> as the doer of the crime.<\/p>\n

In most American jurisdictions, including Texas, the corpus delecti<\/em> rules requires some corroboration of the first two elements-an injury or loss and a criminal agent\u2026\u201d\u00a0 Salazar v. State<\/span>, 86 S.W.3d 640,\u00a0645.<\/p>\n

\u201cIt is too elementary that injury must be plead and proved before a cause of action arises to require the citation of authorities.\u201d\u00a0 Whitesboro Nat. Bank v. Wells<\/span>, 182 S.W.2d 516, 518.<\/p>\n

\u201cIt is axiomatic that standing is the first prerequisite to maintaining a suit.\u00a0 Hunt v. Bass<\/em>, 664 S.W.2d 323, 324\u2026Persons have standing to sue if they can show that (1) they have sustained some direct injury as a result of a wrongful act; (2) there is a direct relationship between their alleged injury and the claim sought to be adjudicated; (3) they have a personal stake in the controversy; (4) the challenged action as caused them an injury in fact, whether economic or otherwise\u2026Because standing is a jurisdictional requirement, it may be addressed for the first time on appeal.\u201d\u00a0 Sierra Club v. Cedar Point Oil Co<\/span>., 73 F3d 546, 555\u2026\u201d<\/p>\n

\u201cThe Supreme Court held that because the named plaintiff was unable to allege and show that he personally had been injured by the defendant\u2019s actions, his lack of individual standing precluded the trial court\u2019s exercise of subject matter jurisdiction\u2026The court explained that [o]ur state constitution contemplates, that plaintiffs seeking redress in the courts must first demonstrate standing.\u00a0 Because the Texas constitution requires the presence of a proper party to raise issues before the court, standing is a threshold inquiry regardless of whether the plaintiff brings an individual or class action.\u201d\u00a0 Polaris Industries, Inc. v. McDonald<\/span>, 119 S.W.3d\u00a0\u00a0 331, 338, 339.<\/p>\n

\u201cA \u201ccause of action\u201d constists of a plaintiff\u2019s primary right and the defendant\u2019s act or omission which violates that right. Stone Fort Nat. Bank of Nacogdoches v. Forbes<\/em>, 126 Tex. 568, 91 S.W.2d 674, 676 (1936); Martinez v. Goodyear Tire & Rubber Co<\/em>., 651 S.W.2d 18, 19\u2026Moreover, a \u201ccause of action\u201d comprises every fact which is necessary for a plaintiff to prove in order to obtain judgment.\u201d\u00a0 Krchnak v. Fulton<\/span>, 759 S.W.2d 524, 526.<\/p>\n

\u201cThe requirement in this State that a plaintiff have standing to assert a claim derives from the Texas Constitution\u2019s separation of powers among the departments of government, which denies the judiciary authority to decide issues in the abstract, and from the Open Courts provision, which provides court access only to a \u201cperson for an injury done him\u201d. A court has no jurisdiction over a claim made by a plaintiff without standing to assert it.\u00a0 For standing, a plaintiff must be personally aggrieved; his alleged injury must be concrete and particularized, actual or imminent, not hypothetical.\u00a0 A plaintiff does not lack standing simply because he cannot prevail on the merits of his claim; he lacks standing because his claim of injury is too slight for a court to afford redress.\u201d \u00a0 Daimler Chrysler Corporation, v. Bill Inman et al<\/span><\/a>, NO. 03-1189, Texas Supreme Court, 2008.<\/p>\n

\u201cThe dissent argues that standing requires only, one, a real controversy that, two, will be determined.\u00a0 Those are requirements for standing, but so is concrete injury, because if injury is only hypothetical, there is no real controversy.\u201d \u00a0 Daimler Chrysler Corporation, v. Bill Inman et a<\/span><\/a>l, NO. 03-1189, Texas Supreme Court, 2008.<\/p>\n

Utah<\/strong>:<\/p>\n

\u201cGenerally,\u00a0 \u201c\u2018[t]o establish guilt\u2019 \u201d in a criminal case, \u201cthe prosecution [must] show that [1] the injury or harm specified in the crime occurred, [2] this injury or harm was caused by someone\u2019s criminal activity, and [3] the defendant was the [perpetrator].\u2019 \u201d State v. Talbot<\/em>, 665 P.2d 1274, 1276 (Utah 1983) (citation omitted).\u00a0 The corpus delecti, or body of the crime, involves only the first two elements, however.\u201d\u00a0 State v. Mauchley<\/span>, 67 P.3d 477, 482 (Utah 2003).<\/p>\n

\u201c\u201dCorpus delecti rule\u201d states that person may not be convicted of crime if no independent evidence, outside defendant\u2019s own statement, exists; to satisfy doctrine, state must produce independent evidence that injury or harm specified in crime occurred and that injury or harm was caused by someone\u2019s criminal activity.\u201d\u00a0 State v. Archuleta<\/span>, 850 P.2d 1232, 1241.<\/p>\n

\u201cMr. Justice Cooley, in Post v. Campau, 42 Mich. 96, 3 N.W. 272, said: \u201cThe elements of a cause of action are, first, a breach of duty owing by one person to another; and second, a damage resulting to the other from the breach.\u201d\u00a0 In Foot v. Edwards, 3 Blatchf. 313, Fed. Cas. No. 4,908, Mr. Justice Ingersoll said: \u201cThe commission of an act by the defendant, and damage to the plaintiff in consequence thereof, must unite, to give a good cause of action.\u00a0 No one of these facts by itself is a cause of action against the defendant.\u201d\u00a0 In City of North Vernon v. Vogler, 103 Ind. 319, 2 N.E. 821, it is said: \u201cIn every valid cause of action two elements must be present-the injury and the damage.\u00a0 The one is the legal wrong which is to be redressed; the other, the scale or measure of the recovery.\u201d\u00a0 Fields v. Daisy Gold Min. Co<\/span>., 73 P. 521, 522, 26 Utah, 373.<\/p>\n

\u201cAn issue is \u201cripe\u201d for adjudication only when it has sharpened into an actual or imminent clash of legal rights.\u201d\u00a0 Pett v. Autoliv ASP, Inc<\/span>., 106 P.3d 705.<\/p>\n

\u201cIn general, standing is available only to a person who has sustained some injury to her personal, legal, or property rights.\u201d\u00a0 In re E.H<\/span>., 137 P.3d 809, 819.<\/p>\n

\u201cTo satisfy the \u201cbasic requirements\u201d of the traditional standing test, \u201ca party must alleged that he or she has suffered or will immediately suffer an injury that is fairly traceable to the conduct at issue such that a favorable decision is likely to redress the injury.\u201d\u00a0 Chen v. Stewart<\/span>, 123 P.3d 416, 437 (Utah 2005).<\/p>\n

\u201cIn order\u00a0 to have standing, a plaintiff must be able to show that he has suffered some distinct and polpable injury that gives him a personal stake in the outcome of the legal dispute.\u201d\u00a0 Council of Holliday City v. Larkin<\/span>, 89 P.3d 164.<\/p>\n

\u201cUnder principals of standing, a party may generally assert only his or her own legal rights, and cannot raise the claims of third parties who are not before the court.\u201d\u00a0 Provo City Corp. v. Thompson<\/span>, 86 P.3d 735.<\/p>\n

\u201cThe requirement that a plaintiff demonstrate particularized injury is the traditional test for standing.\u201d\u00a0 Washington County Water Conservancy Dist. v. Morgan<\/span>, 82 P.3d 1125.<\/p>\n

Vermont<\/strong>:<\/p>\n

\u201ccourts must look behind names that symbolize the parties to determine whether a justiciable case or controversy is presented.\u201d\u00a0 State v. CNA Ins. Companies<\/span>, 779 A.2d 662 (Vt 2001) [quoting United States v. Interstate Commerce Commission<\/span><\/a>, 337 U.S. 426 (1949)].<\/p>\n

\u201cWe examined, accordingly, the substance of the plaintiff\u2019s constitutional and civil rights claims, concluding that they implicated no legally protected right under the constitution.\u00a0 We affirmed, therefore, the trial court\u2019s dismissal both on lack of standing and on the merits.\u201d\u00a0 Daye v. State<\/span>, 769 A.2d 630, 633 (Vt. 2000).<\/p>\n

\u201cTo satisfy the standing requirement, a plaintiff must show (1) injury-in-fact, (2) causation, and (3) redressibility; thus, the plaintiff must allege a personal injury traceable to the defendant\u2019s conduct that the court can remedy\u2026\u201d\u00a0 Brigham v. State<\/span>, 889 A.2d 715.<\/p>\n

\u201cThe main standing requirement is that the plaintiff show threat of injury to a protected interest.\u201d\u00a0 Blum v. Friedman<\/span>, 782 A.2d 1204, 1207.<\/p>\n

\u201cthe phrase \u201cjudicial power\u201d implies the construction of laws and the adjudication of legal rights.\u201d\u00a0 Gould v. Parker<\/span>, 42 A.2d 416, 418.<\/p>\n

Virginia<\/strong>:<\/p>\n

\u201cBut basic concepts of our criminal jurispridence cannot be treated lightly in a zealous, and albeit a commendable, desire to reduce crime and convict culpits.\u00a0 Among these safeguards is the requirement that the State must establish the existence of the corpus delecti<\/em>\u00a0and prove its case beyond a reasonable doubt by admissible evidence.\u201d\u00a0 Pepoon v. Commonwealth<\/span>, 66 S.E.2d 854, 859.<\/p>\n

\u201cPoint of standing is to ensure that person who asserts a position has substantial legal right to do so and that his rights will be affected by disposition of the case.\u201d\u00a0 Cupp v. Board of Supr\u2019s of Fairfax County<\/span>, 318 S.E.2d 407.<\/p>\n

\u201cThe purpose of requiring standing is to make certain that a party who asserts a particular position has the legal right to do so and that his rights will be affected by the disposition of the case.\u201d\u00a0 Goldman v. Landslide<\/span>, 552 S.E.2d 67, 71 (Va. 2001).<\/p>\n

Washington<\/strong>:<\/p>\n

\u201cAll political power is inherent in the people, and governments derive their just powers from the consent of the governed, and are established to protect and maintain individual rights.\u201d Washington constitution article I \u00a7 1<\/a>.<\/p>\n

\u201cCorpus delecti is usually proven by following two elements: injury or loss, and someone\u2019s criminal act as cause thereof\u2026\u201d\u00a0 State v. Smith<\/span>, 801 P.2d 975, 115 Wash.2d 775.<\/p>\n

\u201c\u201cCorpus delecti\u201d consists of injury or loss and someone\u2019s criminal act which caused it.\u201d\u00a0 State v. Espinoza<\/span>, 774 P.2d 1177, 1182, 112 Wash.2d 819.<\/p>\n

\u201cCorpus delecti usually consists of two elements: (1) \u00a0an injury or loss\u2026 and (2)somone\u2019s criminal act as the cause thereof.\u201d\u00a0 City of Bremerton v. Corbett<\/span>, 773 P.2d 1135, 138,\u00a0106 Wash.2d 569.
\n\u201cIn order to establish the corpus delecti<\/em> of any crime there must be shown to have existed a certain act or result forming the basis of the criminal charge and the existence of a criminal agency as the cause of such act or result.\u201d\u00a0 State v. Goranson<\/span>, 408 P.2d 7, 9, [quoting State v. Meyer, 37 Wash.2d 759, 763, 226 P.2d 204 (1951)].<\/p>\n

\u201cThe term corpus delecti means the body of the crime, or, to state it differently, that the crime charged has actually been committed by some one.\u00a0 It is made up of two elements: first, that a certain result has been produced, as that a human being has died; and second, that some one is criminally responsible for the result.\u00a0 State v. Henderson, Or., 184 P.2d 392.\u201d\u00a0 State v. Jeannet<\/span>, 192 P.2d 983, 984.<\/p>\n

\u201cThe doctrine of standing prohibits a litigant from raising another\u2019s legal rights.\u00a0 Allen v. Wright<\/em>, 468 US 737, 750-751.\u201d\u00a0 Huberman v. Public Power Supply System<\/span>, 744 P.2d 1032, 1055.<\/p>\n

\u201cIf a plaintiff lacks standing to bring a suit, courts lack jurisdiction to consider it.\u201d\u00a0 High Tide Seafoods v. State<\/span>, 725 P2d 411, 415 (Wash. 1986).<\/p>\n

\u201cInjury in fact element of standing is satisfied when a plaintiff alleged the challenged action will cause a specific and personal harm.\u201d\u00a0 Kucera v. State, Dept. of Transp<\/span>., 995 P.2d 63.<\/p>\n

\u201cDoctrine of standing prohibits the litigant from raising another\u2019s legal rights.\u201d\u00a0 Haberman v. Washington Public Power Supply System<\/span>, 744 P.2d 1032.<\/p>\n

Washington DC<\/strong>:<\/p>\n

\u201cIt is an elementary matter of jurisprudence that an individual must have standing in order to maintain an action.\u00a0 Basic to standing is the requirement that the individual be injured in fact by the conduct of the other party.\u00a0 See, e.g., Lee v. District of Columbia Board of Appeals and Review<\/em>, 423 A.2d 210 (D.C. 1980).\u00a0 We find no injury to Burleson flowing from United\u2019s conduct.\u00a0 Burelson is without standing to maintain his action against United.\u201d\u00a0 Burelson v. United Title & Escrow Co. Inc<\/span>., 484 A.2d 535, 537.<\/p>\n

West Virginia<\/strong>:<\/p>\n

\u201cIt is well-recognized, and we now so hold, that [s]tanding\u2026is comprised of three\u00a0 elements; first, the party\u2026[attempting to establish standing] must have suffered an \u201cinjury-in-fact\u201d \u2013 an invasion of a legally protected interest which is (a) concrete and particularized and (b) actual or imminent and not conjectural or hypothetical.\u00a0 Second, there must be a causal connection [between] the injury and the conduct forming the basis of the suit.\u00a0 Third, it must be likely that the injury will be redressed through a favorable decision of the court.\u201d\u00a0 Findley v. State Farm Mut. Auto. Ins. Co<\/span>., 576 S.E.2d 807,821.<\/p>\n

\u201c\u201dGenerally, standing is defined as \u2018[a] party\u2019s right to make a legal claim or seek judicial enforcement of a duty or right.\u201d” Findley v. State Farm Mut. Auto. Ins. Co<\/em>.,\u00a0 213 W.Va. 80, 94, 576 S.E.2d 807,821 (2002)\u2026One aspect of standing is that one generally lacks standing to assert the rights of another.\u201d\u00a0 State ex rel. Lueng v. Sanders<\/span>, 584 S.E.2d 203, 212 (W.Va. 2003).<\/p>\n

Wisconsin<\/strong>:<\/p>\n

\u201cAll men are born equally free and independent, and have certain inherent rights; among these are life, liberty, and the pursuit of\u00a0 happiness; to\u00a0 secure these\u00a0 rights, governments are instituted\u00a0 among men,\u00a0 deriving their\u00a0 just powers from the consent of the governed.\u201d\u00a0 Wisconsin constitution article I \u00a7 1<\/a> .<\/p>\n

While the corpus delecti must be proved beyond all reasonable doubt, yet it may be established by circumstantial as well as direct evidence.\u00a0 Schwantes v. State<\/span>, 106 N.W. 237, 127 Wis. 169.<\/p>\n

\u201cLaw of standing is to be construed liberally; where an actual injury is demonstrated, even a trifling interest may be sufficient to confer standing.\u201d\u00a0 Milwaukee Brewers Baseball Club v. Wisconsin Dept. of Health and Social Services<\/span>, 387 N.W.2d 245.<\/p>\n

\u201cWisconsin employs a two-step standing analysis.\u00a0 The analysis requries the court to determine (1) whether the plaintiff has suffered a threatened or actual injury, and (2) whether the interest asserted is recognized by law.\u201d\u00a0 Schwittay v. Sheboygan Falls Mut. Ins. Co.<\/span>, 630 N.W.2d 772, 776.<\/p>\n

Wyoming<\/strong>:<\/p>\n

\u201cA party has standing \u201conly if he has a tangible and legally protectable interest at stake in the litigation; his interest must be injured or threatened with injury\u2026\u201d\u00a0 Billings v. Wyoming Bd. of Outfitters<\/span>, 88 P.3d 455, 479 (Wyo. 2004).<\/p>\n

\u201cthe duty of this court, as of every judicial tribunal<\/em><\/strong>, is limited to determining rights<\/em><\/strong> of persons or of property, which are actually controverted in the particular case before it.\u201d\u00a0 Tyler v. Judges of the Court of Registration<\/span>, 179 U.S. 405, 21 SCt. 206, 208.<\/p>\n

In addition to the federal cases cited above:<\/strong><\/p>\n

\u201cThe plaintiff must show that he himself is injured by the challenged action of the defendant.\u00a0 The injury may be indirect, see United States v. SCRAP, 412 U.S. 669, 688, 93 S.Ct. 2405, 2416, 37 L.Ed.2d 254 (1973), but the complaint must indicate that the injury is indeed fairly traceable to the defendant\u2019s acts or omissions.\u00a0 Simon v. Eastern Ky. Welfare Rights Org., 426 U.S. 26, 41-42, 96 S.Ct. 1917, 1925-1926, 48 L.Ed.2d 450 (1976); O\u2019Shea v. Littelton, 414 U.S. 488, 498, 94 S.Ct. 669, 677, 38 L.Ed2d 674 (1974); Linda R. S. v. Richard D., 410 U.S. 614, 617, 93 S.Ct. 1146, 1148, 35 L.Ed.2d 536 (1973).\u201d\u00a0 Vil. of Arlington Hts. v. Metro Housing Dev<\/span><\/a>., 429 U.S. 252, 262.<\/p>\n

\u201cComponent parts of every crime are the occurrence of a specific kind of injury or loss, somebody\u2019s criminality as source of the loss, and the accused\u2019s identity as the doer of the crime; the first two elements are what constitutes the concept of \u201ccorpus delecti.\u201d\u00a0 U.S. v. Shunk<\/span>, 881 F.2d 917, 919 C.A. 10 (Utah).<\/p>\n

\u201cMost American courts take the view that the phrase \u201ccorpus delecti\u201d<\/em> includes first, the fact of an injury or a loss and secondly, the fact of somebody\u2019s criminality (in contrast e.g.<\/em> to accident) as the cause of the injury or loss.\u201d\u00a0 United States. v. Echeles<\/span>, 222 F.2d 144, 155 (C.A. 10th Cir Ill.).<\/p>\n

\u201cOn the contrary, we share the view most American courts that the\u00a0phrase \u201ccorpus delecti\u201d<\/em>includes but two elements: first, the fact of an injury or loss; and secondly, the fact of somebody\u2019s <\/em>criminality as the cause of the injury or loss.\u201d\u00a0 French v. United States<\/span>, 232 F.2d 736 738, (C.A. 5th Cir. La.).<\/p>\n

\u201cTo paraphrase one of the leading cases: \u2018Most American courts take the view that the phrase \u201ccorpus delecti\u201d<\/em> includes first, the fact of an injury or a loss and secondly, the fact of somebody\u2019s criminality (in contrast e.g.<\/em> to accident) as the cause of the injury or loss\u2026\u2019\u00a0 Manning v. United States, 10 Cir., 215 F.2d 945, at page 947; United States v. Echeles, 7 Cir., 1955, 222 F.2d 144; United States v. Di Orio, 3 Cir., 1940, 150 F.2d 938; George v. United States, 1942, 75 U.S.App.D.C. 197, 125 F.2d 559, 563; United States v. Markman, 2 Cir., 1952, 193 F.2d 574, 576.\u201d\u00a0 Sandez v. United States<\/span>, 239 F.2d 239, 244 (C.A. 9th Cir. Calif.).<\/p>\n

Standing is the same wherever you go, the important elements are (1) the violation of a right, a legal injury; and (2) damage.\u00a0 The only \u201cauthority\u201d one should need is to look at the Declaration of Independence<\/a> for the only reason for the establishment of an American government:<\/p>\n

\u201cWe hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness. \u2014 That to secure these rights, Governments are instituted <\/strong>among Men, deriving their just powers from the consent of the governed\u2026\u201d (Emphasis mine)<\/p>\n

This of course is repeated in \u201cstate\u201d constitutions such as Arizona: \u201cgovernments \u2026 are established to protect and maintain individual rights.\u201d\u00a0 Arizona constitution article II \u00a7 2<\/span><\/a>. This is why standing and jurisdiction must always involve a plaintiff\u2019s rights.<\/p>\n

However, statists, especially attorneys, are not interested in the plain truth.\u00a0 That is why they claim everything I write is taken out of context.\u00a0 An example is standing.\u00a0 This incredibly simple issue is intentionally complicated by attorneys whose money is made arguing.\u00a0 Attorneys\u00a0 will claim because I provide quotes and citations from civil cases, that standing and jurisdiction only applies to civil cases, not criminal cases.\u00a0 One attorney in Arizona, Paula Burgess, acting as a judge, told me with a straight face article II \u00a7 2 did not apply to criminal cases.\u00a0 In Ms. Burgess\u2019s opinion the criminal court system was either not created by the Arizona constitution or is not a part of the government.\u00a0 It\u2019s absurd to claim standing and jurisdiction requirements do not apply in criminal cases.<\/p>\n

It\u2019s simple logic and common sense, juris doctorate<\/a> not required:<\/p>\n

(1) the government was established\/instituted for one purpose i.e., to secure\/protect rights;<\/p>\n

(2) the courts being a part of the government have the same singular purpose i.e., to secure\/protect rights;<\/p>\n

(3) the courts\u2019 jurisdiction has one purpose i.e., to secure\/protect rights;<\/p>\n

(4) Standing to invoke a court\u2019s jurisdiction requires the allegation a right is being violated.<\/p>\n

Standing applies in criminal cases.\u00a0 What attorneys probably don\u2019t like is it doesn\u2019t require a one-hundred thousand dollar education to know and understand it; all it requires is to know what the purpose of government is supposed<\/em> to be.\u00a0 Maybe one of the reasons attorneys don\u2019t like this is that it\u2019s a threat to their monopoly.<\/p>\n

Let\u2019s examine the heinous crime called the \u201cunauthorized practice of law\u201d, attorneys LOVE this.\u00a0 Their passionate enforcement is evidence enough (try to assist a friend in court and watch the attorneys come alive).\u00a0 In California it is \u201cpunishable by up to one year in a county jail or by a fine of up to one thousand dollars ($1000), or by both\u2026\u201d California Business and Professions Code \u00a7 6126(a)<\/a>.<\/p>\n

Government has one purpose \u201cgovernments \u2026 are established to protect and maintain individual rights.\u201d\u00a0 Arizona constitution article II \u00a7 2<\/span><\/a>.\u00a0 Whose rights am I accused of violating if I am accused of the \u201cunauthorized practice of law\u201d crime?\u00a0 If you have trouble identifying whose rights to life, liberty or property are violated, then don\u2019t despair because it violates no one\u2019s rights.\u00a0 It\u2019s the same if I am growing marijuana on my property, it violates no one\u2019s rights and injures no one.\u00a0 I wonder how many attorneys would be out of work if the \u201cdrug war\u201d ended tomorrow?\u00a0 Looks like a motive to me.<\/p>\n

Remember, attorneys are part of the system, their allegiance<\/a> is to that system because that system is where and how they get such high profits.\u00a0 Anything<\/em> that would take away fom their profits will be attacked.\u00a0 Therefore, anything that would take business away from the courts will be opposed by this aggression-drunk cult<\/a>.<\/p>\n

As designed by this cult, there will always be conflicting \u201cprecedents\u201d and there are probably \u201copinions\u201d out there that may appear to conflict, or actually conflict with, the cases I provide below.\u00a0 Do not let that discourage you, remember the cases I have cited are consistent with constitutions, enabling acts and the Declaration of Independence.\u00a0 When conflicting \u201copinions\u201d are brought forth, then take that as evidence that attorneys will say anything.\u00a0 It\u2019s one more reason not to give any credibility to an attorney.<\/p>\n

This cross-reference is a work in progress, so please check back often for updates.\u00a0 I will have each \u201cstate\u201d standing \u201cauthority\u201d posted.\u00a0 And remember, I, Marc Stevens, am not an attorney, so everything is for entertainment purposes only and if anything here resembles the truth, then it must have been taken out of context.<\/p>\n

\u201cDistinctions between crime and tort<\/strong>\u2026<\/p>\n

While the same act may constitute both a crime and a tort, the distinction between crimes and torts is based on the public nature of the criminal offense.<\/p>\n

The distinction with respect to the character of the rights affected and the nature of the wrong is this: \u00a0A tort is merely a private wrong in that it is an infringement of the civil rights of individuals, considered merely as individuals, while a crime is a public wrong in that it affects public rights and is an injury to the whole community, considered as a community in it\u2019s social aggregate capacity.<\/p>\n

The distinction between a tort and a crime lies in the difference between the methods by which the remedy for the wrong is pursued; a wrong for which the remedy is pursued by, and at the discretion of, the individual injured or his representative is a tort, and a wrong for which the wrongdoer is proceeded against by the sovereign or state for the purpose of punishment is a crime.\u201d \u00a0Corpus Juris Secundum<\/span>, Vol 22, page 26 (2006 ed). \u00a0Supporting citations from text:<\/p>\n

Ind-State ex rel Johnson v. White Circuit Court<\/span>, 225 Ind 602, 77 N.E.2d 298\u2026Mich.-People v. Veenstra<\/span>, 337 Mich. 427, 60 N.W.2d 309\u2026Pa.-Com. v. Malloy<\/span>, 304 Pa.Super. 297, 450 A.2d 689\u2026Ala.-Holland v. State, 440 So.2d 1236\u2026N.J.- Tomlin v. Hildreth, 65 N.J. L. 438, 47 A. 649\u2026N.C.-State Highway and Public Works Comm. v. Cobb, 215 N.C. 556, 2 SE2d 565\u2026<\/p>\n

Alabama<\/strong>:<\/p>\n

\u201cThere are only two elements in the corpus delecti of an offense: (1) That a certain result has been produced, and (2) that a person is criminally responsible for that result.\u201d\u00a0 Ex parte Slaton<\/span>, 680 So.2d 909, 925 (Ala. 1996).<\/p>\n

\u201c\u201cCorpus delecti\u201d consists of two elements: that a certain result has been produced that some person is criminally responsible for the act.\u201d\u00a0 Johnson v. State<\/span>, 473 So.2d 607, 609.<\/p>\n

\u201cThus, although a certain section of Amendment III appears on its face to be discriminatory, because \u201cplaintiff in this case alleged that he or she suffered an injury under this section, no case or controversy was ever presented to the trial court to invoke its jurisdiction\u2026\u201d<\/p>\n

\u201cUnder Alabama law, every action in tort consists of three elements: The existence of a legal duty by defendant to plaintiff; a breach of that duty; and damage as the proximate result.\u00a0 Alabama Power Co. v. Guy<\/em>, 281 Ala. 583, 206 So.2d 594, 599 (1967).\u201d\u00a0 Dobbs v. Alabama Power Co<\/span>., 549 So.2d 35, 36 (Ala. 1989).<\/p>\n

\u201cTo present a justiciable case or controversy, the individual plaintiff must have standing to sue; to have standing, the individual must allege an injury directly arising from or connected with the wrong alleged.\u00a0 The standing requirement applies whether the plaintiff sues individually or on behalf of a class.\u201d\u00a0 Ex Parte Blue Cross & Blue Shield of Alabama<\/em>, 582 So2d 469, 474\u2026<\/p>\n

\u201cWhen a party without standing purports to commence an action, the trial court acquires no subject matter jurisdiction.\u00a0 Barshop v. Medina County Underground Water Conservation District<\/em>, 925 S.W.2d 618, 626\u2026(\u2018standing is a necessary component of subject matter jurisdiction\u2019).\u00a0 See also Rames v. Bryd<\/a> <\/em>, 521 US 811\u2026(\u2018\u201cstanding is perhaps the most important of [the jurisdictional] doctrines\u2019\u201d); National Organization for Women, Inc., v. Scheidler<\/em><\/a> , 510 US 249\u2026(\u2018standing represents a jurisdictional requirement which remains open to review at all stages of the litigation\u2019)\u2026(\u2018standing is a jurisdictional prerequisite\u00a0 to every case and may be raised at any stage of the proceedings\u2019)\u2026\u201d\u00a0 Ex parte James<\/span>, 836 So2d 813, 871, 872-873.<\/p>\n

\u201cStanding requires an injury in fact\u2026When a party without standing puports to commence an action, the trial court acquires no subject matter jurisdiction\u2026If a named plaintiff has not been injured by the wrong alleged in the complaint, then no case or controversy is presented\u2026A party\u2019s injury must be \u201ctangible,\u201d\u2026\u201d\u00a0 Kid\u2019s Care, Inc. v. Ala. Dept\u2019 of Hum. Res<\/span>., 843 So.2d 164, 166-167 (Ala. 2002).<\/p>\n

\u201cStanding turns on whether the party has been injured in fact and whether the injury is to a legally protected right.\u201d\u00a0 Walters v. Stewart<\/span>, 838 So.2d 1047.<\/p>\n

\u201cJudicial power is authority vested in some court, officer or person, to hear and determine when the rights of person or property, or the propriety of doing an act, are the subject-matter of adjudication.\u201d\u00a0 State v. Jelks<\/span>, 35 So. 60, 62.<\/p>\n

Alaska<\/strong>:<\/p>\n

\u201cDegree of injury required under interest-injury standing need not be great; an \u201cidentifiable trifle\u201d is said to suffice to fight out a question of principal.\u201d\u00a0 Alaskans for a Common Language, Inc. v. Kritz<\/span>, 3 P.3d 906 (Alaska 2000).<\/p>\n

\u201cState courts grant standing to any person who can show injury-in-fact.\u201d\u00a0 In re Dissolution of Marriage of Alaback<\/span>, 997 P.2d 1181.<\/p>\n

\u201cthe duty of this court, as of every judicial tribunal<\/em><\/strong>, is limited to determining rights<\/em><\/strong> of persons or of property, which are actually controverted in the particular case before it.\u201d\u00a0 Tyler v. Judges of the Court of Registration<\/span>, 179 U.S. 405, 21 SCt. 206, 208.<\/p>\n

 <\/p>\n

Arizona<\/strong>:<\/p>\n

\u201cAll political power is inherent in the people, and governments derive their just powers from the consent of the governed, and are established to protect and maintain individual rights.\u201d\u00a0 Arizona constitution article II \u00a7 2<\/span><\/a>.<\/p>\n

\u201cit is declared that the public policy of this state and the general purposes of the provisions of this title [criminal code title 13] are: 1. To proscribe conduct that unjustifiably and inexcusably causes or threatens substantial harm to individual or public interests.\u201d\u00a0 Arizona criminal code \u00a7 13-101<\/a> .<\/p>\n

\u201cTwo elements comprise the corpus delecti of a crime: (1) the basic injury\u2026(2) the fact that the basic injury was the result of a criminal, rather than a natural or accidental, cause. \u00a0State v. Thomas<\/em>, 78 Ariz. 52, 59, 275 P.2d 408, 413 (1954).\u201d \u00a0State v. Atwood<\/span>, 832 P.2d 593, 614, 171 Ariz. 576.<\/p>\n

\u201cIn Arizona, both \u201cbut for\u201d causation and proximate cause must be established in a criminal case.\u201d \u00a0State v. Marty, 801 P.2d 468, 471, 166 Ariz. 233.<\/p>\n

\u201cIf such preliminary proof has been submitted the confession or statements may then be used to assist in proving the corpus delecti beyond a reasonable doubt, the degree necessary for conviction.\u201d\u00a0 State v. Hernandez<\/span>, 320 P.2d 476, 469, 83 Ariz. 279.<\/p>\n

\u201cIn order to establish corpus delecti, state must prove that a certain result has been produced and that someone is criminally responsible for that result.\u201d\u00a0 State v. Gerlaugh<\/span>, 654 P.2d 800, 134 Ariz. 164.<\/p>\n

\u201cTo establish corpus delecti, there must be some proof that a certain result has been produced and that someone is criminally responsible for the act.\u201d\u00a0 State v. Pineda<\/span>, 519 P.2d 41, 100 Ariz. 342.<\/p>\n

\u201c\u201cCorpus delecti\u201d of a crime is established by showing proof of result and that some one is criminally responsible therefore.\u201d\u00a0 State v. Flores<\/span>, 454 P.2d 172, 9 Ariz.App. 502.<\/p>\n

\u201c\u201cCorpus delecti\u201d has as its two elements that a certain result has been produced and that some person is criminally responsible for the act.\u201d\u00a0 State v. Wilson<\/span>, 548 P.2d 23, 113 Ariz. 145.
\n\u201cIn Sears, we denied standing to citizens seeking relief against the governor because they failed to plead and prove palpable injury personal to themselves.\u201d\u00a0 Bennet v. Napolitano<\/span>, 81 P3d 311, 315.<\/p>\n

\u201cTo gain standing to bring an action, a plaintiff must allege a distinct and palpable injury.\u00a0 Warth v. Seldin<\/em><\/a>, 422 U.S. 490, 501.\u201d\u00a0 Sears v. Hull<\/span>, 961 P.2d 1013, 1017 (1998).<\/p>\n

\u201cTo gain standing to bring an action, a plaintiff must allege a distinct and palpable injury.\u201d\u00a0 Fernandez v. Takata Seat Belts, Inc<\/span>., 108 P.3d 917.<\/p>\n

Arkansas<\/strong>:<\/p>\n

\u201cIt is a fundamental principal that the courts are instituted to afford relief to persons whose rights have been invaded\u2026by the defendant\u2019s conduct\u2026a court may and properly should refuse to entertain an action at the instance of one whose rights have not been invaded or infringed, as where he seeks to invoke a remedy in behalf of another who seeks no redress.\u201d\u00a0 Jag Consulting v. Eubanks<\/span>, 72 S.W.3d 549 556.<\/p>\n

\u201cthe duty of this court, as of every judicial tribunal<\/em><\/strong>, is limited to determining rights<\/em><\/strong> of persons or of property, which are actually controverted in the particular case before it.\u201d\u00a0 Tyler v. Judges of the Court of Registration<\/span>, 179 U.S. 405, 21 SCt. 206, 208.<\/p>\n

California<\/strong>:<\/p>\n

\u201cIn every prosecution for crime it is necessary to establish the \u201ccorpus delecti\u201d, i.e., the body or elements of the crime.\u201d\u00a0 People v. Lopez<\/span>, 62 Ca.Rptr. 47, 254 C.A.2d 185.<\/p>\n

\u201cIn every criminal trial, the prosecution must prove the corpus delecti, or the body of the crime itself-i.e., the fact of injury, loss or harm, and the existence of a criminal agency as its cause.\u201d\u00a0 People v. Sapp<\/span>, 73 P.3d 433, 467 (Cal. 2003) [quoting People v. Alvarez<\/span>, (2002) 27 Cal.4th 1161, 1168-1169, 119 Cal.Rptr.2d 903, 46 P.3d 372.].<\/p>\n

\u201cElements of \u201ccorpus delecti,\u201d injury or loss or harm and a criminal agency which causes such injury, loss or harm, need only be proven by a \u201creasonable probability,\u201d i.e., by slight or prima facie proof\u2026\u201d\u00a0 People v. Ramirez<\/span>, 153 Cal.Rptr. 789, 791, 91 C.A. 132.<\/p>\n

\u201c\u201cCorpus delecti\u201d of crime consists of fact of injury, loss, or harm, and existence of criminal agency as cause.\u201d\u00a0 People v. Daly<\/span>, 10 Cal.Rptr.2d 21, 28, 8 CA4th 47.<\/p>\n

\u201cGenerally, \u201ccorpus delecti\u201d of crime is (1) the fact of the loss or harm, and (2) the existence of a criminal agency as its cause.\u201d\u00a0 People v. Dorsey<\/span>, 118 Cal.Rptr. 362, 43 CA3d 953.<\/p>\n

\u201cThere\u00a0is no requirement of independent evidence \u2018of every physical act constituting an\u00a0element of an offense,\u2019 so long as there is some slight or prima facie showing of injury, loss, or harm by a criminal agency.\u201d\u00a0 In re I.M<\/span>., 23 Cal.Rptr.3d 375, 381 (2005).<\/p>\n

\u201cThe corpus delecti of a crime consists of two elements[:] the fact of the injury or loss or harm, and the existence of a criminal agency as its cause.\u201d \u00a0People v. Jones<\/span>, 949 P.2d 890, 902, 70 Cal.Rptr.2d 793, 17 Cal.4th 279.<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cWithout standing, there is no actual or justiciable controversy, and courts will not entertain such cases.\u00a0 (3 Witlen, Cal. Procedure (3rd ed. 1985) Actions \u00a7 44, pp 70-72.)\u00a0 \u201cTypically, \u2026 the standing inquiry requires careful judicial examination of a complaint\u2019s allegations to ascertain whether the particular plaintiff is entitled to an adjudication of the particular claims asserted.\u201d\u00a0 (Allen v. Wright<\/em><\/a>, (1984) 468 U.S. 737, 752\u2026Whether one has standing in a particular case generally revolved around the question whether that person has rights that may suffer some injury, actual or threatened.\u201d\u00a0 Clifford S. v. Superior Court<\/span>, 45 Cal.Rptr.2d 333, 335.<\/p>\n

\u201cAs a general principal, standing to invoke the judicial process requires an actual justiciable controversy as to which the complainant has a real interest in the ultimate adjudication because he or she has either suffered or is about to suffer an injury.\u201d\u00a0 People v. Superior Court<\/span>, 126 Cal.Rptr.2d 793.<\/p>\n

\u201cJudicial power generally is the power to adjudicate upon the legal rights of persons and property,\u00a0with reference to transactions or\u00a0occurrences existing or already had and closed\u2026The judicial\u00a0function is to \u2018declare the law and define the rights of the parties under it.\u2019\u00a0 Frasher v. Rader, 124 Cal. 133, 56 P. 797\u2026\u2019A determination of the rights of an individual\u00a0under the existing laws\u2019 is an exercise of judicial power\u2026An essential element of judicial power, distinguishing it from legislative power, is that it requires\u00a0\u201dthe ascertainment of existing rights.\u201d\u00a0 People v. Bird<\/span>, 300 P. 22, 26-27.
\nColorado<\/strong>:<\/p>\n

\u201cthe corpus delecti<\/em>\u00a0of a crime minimally requires two elements: \u201c(1) An injury which is penally proscribed\u2026and (2) The unlawfulness of some person\u2019s conduct in causing that injury.\u201d \u00a0People of the State of Colorado v. Smith<\/span>, 510 P.2d 893, 182 Colo. 31.<\/p>\n

\u201cGenerally, to subject a person to criminal liability, there must be concurrence of the actus reus, an unlawful act, and the mens rea, a culpable mental state.\u201d \u00a0Gorman v. State<\/span>, 19 P.3d 662.<\/p>\n

\u201cThe corpus delecti<\/em> ordinarily consists of a penally proscribed injury\u2026and unlawful conduct causing the injury.\u201d \u00a0People v. Trujillo<\/span>, 860 P.2d 542, 545.<\/p>\n

\u201cThe\u00a0corpus delecti<\/em>, or the fact that a crime occurred, must be proved in every case.\u201d \u00a0People v. Quinn<\/span>, 794 P.2d 1066, 1068.<\/p>\n

\u201cProperly understood the general principle is sound, for courts only adjudicate justiciable controversies\u2026 courts must look behind names that symbolize the parties to determine whether a justiciable case or controversy is presented.\u201d\u00a0 Friedrichs v. Goldy<\/span>, 387 P.2d 274, 277 [quoting United States v. Interstate Commerce Commission<\/span><\/a>, 337 U.S. 426 (1949]).<\/p>\n

\u201cThe Wimberly<\/em> standing inquiry requires a court to determine \u201c(1) whether the plaintiff was injured in fact, [and] (2) whether the injury was to a legally protected right.\u201d\u00a0 Wimberly<\/em>, 194 Colo. at 168\u2026The first prong of the standing test is a constitutional requirement since the judicial power granted \u201cby article VI of the Colorado constitution may be exercised only if an actual controversy exists, as demonstrated by real injury\u2026The second standing requirement, that the injury be to a legally protected right\u2026\u201d\u00a0 Maurer v. Young Life<\/span>, 779 P.2d 1317.<\/p>\n

\u201cThe judicial power of the state shall be vested in a supreme court, district courts, a probate court in the city and county of Denver, a juvenile court in the city and county of Denver, county courts, and such other courts or judicial officers with jurisdiction inferior to the supreme court, as the general assembly may, from time to time establish; provided, however, that nothing herein contained shall be construed to restrict or diminish the powers of home rule cities and towns granted under article XX, section 6 of this constitution to create municipal and police courts.\u201d\u00a0 Colorado constitution<\/a>, article VI, section 1.<\/p>\n

[Notice there is no distinction regarding criminal and civil jurisdictions, the “judicial power” comprehends both criminal and civil and each require a “real injury…to a…protected right…”]<\/p>\n

\u201cParties have standing if: (1) they have suffered an injury in fact; and (2) the harm is to a legally protected interest.\u201d\u00a0 Garhart ex rel. Tinsman v. Columbia\/Hathone, LLC<\/span>., 95 P.3d 571.<\/p>\n

\u201cA plaintiff has standing if he incurred an injury in fact-in-fact to a legally protected interest, as comtemplated by statutory or constitutional provisions.\u201d\u00a0 Brotman v. East Lake Creek Ranch, LLP<\/span>., 31 P.3d 886.<\/p>\n

\u201cthe legislature did not deprive the courts of judicial power which may be defined as the machinery by which persons have their rights determined\u2026\u201d\u00a0 Denver Local Union No. 13, etc. v. Perry Truck Lines<\/span>, 101 P.2d 436, 447.<\/p>\n

\u201cthe duty of this court, as of every judicial tribunal<\/em><\/strong>, is limited to determining rights<\/em><\/strong> of persons or of property, which are actually controverted in the particular case before it.\u201d\u00a0 Tyler v. Judges of the Court of Registration<\/span>, 179 U.S. 405, 21 SCt. 206, 208.<\/p>\n

Connecticut<\/strong>:<\/p>\n

\u201c\u201cCorpus delecti\u201d consists of occurrence of specific kind of loss or injury embraced in crime charged, rather than commission of crime charged by someone.\u201d\u00a0 State v. Vuilleumer<\/span>, 210 A.2d 673, 674, 3 Conn.Cir. 223.<\/p>\n

\u201cUnder the Wigmore definition, the corpus delecti consists of the occurrence of the specific loss or injury embraced in the crime charged.\u00a0 We adopt this definition.\u201d\u00a0 State v. Tillman<\/span>, 202 A.2d 494, 496.<\/p>\n

\u201cCause of action is that single group of facts which is claimed to have brought about unlawful injury to plaintiff and which entitles plaintiff to relief.\u201d\u00a0 Gurliacci v. Mayer<\/span>, 590 A.2d 914 (Conn. 1991).<\/p>\n

\u201cStanding is the legal right to set judicial machinery in motion.\u00a0 One cannot rightfully invoke the jurisdiction of the court unless he [or she] has, in an individual or representative capacity, some real interest in the cause of action, or a legal or equitable right, title or interest in the subject matter of the controversy\u2026\u201d\u00a0 West Farms Mall, LLC v. West Hartford<\/span>, 901 A.2d 649, 655-656 (Conn. 2006).<\/p>\n

\u201cIf a party is found to lack standing, the court is without subject matter jurisdiction to determine the cause\u2026[A] court lacks discretion to consider the merits of a case over which it is without jurisdiction\u2026\u201d\u00a0 Missionary Soc. v. Bd. of Pardons & Paroles<\/span>, 896 A.2d 809, 812 (Conn. 2006).<\/p>\n

\u201cOnce the question of subject matter jurisdiction has been raised, cognizance of it must be taken and the matter passed upon before [the court] can move one further step in the cause\u2026We accordingly address this issue, the question is whether the person who standing is challenged is a proper party to request an adjudication of the issue\u2026Standing requires no more than a colorable claim of injury; a [party] ordinarily establishes standing by allegations of injury.\u201d\u00a0 Wesley v. Schaller Subaru, Inc<\/span>., 893 A.2d 389, 397 (Conn. 2006).<\/p>\n

\u201cIf a party is found to lack standing, the court is wihtout subject matter jurisdiction to determine the cause.\u201d\u00a0 Cadle Co. v. D\u2019Addario<\/span>, 844 A.2d 836.<\/p>\n

\u201cThe general rule is that one party has no standing to raise another\u2019s rights.\u201d\u00a0 Security Ins. Co. of Hartford v. Lumbermens Mut. Ca. Co<\/span>., 826 A.2d 107.<\/p>\n

\u201cA party cannot rightfully invoke the jurisdiction of the court unless he has, in an individual or representative capacity, some real interest in the cause of action, or a legal or equitable right, title or interest inthe subject matter of the controversy.\u00a0 The burden rests with the party who seeks the exercise of jurisdiction in his favor to allege facts demonstrating that he is a proper party to invoke judicial resolution of the dispute and, has standing.\u201d\u00a0 Goodyear v. Discala<\/span>, 849 A.2d 791.<\/p>\n

Delaware<\/strong>:<\/p>\n

\u201cThough questioned by Wigmore, the prevailing American rule is that proof of the corpus delecti requires (1) proof of the injury, death or loss, according to the nature of the crime, and (2) proof of criminal means as the cause.\u00a0 7 Wigmore on Evidence, [section] 2072.\u00a0 This is the rule in Delaware.\u201d\u00a0 Nelson v. State<\/span>, 123 A.2d 859, 861.<\/p>\n

\u201cIn criminal prosecutions, the State need only show a \u201cbut for\u201d relationship between an action and a result to establish causation.\u201d \u00a0Bolluck v. State<\/span>, 775 A.2d 1043, 1049 (2001.<\/p>\n

\u201cThe party invoking the jurisdiction of a court bears the burden of establishing the elements of standing. The degree and manner of evidence that is required to establish standing varies as the successive of any litigation proceeds.\u00a0 At the pleading stage, general allegations of injury are sufficient to withstand a motion to dismiss\u2026When a motion for summary judgment is filed however, the plaintiff can no longer rest on such \u201cmere allegations.\u201d \u2026 The term \u201cstanding\u201d refers to the right of a party to invoke the jurisdiction of a court to enforce a claim or to redress a grievance.\u00a0 Standing is a threshold question that must be answered by a court affirmatively to ensure that the litigation before the tribunal is a \u201ccase or controversy\u201d that is appropriate for the exercise of the court\u2019s judicial powers.\u00a0 The issue of standing is concerned \u201conly with the question of who is entitled to mount a legal challenge and not with the merits of the subject matter in controversy.\u201d\u00a0 To establish standing, a plaintiff must demonstrate first, that he or she sustained an \u201cinjury-in-fact\u201d; and second, that the interests he or she seeks to be protected are within the zone of interests to be protected.\u201d\u00a0 Dover Hist. Soc. v. Dover Planning Com\u2019n<\/span>., 838 A.2d 1103, 1109-1110 ( Del.2003).<\/p>\n

Florida<\/strong>:<\/p>\n

\u201cCausation consists of two distinct subelements.\u00a0 As legal scholars have recognized, before a defendant can be convicted of a crime that includes an element of causation, the State must prove beyond a reasonable doubt that the defendant\u2019s conduct was (1) the \u201ccause in fact\u201d and (2) the \u201clegal cause\u201d (often called \u201cproximate cause\u201d) of the relevant harm\u2026In order to establish that a defendant\u2019s conduct was the \u201ccause in fact\u201d of a particular harm, the State usually must demonstrate that \u201cbut for\u201d the defendant\u2019s conduct, the harm would not have occurred.\u201d\u00a0 Eversly v. State<\/span>, 748 So.2d 963, 966-967 (Fla. 1999).<\/p>\n

\u201c\u201dA Cause of action is some particular legal right of plaintiff against defendant, together with some definite violation thereof which occasions loss or damage.\u201d\u00a0 Luckie v. McCall Manufacturing Co., 152 So.2d 311, 314\u2026\u201d\u00a0 Soowal v. Marden<\/span>, 452 So.2d 625, 626.<\/p>\n

\u201cIt is a fundamental principle of law that no person be adjudged guilty of a crime until the state has shown that a crime has been committed.\u00a0 The state therefore must show that a harm has been suffered of the type contemplated by the charges (for example, a death in the case of a murder charge or a loss of property in the case of a theft charge), and that such harm was incurred due to the criminal agency of another.\u00a0 Thus, it is sufficient if the elements of the underlying crime are proven rather than those of the particular degree or variation of that crime which may be charged.\u201d\u00a0 State v. Allen<\/span>, 335 So. 2d 823,825 (Fla. 1976).<\/p>\n

\u201cA party has standing when he or she has a sufficient stake in a justiciable controversy.\u00a0 Sierra Club v. Morton<\/em><\/a>, 405 U.S. 727, 731\u2026To establish standing it must be shown that the party suffered injury in fact (economic or otherwise) for which relief is likely to be addressed.\u00a0 See Warth v. Seldin<\/a> <\/em>, 422 U.S. 490, 501\u2026it may not be abstract, conjectural or hypothetical.\u00a0 Allen v. Wright<\/em><\/a>, 468 U.S. 737, 791\u2026\u201d\u00a0 Peregard v. Cosmides<\/span>, 663 So.2d 665, 668.<\/p>\n

\u201cA litigant must assert his or her own legal rights and interests, and cannot rest claim to relief on the legal rights or interests of third paries.\u201d\u00a0 Alterra Healthcare Corp. v. Estate of Shelley<\/span>, 827 So.2d 936.<\/p>\n

\u201cGenerally, to have standing to bring an action the plaintiff must allege that he has suffered or will suffer a special injury.\u201d\u00a0 Alachua County v. Scharps<\/span>, 855 So.2d 195.<\/p>\n

Georgia<\/strong>:<\/p>\n

\u201cIn defining \u2018corpus delecti\u2019 Wharton says: \u2018It is made up of two elements: (1) That a certain result has been produced\u2026(2) That some one is criminally responsible for the result\u2026\u201d\u00a0 McVeigh v. State<\/span>, 53 S.E.2d 462, 469.<\/p>\n

\u201cA cause of action is some particular right of the plaintiff against the defendant, together with some definite violation of that right which occasions damage, whether the right arises by contract or tort.\u00a0 Ellison v. Ga. R. Co.<\/em>, 87 Ga. 691, 13 S.E. 809 (1891); City of Columbus v. Anglin<\/em>. 120 Ga. 785(4), 48 S.E. 318 (1904).\u00a0 It may also be defined from the standpoint of duties, provided the complainant has proven a duty owed by the defendant to him, and a breach of that duty shown which results in loss to the complainant.\u00a0Ellison v. Ga. R. Co.<\/em>,\u00a0supra.\u00a0 There can be no right of action until there has been a wrong, that is, a violation of a legal right or breach of a legal duty\u2026\u201d\u00a0 Bryant v. Randall<\/span>, 261 S.E.2d 602,\u00a0605-606.<\/p>\n

\u201cParticular remedy is not available to party who has no entitlement to right sought to be secured.\u201d\u00a0 Ragsdale v. New England Land and Development Corp<\/span>., 297 S.E.2d 31.<\/p>\n

\u201cStanding deals with question of whether party may assert right even presuming it exists.\u201d\u00a0 Nationwide Mortg. Resources, Inc. v. Stalzer<\/span>, 455 S.E.2d 402.<\/p>\n

Hawaii<\/strong>:<\/p>\n

\u201cIn order to prove that a crime occurred, the State must prove beyond a reasonable doubt: (1) the basic injury \u2026, (2) the fact that the basic injury was the result of a criminal, rather than a natural or accidental\u00a0cause\u2026\u201d\u00a0 State v. Libero<\/span>, 83 P.3d 753, 763 (2003), [quoting State v. Dudoit<\/span>, 55 Haw. 1, 2, 514 P.2d 373, 374 (1973)].<\/p>\n

\u201c\u201cCorpus delecti\u201d of any particular crime means actual commission of crime by someone and it made up of two elements; that is, certain result has been produced and some person is criminally responsible for the act.\u201d\u00a0 State v. Hale<\/span>, 367 P.2d 81, 85, 45 Haw. 269.<\/p>\n

\u201cPlaintiff without standing is not entitled to invoke a court\u2019s jurisdiction.\u201d\u00a0 Mottle v. Miyahira<\/span>, 23 P.3d 716.<\/p>\n

\u201cPetitioner must satisfy all three prongs of the three-part \u201cinjury-in-fact\u201d test to establish its standing.\u201d\u00a0 Sierra Club v. Hawai\u2019I Tourism Authority ex rel Board of Directors<\/span>, 59 P.3d 877.<\/p>\n

Idaho<\/strong>:<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cIn Miles v. Idaho Power Co<\/em>, 116 Idaho 635, 778 P.2d 757 (1989), the court stated three basic propositions concerning standing that guide our decision here: 1. \u201cThe doctrine of standing focuses on the party seeking relief and not on the issues the party wishes to have adjudicated.\u201d 2. \u201c[T]o satisfy the case or controversy requirement of standing, litigants generally must allege or demonstrate an injury in fact and a substantial likelihood that the judicial relief requested will prevent or redress the claimed injury.\u201d\u00a0 Boundary Backpackers v. Boundary County<\/span>, 913 P.2d 1141, 1145.<\/p>\n

\u201cPerson wishing to invoke a court\u2019s jurisdiction must have standing\u2026Doctrine of standing focuses on the party seeking relief and not on the issues the party wishes to have adjudicated\u2026To satisfy the requirement of standing, the petitioners must allege or demonstrate an injury in fact and a substantial likelihood that the judicial relief requested will prevent or redress the claimed injury.\u201d\u00a0 Schneider v. Howe<\/span>, 133 P.3d 1232.<\/p>\n

\u201cThe issue of standing is jurisdictional and may be raised at any time.\u201d\u00a0 Beach lateral Water Users Ass\u2019n v. Harrison<\/span>, 130 P.3d 1138.<\/p>\n

\u201cThe doctrine of standing focuses on the party seeking relief and not the issues the party wishes to have adjudicated.\u201d\u00a0 Troutner v. Kempthorn<\/span>, 128 P.3d 926.<\/p>\n

\u201cStanding is a fundamental prerequisite to invoking a court\u2019s jurisdiction.\u201d\u00a0 Noh v. Cenarrusa<\/span>, 53 P.3d 1217.<\/p>\n

Illinois<\/strong>:<\/p>\n

\u201cOccurrence of injury or loss, and its causation by criminal conduct, are termed the \u201ccorpus delecti.\u201d\u00a0 People v. Assenato<\/span>, 586 N.E.2d 445, 448, 166 Ill.Dec. 487, 490.<\/p>\n

\u201c\u201cCorpus delecti\u201d of an offence consists of fact that injury occurred and fact that injury was caused by a criminal act.\u201d\u00a0 People v. Lewis<\/span>, 498 N.E.2d 1169, 1174, 101 Ill.Dec. 661, 666.<\/p>\n

\u201cIt is elementary that the corpus delecti<\/em> constitutes an essential element of a criminal prosecution\u2026\u201d\u00a0 People v. O\u2019Neil<\/span>, 165 N.E.2d 319, 320.<\/p>\n

\u201cRather, we understand the rule to be that the corpus delecti<\/em>, like every essential element of a criminal case, must be proved by competent evidence beyond a reasonable doubt.\u201d\u00a0 People v. Jones<\/span>, 177 N.E.2d 112, 114.<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cIn Illinois, standing requires only some injury in fact to a legally cognizable interest and the injury, whether actual or threatened, must be distinct and palpable, fairly traceable to the defendant\u2019s actions, and substantially likely to be prevented or redressed by the\u2026relief requested.\u201d\u00a0 In re D.W.<\/span>, 799 N.E.2d 410.<\/p>\n

\u201cStanding requries only some injury in fact to a legally cognizable interest.\u201d \u00a0 In re County Treasurer and Ex Officio County Collector of Cook County<\/span>, 775 N.E.2d 86.<\/p>\n

\u201cThis court has repeatedly held that standing requires some injury in fact to a legally recognized interest.\u201d\u00a0 In re Estate of Wellman<\/span>, 673 N.E.2d 272, 276 (Ill. 1996).<\/p>\n

\u201cThe definition of judicial power given by Judge Cooley in his work on Constiutional Limitations, held by this court to be sufficiently accurate\u00a0 for the purposes of the question then before the court, which was in substance the same as that now under consideration, is as follows: \u201cThe power which adjudicates upon and protects the rights and interests of individual citizens, and to that end construes and applies the laws.\u201d\u00a0 Owners of Lands v. People, 113 Ill. 309.\u201d\u00a0 People v. Chase<\/span>, 46 N.E. 454, 458.\u00a0 Also quoted in People v. Bruner<\/span>, 175 N.E. 400, 404<\/p>\n

\u201c\u201dJudicial power\u201d implies the construction of laws and the adjudication of legal rights\u2026[note 6] No law is construed by the board, and no legal rights are submitted to and adjudicated by it, without which, we have seen, judicial power is not exercised.\u201d\u00a0\u00a0People v. Appelbaum<\/span>, 95 N.E. 995, 997.<\/p>\n

\u201cJudicial power is the power which adjudicates upon the rights of citizens, and to that end construes and applies the law.\u201d\u00a0\u00a0People v. Hawkinson<\/span>, 155 N.E. 318, 319.<\/p>\n

Indiana<\/strong>:<\/p>\n

\u201cCorpus delecti consists of a showing of \u201c1) the occurrence of the specific kind of injury and 2) someone\u2019s criminal act as the cause of the injury.\u201d”\u00a0 Johnson v. State<\/span>, 653 N.E.2d 478, 479 (Ind. 1995).<\/p>\n

\u201cState must produce corroborating evidence of \u201ccorpus delecti,\u201d showing that injury or harm constituting crime occurred and that injury or harm was caused by someone\u2019s criminal activity.\u201d\u00a0 Jorgensen v. State<\/span>, 567 N.E.2d 113, 121.<\/p>\n

\u201cTo establish the corpus delecti, independent evidence must be presented showing the occurrence of a specific kind of injury and that a criminal act was the cause of the injury.\u201d\u00a0 Porter v. State<\/span>, 391 N.E.2d 801, 808-809.<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cThe distinction between torts and\u00a0crimes is\u00a0based upon the public nature of the criminal offense.\u00a0 \u201cAlthough the same act may constitute both a crime and\u00a0a tort, the crime is an offense against the public pursued by the sovereign, while the tort is a private injury which is pursued by the injured party.\u201d\u00a0 14 Am.Jur. 755, [section] 3.\u00a0 The same distinction has been noted by another authority in the following language:\u00a0 \u201cThe real distinction between a tort and a crime is to be sought for, not in a difference between their tendencies, but in the\u00a0difference between the methods by\u00a0which\u00a0the remedy for\u00a0the wrong is pursued, a wrong for\u00a0which the remedy is pursued by and at the discretion of the individual injured or his representative being a tort, and a wrong for which the wrongdoer is proceeded against by the sovereign or state for the purpose of punishment being a crime.\u201d\u00a0 State v. White Circuit Court<\/span>, 77 N.E.2d 298, 300-301.<\/p>\n

\u201cStanding is a fundamental, threshold, constitutional issue that must be addressed by this, or any, court to determine if it should exercise jurisdiction in the particular case before it.\u00a0 The issue of standing focuses on whether the complaining party is the proper one to invoke the court\u2019s power.\u00a0 Scott v. Randell<\/em>, 736 N.E.2d 308 (Ind.Ct.App.2000)\u2026To establish standing, therefore, a plaintiff must demonstrate a personal stake in the outcome of the lawsuit and that the injury is a result of the defendant\u2019s conduct [citation omitted].\u00a0 If properly challenged, when a plaintiff fails to establish standing in the pleadings, the court must dismiss the complaint.\u00a0 Shulz v. State<\/span>, 731 N.E.2d 1041.\u00a0 Moreover:<\/p>\n

Although the Indiana constitution contains no \u201ccase or controversy\u201d requirement, the federal limits on justiciability are instructing because the standing requirement under both federal and state constitutional law fulfills the same purpose; ensuring that the litigant is entitled to have the court decide the merits of the dispute or of the particular issues.\u00a0 Id. at 1044.\u00a0 Under the federal test, to establish standing a plaintiff must allege a personal injury that is fairly traceable to the defendant\u2019s allegedly unlawful conduct and is likely to be redressed by the requested relief.\u00a0 Id. citing Allen v. Wright<\/em><\/a>, 768 U.S. 737\u2026\u201d\u00a0 Alexander v. PSB Lending Corp<\/span>, 800 N.E.2d 984, 989.<\/p>\n

\u201cUnder the general rule of standing, only those persons who have a personal stake in the outcome of the litigation and who show that they have suffered or were in immediate danger of suffering a direct injury as a result of the complained-of conduct will be found to have standing; absent this showing, complainants may not invoke the jurisdiction of the court.\u201d\u00a0 State ex rel Citidine v. Indiana Dept. of Trans<\/span>.,790 N.E.2d 978.<\/p>\n

Iowa<\/strong>:<\/p>\n

While the corpus delecti must be proved beyond all reasonable doubt, yet it may be established by circumstantial as well as direct evidence.\u00a0 State v. Wescott<\/span>, 104 N.W. 341, 130 Iowa 1; State v. Kelly<\/span>, 186 N.W. 834, 193 Iowa 62.<\/p>\n

\u201cThe principals of causation\u00a0normally associated with civil tort litigation are pertinent in\u00a0criminal cases.\u00a0 State v. Murray<\/em>, 512 N.W.2d 547, 550 (Iowa 1994).\u201d\u00a0 State v. Garcia<\/span>, 616 N.W.2d 594, 596 (Iowa 2000).<\/p>\n

\u201cIn order for there to be a \u201cright of action\u201d or \u201ccause of action,\u201d there must be a legal right in plaintiff corresponding duty on part of the defendant and attendant breach of that duty with resultant harm to plaintiff\u2026\u201d\u00a0 Giltner v. Stark<\/span>, 252 N.W.2d 743.<\/p>\n

\u201cTo have standing, complaining party must have specific, personal, and legal interest in the litigation and be injuriously affected.\u201d\u00a0 In re Marriage of Mitchell<\/span>, 531 N.W.2d 132.<\/p>\n

\u201cone should bear in mind the fundamental principal that courts are instituted to afford relief to persons whose rights have been invaded, or are threatened with invasion by the defendant\u2019s act or conduct\u2026\u201d\u00a0 Bowers v. Bailey<\/span>, 21 N.W.2d 773, 776.<\/p>\n

\u201cCorpus delecti is made up of two element: (1) a result has been produced\u2026(2) some one is criminally responsible for the result.\u201d\u00a0 State v. Stamper<\/span>, 195 N.W.2d 110, 112-113.<\/p>\n

\u201cIn our opinion, the term [corpus delecti] means, when applied to any particular offense, that the particular crime charged has actually been committed by some one.\u00a0 It is made up of two elements: First, that a certain result has been produced\u2026second, that some one is criminally responsible for the result.\u201d\u00a0 State v. Whisler<\/span>, 3 N.W.2d 525, 528.<\/p>\n

Kansas<\/strong>:<\/p>\n

\u201cWe first note that standing is a jurisdictional issue in Kansas\u2026As a result, standing is not waivable.\u201d\u00a0 Midcontinental Specialists v. Capital Homes<\/span>, 106 P.3d 483.<\/p>\n

\u201cStanding is a question of whether the plaintiff has alleged such a personal stake in he outcome of a controversy as to warrant invocation of jurisdiction and to justify\u00a0 exercise of the courts\u2019 remedial powers on his behalf\u2026The party must have personally suffered some injury and there must be a causal connection between the injury and the challenged conduct.\u201d\u00a0 Moorhouse v. City of Wichta<\/span>, 913 P.2d 172, 176.<\/p>\n

\u201cGenerally, \u201cstanding\u201d requires that a plaintiff have a personal interest in the court\u2019s decision, and that he or she personally has suffered some actual or threatened injury as a result of a putatively illegal conduct of the defendant.\u201d\u00a0 Lower v. Bd. of Directors of Haskell County Cemetary Dist<\/span>., 56 P.3d 235.<\/p>\n

\u201cStanding is a jurisdictional issue.\u201d\u00a0 Nichols v. Kansas Governmental Ethics Com\u2019n<\/span>., 18 P.3d 270.<\/p>\n

\u201cIt is the primary duty of the courts to safeguard the declaration of right and remedy guaranteed by the constitutional provision insuring a remedy for all injuries.\u201d\u00a0 Noel v. Menninger Foundation<\/span>, 267 P.2d 934, 943.<\/p>\n

Kentucky<\/strong>:<\/p>\n

\u201cBefore a party can have a controversy judicially determined, he must have an interest in the subject matter\u2026Generally, a defect in parties or objections based upon the absence of a legal right to maintain\u00a0an action should be raised\u00a0by a demurrer, plea in abatement or in bar.\u201d\u00a0 Thompson-Starrett Co. v. Mason\u2019s Adm\u2019rs<\/span>., 201 S.W.2d 786, 883.<\/p>\n

Louisiana:<\/strong><\/p>\n

<\/a><\/strong>All government, of right, originates with the people, is founded on their will alone, and is instituted to protect the rights of the individual and for the good of the whole. Its only legitimate ends are to secure justice for all, preserve peace, protect the rights, and promote the happiness and general welfare of the people. The rights enumerated in this Article are inalienable by the state and shall be preserved inviolate by the state. \u201c\u00a0 Article I \u00a7 1, Louisiana constitution<\/a>.<\/a><\/strong><\/p>\n

\u201c\u201cCorpus delecti,\u201d the body or substance of a crime, is composed of two elements: occurrence of an unlawful injury, and illegal conduct causing that injury.\u201d\u00a0 State v. Outlaw<\/span>, 485 So.2d 217, 221.<\/p>\n

\u201cCorpus delecti, the body or substance of a crime, has two elements: (1) an unlawful injury has occurred; and (2) some person\u2019s illegal conduct caused that injury.\u201d\u00a0 State v. Reed<\/span>, 420 So.2d 950, 951.<\/p>\n

Maine:<\/strong><\/p>\n

\u201cThe United States Supreme Court as stated that standing requires one who as suffered an injury to show that the injury in fact is fairly traceable to the challenged action and that such injury is likely to be redressed by the judicial relief sought.\u00a0\u00a0 Allen v. Wright<\/em><\/a> , 468 U.S. 737\u2026We have previously held that to have standing a litigant must have suffered a particularized injury that is distinct from the harm suffered by the public at large\u2026We have construed particularized injury as an injury resulting from an action adversely and directly affecting the party\u2019s property, pecuniary or personal rights.\u00a0 New England Herald Dev. Group v. Town of Falmouth<\/em>, 521 A.2d 693, 695 (Me. 1987).\u201d\u00a0 Proctor v. County of Penobscot<\/span>, 651 A.2d 355, 357.<\/p>\n

You\u2019ll notice that the attorney for the County wrote: a plaintiff \u201cgenerally must assert his own legal rights and interest and cannot rest his claim to relief on the legal rights or interest of third parties.\u201d\u00a0 Also at page 357.<\/p>\n

\u201cThe requirement for standing that a party suffer an injury that is fairly traceable to the challenged action is met when a defendant\u2019s actions have adversely affected and directly affected the party\u2019s property, pecuniary or personal rights.\u201d\u00a0 Collins v. State<\/span>, 750 A.2d 1257, 1260.<\/p>\n

Maryland<\/strong>:<\/p>\n

\u201cWhile the corpus delecti<\/em> must be proved beyond a reasonable doubt\u2026it may be established by circumstantial evidence\u2026\u201d\u00a0 James v. State<\/span>, 248 A.2d 910, 912.<\/p>\n

\u201cProperly understood the general principle is sound, for courts only adjudicate justiciable controversies\u2026 courts must look behind names that symbolize the parties to determine whether a justiciable case or controversy is presented.\u201d\u00a0 Blind Industries v. D.G.S<\/span>., 808 A.2d 782, 784 (Md. 2002) [quoting United States v. Interstate Commerce Commission<\/span><\/a>, 337 U.S. 426 (1949)].<\/p>\n

Massachusetts<\/strong>:<\/p>\n

\u201cThe end of the institution, maintenance, and administration of government is to secure the existence of the body-politic, to protect it, and to furnish the individuals who compose it with the power of enjoying, in safety and tranquillity, their natural rights and the blessings of life\u2026\u201d\u00a0 Preamble<\/a>, Massachusetts Constitution 1780, still in current constitution<\/a> .<\/p>\n

\u201cCriminal responsibility is imposed on the basis of the intentional doing of an act with awareness of the probability that the act will result in substantial damage, regardless of whether the injury turns out to be minor or insignificant.\u201d\u00a0 Com. v. Ruddock<\/span>, 520 N.E.2d 501.<\/p>\n

\u201cThe issue of standing may be raised at any time.\u201d\u00a0 In re Harvard Pilgrim Healthcare, Inc.<\/span>, 746 N.E.2d 513.<\/p>\n

\u201cTo have standing in any capacity, a litigant must show that the challenged action has caused litigant injury.\u201d\u00a0 Perella v. Massachusetts Turpike Auth<\/span>., 772 N.E.2d 70.<\/p>\n

\u201cCourts are not established to enable parties to litigate in which they have no interest affecting their liberty, rights or property.\u201d\u00a0 Razin v. Razin<\/span>, 124 N.E.2d 269, 270.<\/p>\n

Michigan<\/strong>:<\/p>\n

\u201cLack of license to carry a concealed weapon established that crime had been committed and therefore was part of the \u201ccorpus delecti.\u201d\u00a0 People v. Autry<\/span>, 152 N.W.2d 55, 56, 7 Mich.App.480.<\/p>\n

\u201c\u201cCorpus delecti\u201d includes fact of specific loss or injury and someone\u2019s criminality.\u201d\u00a0 People v. Randall<\/span>, 201 N.W.2d 292, 293, 42 Mich.App. 187.<\/p>\n

\u201c\u201cCorpus delecti,\u201d meaning body or substance of crime charged, involves two elements: injury which is penally proscribed and unlawfulness of some person\u2019s conduct in causing injury.\u201d\u00a0 People v. Swift<\/span>, 470 N.W.2d 491, 492, 188 Mich.App. 619.<\/p>\n

\u201cFor there to be criminal responsibility, defendant\u2019s acts must have caused harm.\u201d\u00a0 People v. Zak<\/span>, 457 N.W.2d 59.
\n\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cAlthough the same act may constitute both a crime and\u00a0a tort, the crime is an offense against the public pursued by the sovereign, while the tort is a private injury which is pursued by the injured party.\u201d\u00a0 People v. Veenstra<\/span>, 60 N.W.2d 309, 310-311.<\/p>\n

\u201cStanding relates to civil as well as criminal matters.\u201d\u00a0 People v. Smith<\/span>, 360 N.W.2d 841, 844-845 (Mich. 1984).<\/p>\n

\u201cIn order to have standing, a party must have a legally protected interest that is in jeopardy of being adversely affected.\u201d\u00a0 In re Foster<\/span>, 573 N.W.2d 324, 328.<\/p>\n

\u201cPlaintiff must assert his own legal rights and interests and cannot rest his claim to relief on legal rights or interests of third parties.\u201d\u00a0 Fieger v. Commissioner of Ins<\/span>., 437 N.W.2d 271.<\/p>\n

\u201cTo adjudicate upon and protect the rights and interests of individual citizens, and to that end to construe and apply the laws, is the peculiar province of the judicial department\u2026The primary functions of the judiciary are to declare what the law is and to determine the rights of parties conformably thereto.\u201d\u00a0 Johnson v. Kramer Bros. Freight Lines, Inc.<\/span>, 98 N.W.2d 586, 588.<\/p>\n

Minnesota<\/strong>:<\/p>\n

\u201cOBJECT OF GOVERNMENT. Government is instituted for the security, benefit and protection of the people, in whom all political power is inherent, together with the right to alter, modify or reform government whenever required by the public good.\u201d\u00a0 Minnesota constitution Article I \u00a7 1<\/a>.<\/p>\n

\u201cJUDICIAL POWER<\/strong>\u2026Power that adjudicates upon and protects the rights and interests of persons or property, and to that end declares, construes and applies the law, In re Hungstiger, 130 Minn. 474, 153 N.W. 869, 870; People ex rel. Rusch v. White 334 Ill. 465, 166 N.E. 100, 106, 64 A.L.R. 1006; In re Assessment of Kansas City Southern Ry. Co., 168 Okl. 495, 33 P.2d 772, 775\u2026\u201d\u00a0 Black\u2019s Law Dictionary, Rev. 4th Ed<\/span>., page 986.\u00a0 [Could be used anywhere]<\/p>\n

The corpus delecti must be proven beyond a reasonable doubt.\u00a0 State v. Lalizer<\/span>, 4 Minn. 368.<\/p>\n

\u201cA \u201ccause of action\u201d is a violation of a legal right.\u201d\u00a0 Halliwill v. Mutual Service Ca. Ins. Co<\/span>., 100 N.W.2d 817.<\/p>\n

\u201cTo have standing to bring claim, a person must have suffered some injury in fact as a result of the alleged actions.\u201d\u00a0 Epland v. Meade Ins. Agency Associates<\/span>, 564 N.W.2d 203, 208 (Minn. 1997).<\/p>\n

\u201cJudicial power is the power that adjudicates upon the rights or persons or property, and to that end declares, construes and applies the law.\u201d\u00a0 In re Hunstiger<\/span>, 153 N.W. 869, 870.<\/p>\n

Mississippi<\/strong>:<\/p>\n

\u201cThe Latin words \u201ccorpus\u00a0delecti\u201d mean literally, \u201cthe body of the crime\u201d.\u00a0 In order to prove the corpus delecti, there are two elements which must be proved beyond a reasonable doubt:\u00a0 One, the existence of a\u00a0certain act or result forming the basis of that criminal charge; and, two, the existence of criminal agency as the cause of this act or result\u2026It is a well-settled principal of criminal law that a conviction for crime cannot be had unless the corpus delecti-that is, the fact that a crime has actually been perpetrated (the fact of injury or harm and the existence of some person criminally responsible therefore)-is first established by the prosecution.\u00a0 In other words, the prosecution must establish the actual commission, by someone, of the particular offense charged.\u00a0 The accused is not required in any case to answer a charge against him in the absence of evidence upon the part of the prosecution sufficient to establish the corpus delecti; and if an accused is found guilty despite the failure of the prosecution to establish the corpus delecti, the verdict may be set aside and a new trial ordered\u2026the reason the state is requried to prove the corpus delecti is to satisfy the mind that there is a real and not an imaginary crime for which the accused stands charged.\u201d\u00a0 Kirtkland v. State<\/span>, 371 So.2d 402, 404.<\/p>\n

\u201cIt [corpus delecti] has two elements which must be proven beyond a reasonable doubt in order to show that a crime has actually been committed [citations omitted].\u00a0 First, it is necessary to prove the existence of a certain act or result forming the basis of the criminal charge\u2026Moreover, the State must prove the existence of criminal agency as the cause of this act or result\u2026However, \u201c[e]very element, criminal charge, and criminal agency myst be proved beyond a reasonable doubt.\u201d”\u00a0 Parks v. State<\/span>, 884 So.2d 738, 743 (Miss. 2004).<\/p>\n

\u201cThe United States Supreme Court has stated the concept of standing generally embraces \u201cthe general prohibition on a litigant raising another person\u2019s legal rights\u2026\u201d\u00a0 Mount v. Mount<\/span>, 624 So2d. 997, 1001.<\/p>\n

\u201cA suit cannot be maintained where it appears from the declaration itself the right of action is not in the party suing, but in another.\u201d\u00a0 Haynes v. Ezell<\/span>, 25 Miss. (3 Cushm.) 242.<\/p>\n

Missouri<\/strong>:<\/p>\n

\u201cTo prove guilt of any crime, State must first demonstrate the crime\u2019s corpus delecti, or body of crime, consisting of two elements \u2013 that loss or injury charged has occurred and that someone\u2019s criminal agency caused loss or injury.\u201d\u00a0 State v. Davis<\/span>, 797 S.W.2d 560.<\/p>\n

\u201c\u201dCorpus delecti\u201d consists of proof, direct or circumstantial, the specific loss or injury occurred and criminal behavior by someone as cause of loss or injury.\u201d\u00a0 State v. Frentzel<\/span>, 730 S.W.2d 554.<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201c\u201cCorpus delecti\u201d consists of two elements: proof, direct or circumstantial, that specific loss or injury occurred, and that someone\u2019s criminality is cause of loss or injury; proof need not include proof of defendant\u2019s connection with crime charged.\u201d\u00a0 State v. Friesen<\/span>, 725 SW2d 638, 639.<\/p>\n

\u201cLack of standing cannot be waived.\u201d\u00a0 In re Ancillary Adversary Proceeding Questions<\/span>, 89 S.W.3d 460.<\/p>\n

\u201cA party seeking relief must have a legally cognizable interest in the subject matter and a threatened or actual injury to have standing.\u201d\u00a0 Meyer v. Meyer<\/span>, 77 S.W.3d 40.<\/p>\n

\u201cA party is \u201cinjured\u201d for purposes of determining whether a party has standing to sue, if a legal right of that party is violated.\u201d\u00a0 R.J.S. Sec., Inc. v. Command Sec. Services, Inc<\/span>., 101 S.W.3d 1.<\/p>\n

\u201cRegardless of the action\u2019s merits, unless the parties to the action have proper standing, a court may not entertain the action\u2026Standing requires that a party seeking relief have a legally cognizable interest in the\u00a0subject matter and that\u00a0he has a threatened or actual injury.\u201d\u00a0 E. Mo. Laborers D. Coun. v. St. Louis Cty<\/span>., 781 S.W.2d 43, 45-46\u00a0(Mo.banc 1989).<\/p>\n

Montana<\/strong>:<\/p>\n

\u201cGenerally speaking, the term \u201ccorpus delecti,\u201d when applied to any particular offense, means that the specific crime charged has actually been committed by some one, and it is made up of two elements: First, that a certain result has been produced\u2026second, that some one is criminally responsible for the result\u2026\u201dState v. Kindle<\/span>, 227 P. 65, 67.<\/p>\n

\u201cWe have previously stated that the following criteria must be satisfied to establish standing: (1) The complaining party must clearly allege past, present or threatened injury to a property or civil right; and (2) the alleged injury must be distinguishable from the injury to the public generally, but the injury need not be exclusive to the complaining party.\u201d\u00a0 Gryczan v. State<\/span>, 942 P.2d 112, 118.<\/p>\n

\u201cStanding is a threshold requirement of every case.\u201d\u00a0 Palmer v. Bahm<\/span>, 128 P.3d 1031.<\/p>\n

\u201c\u2018Standing\u2019 is a person\u2019s right to make a legal claim or seek judicial enforcement of a duty or right.\u201d\u00a0 In re Parenting of D.A.H<\/span>., 109 P.3d 247.<\/p>\n

\u201cStanding is part of the larger question whether a controversy is justiciable.\u201d Stroebe v. State<\/span>, 127 P.3d 1051.<\/p>\n

\u201cIt is axiomatic and this court has consistently held that the existence of a justiciable controversy is a threshold requirement in order for a court to grant relief\u2026To maintain an action the plaintiff must show that he has a right to be enforced or a wrong to be prevented or redressed\u2026but he is is without standing where it is not shown that his rights have been, or are about to be, invaded.\u201d\u00a0 Powder River County v. State<\/span>, 60 P.3d 357, 379 (Mont. 2002).<\/p>\n

\u201cStanding to sue refers to a \u201cparty\u2019s right to make a legal claim or seek judicial enforcement of a duty or right\u2026A threshold requirement of every case is that a party have standing to bring the action\u2026The mere fact that a person is entitled to bring an action under a given statute is insufficient to establish standing; the party must allege some past, present, or threatened injury which would be alleviated by successfully maintaining the action\u2026Since the general rule is that \u2018a litigant may only assert his own constitutional rights or immunities\u2026\u2019\u201d\u00a0 In re B.F<\/span>., 87 P.3d 427, 430-431.<\/p>\n

Nebraska<\/strong>:<\/p>\n

\u201cTo sustain a conviction, the corpus delecti must be proved beyond a reasonable doubt.\u201d\u00a0 State v. George<\/span>, 424 N.W.2d 350, 351.<\/p>\n

The corpus delecti must be proven beyond a reasonable doubt.\u00a0 Chezem v, State<\/span>, 76 N.W. 1056, 56 Neb. 496; McCue v. State<\/span>, 198 N.W. 163, 112 Neb. 9<\/p>\n

\u201cTo establish standing to being suit it is necessary to show that party is in danger of sustaining direct injury as result of anticipated action\u2026\u201d\u00a0 First Federal Sav. & Loan Assn. of Lincoln v. Department of Banking<\/span>, 192 N.W.2d 736.<\/p>\n

\u201d To have standing to invoke a tribunal\u2019s jurisdiction, one must have some legal or equitable right, title or interest in the subject of the controversy.\u201d\u00a0 Douglas County Bd. of Com\u2019rs v. Civil Service Com\u2019n, Douglas County<\/span>, 641 N.W.2d 55.<\/p>\n

\u201cIn order to have standing, a litigant must assert the litigant\u2019s own legal rights and interests and cannot rest his or her claim on the legal rights or interests of third parties\u2026\u201d\u00a0 Adam v. City of Hastings<\/span>, 676 N.W.2d 710.<\/p>\n

\u201cStanding is the legal or equitable right, title or interest in the subject of the controversy\u2026Standing relates to the court\u2019s power, that is, jurisdiction, to address the issues presented and serves to indentify those disputes which are appropriately resolved through the judicial process\u2026Standing is a jurisdictional component of a party\u2019s case because only a party who has standing may invoke the jurisdiction of a court\u2026The purpose of an inquiry as to standing is to determine whether one has a legally protectable interest or right in the controversy\u2026In order to have standing, a litigant must assert the litigant\u2019s own legal rights and interests and cannot rest his or her claim on the legal rights or interests of third parties.\u201d\u00a0 County of Sarpy v. City of Gretna<\/span>, 678 N.W.2d 740 (Neb. 2004).<\/p>\n

\u201cA cause of action is judicial protection of one\u2019s recognized right or interest, when another, owing a corresponding duty not to invade or violate such right or interest, has caused a breach of that duty.\u201d\u00a0 Millman v. County of Butler<\/span>, 458 N.W.2d 207, 214.<\/p>\n

\u201cgenerally judicial power is the authority to hear and determine a controversy as to rights and upon such determination to render a judgment binding upon the disputants.\u201d\u00a0 Laverty v. Cochran<\/span>, 271 N.W. 354, 357.<\/p>\n

New Hampshire<\/strong>:<\/p>\n

\u201cTo establish causation, the State needed to prove not only that the prohibited result would not have occurred but for the conduct of the defendant, but also that the defendant\u2019s conduct was the legal (or proximate) cause of the prohibited result.\u201d \u00a0State v. Lamprey<\/span>, 821 A.2d 1080, 1082 (N.H. 2003)<\/p>\n

\u201cIn evaluating whether a party has standing to sue, we focus on whether the plaintiff suffered a legal injury against which the law was designed to protect.\u201d\u00a0 Roberts v. General Motors Corp<\/span>., 643 A.2d 956, 958 (N.H. 1994).<\/p>\n

\u201cIn evaluating whether a party has standing to sue, we focus on whether the plaintiff suffered a legal injury against which the law was\u00a0designed to protect\u2026Here, the plaintiffs suffered no injury\u2026They therefore lack standing\u2026\u201d\u00a0 Malnati v. State<\/span>, 803\u00a0A.2d 587, 590 (N.H. 2002).<\/p>\n

\u201cthe duty of this court, as of every judicial tribunal<\/em><\/strong>, is limited to determining rights<\/em><\/strong> of persons or of property, which are actually controverted in the particular case before it.\u201d\u00a0 Tyler v. Judges of the Court of Registration<\/span>, 179 U.S. 405, 21 SCt. 206, 208.<\/p>\n

New Jersey<\/strong>:<\/p>\n

The term \u201ccorpus delecti\u201d embraces occurrence of loss or injury and criminal causation thereof.\u201d\u00a0 State v. Hill<\/span>, 221 A.2d 725, 728, 47 N.J. 490.<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cProof of the corpus delecti<\/em> \u2013 the fact of injury or, in a homicide case, of death, by a criminal agency \u2013 may be supplied by direct or circumstantial evidence.\u00a0 State v. Zarinsky<\/span>, 362 A.2d 611, 621.<\/p>\n

\u201cProof of the corpus delecti<\/em> is required in all criminal cases\u2026There are three basic elements in the proof of a crime: (1) the occurrence of loss or injury, (2) criminal causation of that loss or injury and (3) the identity of the defendant as the perpetrator of the crime.\u00a0 However, it is firmly established in this State that the term corpus delecti<\/em> embraces only the first two of these elements-loss or injury and criminal causation.\u201d\u00a0 State v. Hill<\/span>, 221 A.2d 725, 728.<\/p>\n

\u201cIt is true that the above care all cases of felonious homicide, but the doctrine [of corpus delecti] is in nowise peculiar to such cases; it is equally applicable to all criminal cases.\u201d\u00a0 State v. Gelzeiler<\/span>, 128 A. 240.<\/p>\n

\u201cStanding in no way depends on the merits of the plaintiff\u2019s contention that particular conduct is illegal.\u201d\u00a0 Watkins v. Resorts Intern. Hotel & Casino<\/span>, 591 A.2d 592, 601 (N.J. 1991).<\/p>\n

\u201cNormally, an individual will only be permitted to seek judicial vindication of his own rights.\u201d\u00a0 State v. Norflett<\/span>, 337 A.2d 609.<\/p>\n

\u201cStanding requires only a substantial likelihood of some harm visited upon the plaintiff in the event of an unfavorable decision.\u201d In re Camden County<\/span>, 790 A.2d 158.<\/p>\n

New Mexico<\/strong>:<\/p>\n

\u201c\u2018Standing\u2019 is a doctrine requiring that the claimant must have a personal stake in the outcome of the case; the claimant must allege both injury in fact and a traceable causal connection between the claimed injury and the challenged conduct.\u00a0 Dona Ana County Clerk v. Martinez<\/span>, 124 P.3d 210.<\/p>\n

\u201cStanding requires injury in fact, causation, and likelihood of redress.\u201d\u00a0 Williams v. Stewart<\/span>, 112 P.3d 281.<\/p>\n

\u201cLack of standing is a potential jurisdictional defect, which may not be waived and may be raised at any stage of the proceedings, even sua sponte by the appellate court.\u201d\u00a0 Gunaji v. Macias<\/span>, 31 P.3d 1008.<\/p>\n

New York<\/strong>:<\/p>\n

\u201cWe hold these truths to be self-evident, that all men are created equal; that they are endowed by their Creator with certain unalienable rights; that among these are, life, liberty, and the pursuit of happiness; that to secure these rights, governments are instituted among men\u201d\u00a0 New York constitution, April 20, 1777<\/a>.<\/p>\n

\u201cA crime is an inexcusable act committed by an individual in excess of his personal liberties and injures person or property within the victim\u2019s personal freedom or property right.\u201d<\/p>\n

\u201cWhat is liberty or freedom?\u201d<\/p>\n

\u201cThis freedom and liberty of man should be absolute with the one exception-that when the exercise of that liberty infringes upon the liberty of another, the actor invading another\u2019s liberty commits a wrong and to protect individuals from that invasion, society may class such invasion as crime, and provide for punishment.\u201d \u00a0People v. Douglas<\/span>, 202 N.Y.S.2d 160, 162-163.<\/p>\n

\u201cMere legislataive fiat may not take the place of fact in the determination of issues involving life, liberty and property.\u00a0 Manley v. State of Georgia, 279 U.S. 1, 49 S.Ct. 215, 73 L.Ed. 575\u2026The ultimate fact to be established here, is illegal possession of a gun.\u00a0 The fact proven would be merely the legislative presumption.\u00a0 There would be no actual proof\u2026Under our law the corpus delecti must be proved; here it is presumed\u2026The Legislature has no power to declare one guilty of a crime; that is the function of the court after due proof.\u00a0 It is unconstitutional for the Legislature to presume the guilt of the accused.\u00a0 Under this section there is nothing against which to defend, because no crime has been proved.\u201d\u00a0 People v. Pinder<\/span>, 9 N.Y.S.2d 311, 310-311.<\/p>\n

\u201cThe jurisdiction of this Court extends only to live controversies (see Matter of Grand Jury Subpoenas for Locals 17, 135, 257 & 608, 72 N.Y.2d 307, 311, 532 N.Y.S.2d 722, 528 N.E.2d 1195 [1988]; \u2009Matter of Hearst Corp. v. Clyne, 50 N.Y.2d 707, 713-714, 431 N.Y.S.2d 400, 409 N.E.2d 876 [1980]\u2009).\u201d<\/p>\n

\u201cStanding to sue is critical to the proper functioning of the judicial system. \u2002 It is a threshold issue. \u2002 If standing is denied, the pathway to the courthouse is blocked. \u2002 The plaintiff who has standing, however, may cross the threshold and seek judicial redress. It is difficult to draw an exquisitely sharp line separating the worthy litigant from one who would generate a lawsuit to advance someone else\u2019s cause. \u2002 The rules governing standing help courts separate the tangible from the abstract or speculative injury, and the genuinely aggrieved from the judicial dilettante or amorphous claimant.<\/p>\n

\u201cFor generations, New York courts have treated standing as a common-law concept,<\/a> requiring that the litigant have something truly at stake in a genuine controversy.\u201d\u00a0 Saratoga County Chamber of Commerce v. Patak<\/a>i (2003)<\/p>\n

\u201cAn analysis of standing begins with a determination of whether the party seeking relief has sustained an injury (see Society of Plastics Indus. v. County of Suffolk<\/em>, 77 N.Y.2d 761, 772-773, 570 N.Y.S.2d 778, 573 N.E.2d 1043 [1991]).\u201d\u00a0 Mahoney v. Pataki<\/span>, 772 N.E.2d 1118, 1122 (N.Y. 2002).<\/p>\n

\u201cA plaintiff has standing to maintain an action upon alleging an injury in fact that falls within his or her zone of interest.\u201d\u00a0 Silver v. Pataki<\/span>, 755 N.E.2d 842, 847 (N.Y. 2001).<\/p>\n

\u201cAs we have has on occasion to observe in recent years, \u201c[o]nly where there is a clear legislative intent negating review * * * or lack of injury in fact * * * will standing be denied\u2026\u201d\u00a0 Matter of Dist. Atty. of Suffolk County<\/span>, 448 N.E.2d 440, 443 (N.Y. 1983).<\/p>\n

\u201cTo adjudicate upon, and protect the rights and interests of individual citizens, and to that end to construe and apply the laws, is the peculiar province of the judicial department\u2026The judicial power \u201cis the power to hear and determine those matters which affect the life, liberty, or property of the citizens of the state.\u201d\u00a0 (City of Sapulpa v. Land, 101 Okl. 22, 223 P. 640, 644, 35 A.L.R. 872, 878.)\u201d\u00a0 Nash v. Brooks<\/span>, 297 N.Y.S. 853, 855-856.<\/p>\n

Nevada<\/strong>:<\/p>\n

\u201cTo establish standing, Kirkpatrick must show that he suffered an injury in fact, that there is a causal connection between the injury and the conduct complained of, and that it is likely that the injury will be redressed by a favorable decision.[Footnote] Allen v. Wright<\/em><\/a>, 468 U.S. 731, 751\u2026See also Elley v. Stephens<\/em>, 104 Nev. 413, 416, 760 P.2d 768, 770 (1998).\u201d\u00a0 Kirkpatrick v.Dist. Ct<\/span>., 43 P.3d 998, 1005 (Nev. 2002).<\/p>\n

North Dakota<\/strong>:<\/p>\n

\u201cTo have standing to bring action, plaintiff must have suffered some threatened or actual injury resulting from putatively illegal action, asserted harm must not be specialized grievances shared by all or large class of citizens.\u201d\u00a0 Trinity Medical Center v. North Dakota Bd. of Nursing<\/span>, 399 N.W.2d 835.<\/p>\n

\u201cAnd a definition which we consider appropriate and fully sustained is that judicial power is authority vested in some court, officer, or person to hear and determine when the rights of persons or property, or the propriety of doing an act, are the subject-matter of adjudication.\u201d\u00a0 State v. Blaisdell<\/span>, 132 N.W. 769, 773.<\/p>\n

North Carolina<\/strong>:<\/p>\n

\u201cconstitutionally, a plaintiff can only have standing if it satisfies the \u201ccase or controversy\u201d requirement of Article III of the Constitution of the United States.\u00a0 See Linda R.S. v. Richard D<\/a><\/em>., 410 US 614, 617\u2026Under Supreme Court precedent, a plaintiff satisfies the Article III requirement if it meets a three-pronged test: (1) the plaintiff must have suffered \u201cinjury in fact\u2019; (2) there must be a causal connection between the injury and the conduct complained of; and (3) it must be likely that the injury will be redressed by a favorable decision.\u00a0 See Lujan v. Defenders of Wildlife<\/a><\/em>, 504 U.S. 555, 559\u2026The plaintiff bears the burden of establishing these three elements.\u00a0 See Burten v. Central Interstate URWC Comm\u2019n<\/em>., 23 F3d 208, 209 (8th Cir. 1994).\u00a0 Additionally, the Supreme Court as articulated three prudential limits on standing\u2026lastly, the plaintiff must assert his own legal rights and interests, and cannot rest his claim on the legal rights of others [citing Valley Forge v. Americans United<\/em><\/a>, 454 US 464, 474].\u00a0 Transco v. Calco Enterprises<\/span>, 511 S.E.2d 671, 678.<\/p>\n

\u201cA \u201cperson aggrieved\u201d for standing purposes, is one adversly affected in respect to legal rights, or suffering from an infringement or denial of legal rights.\u201d\u00a0 County of Johnston v. City of Wilson<\/span>, 525 S.E.2d 425.<\/p>\n

\u201cStanding is an aspect of subject matter jurisdiction.\u201d\u00a0 Transcontinental Gas Line Corp. v. Calco Enterprises<\/span>, 511 S.E.2d 671.<\/p>\n

Ohio<\/strong>:<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cA plaintiff must show the injury to himself caused by the defendant, the injury having a remedy in law or equity.\u00a0 The injury need not be either large or economic, but it must be palpable.\u00a0 Warth<\/em><\/a> , 422 U.S. at 498\u2026Finally, plaintiff\u2019s injury cannot be merely speculative.\u00a0 A bare allegation that plaintiff fears that some injury will or may occur is insufficient to confer standing.\u00a0 Los Angeles v. Lyons<\/em><\/a>, (1983), 461 U.S. 95, 103\u2026\u201d\u00a0 Tieman v. Univ. of Cincinnati<\/span>, 712 N.E.2d 1258, 1267.<\/p>\n

\u201cThe United States Supreme Court has held that an association has standing on behalf of its members when \u201c(a) its members would otherwise have standing to sue in their own right; (b) the interests it seeks to protect are germane to the organization\u2019s purpose\u2026However, to have standing, the association must establish that its members have suffered an actual injury.\u201d\u00a0 Ohio Contractors Assn. v. Bicking<\/span>, 643 N.E.2d 1088, 1089 (Ohio 1994).<\/p>\n

\u201cJudicial power, on the other hand, is authority to hear and determine where the rights of persons or property, or the propriety of doing an act, are the subject-matter of adjudication and the judicial act involves the exercise of judgmentor discretion.\u00a0 Ward v. Board of Commissioners of Okfuskee County, 114 Okl. 246, 246 P. 376.\u201d\u00a0 Geauga Lake Improvement Ass\u2019n v. Lozier<\/span>, 182 N.E. 489, 491.<\/p>\n

Oklahoma<\/strong>:<\/p>\n

\u201cCorpus delecti<\/strong> means the body or substance of the crime charged.\u00a0 27 Wharton\u2019s Criminal Law<\/em> 142 (14th ed. 1978).\u00a0 It consists of two elements: a criminally prohibited injury and a criminally prohibited act as its cause.\u201d\u00a0 Fontenot v. State<\/span>, 881 P.2d 69, 77 (Okl.Cr. 1994).<\/p>\n

\u201c\u201dCorpus delecti\u201d means body or substance of crime charge, and it consists of criminally prohibited injury and criminally prohibited act as it\u2019s cause.\u201d \u00a0Fontenot v. State, 881 P.2d 69.<\/p>\n

\u201cThe judicial power here conferred by the Constitution is the power to hear and determine those matters which affect the life, liberty, or property of the citizens of the state\u2026\u201d\u00a0 City of Sapulpa v. Land<\/span>, 223 P. 640, 644, 101 Okl 22.<\/p>\n

\u201cAt a minimum standing is composed of three elements.\u00a0 These components are: (1) a legally protected interest which must have been injured in fact-i.e<\/em>., an injury which is actual, concrete and not conjectural in nature, (2) a causal<\/em> nexus between the injury and the complained conduct, and (3) a likelihood as opposed to mere speculation, that the injury will be redressed by a favorable decision<\/em>\u2026Finally, assessment of standing is not a decision on the merits.\u00a0 Rather, it is a determination whether the plaintiff is the proper party to seek adjudication of the asserted issue.\u201d\u00a0 Cities Servies Co. v. Gulf Oil Corp<\/span>., 976 P.2d 545, 547.<\/p>\n

\u201cAt minimum, \u201cstanding\u201d contains three elements: plaintiff have separate injury in fact, there must be causal connection between injury and condict complained of, and it must be likely, as opposed to merely speculative, that injury will be redressed by favorable decision.\u201d\u00a0 Toxic Waste Impact Group, Inc. v. Leavitt<\/span>, 890 P.3d 906.<\/p>\n

\u201cparty must assert his\/her own legal rights and interests and cannot rest claim for relief on the rights or interests of third parties.\u201d\u00a0 Independent School Dist. NO. 9 v. Glass<\/span>, 639 P.2d 1233, 1237.<\/p>\n

\u201cJudicial power is authority to hear and determine, where the rights or persons or property, or the propriety of doing an act, are the subject-matter of adjudication\u2026\u201d\u00a0 Ward v. Board of Com\u2019rs<\/span>, 246 P. 376, 378 [quoting In re Courthouse of Okmulgee County<\/span>, 161 P. 200.<\/p>\n

Oregon<\/strong>:<\/p>\n

“Literally, the phrase means the `body of the crime.’ To establish guilt, it is generally necessary for the prosecution to show that (a) the injury or harm specified in the crime occurred, (b) [that] injury or harm was caused by someone\u2019s criminal activity, and (c) the defendant was the guilty party. To sustain a conviction, the requirement of independent proof of the\u00a0corpus delicti<\/em>demands only that the prosecution have introduced independent evidence tending to show (a) and (b). It is not necessary that the independent proof tend to connect the defendant with the crime.\u201d \u00a0State v. Chatelain<\/a><\/span>, 220 P. 3d 41. \u00a0[The court here does try to confuse the two thing, the injury, the element of the crime, with a procedural rule.]<\/p>\n

\u201cStanding is an aspect of justiciability which may not be waived.\u201d\u00a0 Strank v. Public Employees Retirement Board<\/span>, 108 P.3d 1058.<\/p>\n

\u201cA person has standing if resolution of the issues presented will have a practical effect on his or her rights.\u201d\u00a0 Generaux v. Dobyns<\/span>, 134 P.3d 983, 986.<\/p>\n

\u201cAt least in the absence of a statute, a party has standing to assert only its own legal rights.\u201d\u00a0 Estate of Selmar A. Hutchins v. Fargo<\/span>, 72 P.3d 638, 640.<\/p>\n

\u201c[r]egardless of what the legislature provides regarding the standing of litigants to obtain judicial relief, the courts always<\/em> must determine that the constitutional requirements of justiciability are satisified. [citation omitted] Specifically, we reasoned that (1) the party that invokes the jurisdiction of the court has the \u201cobligation to establish the justiciability of the claim\u2026(2) to establish that the claim is justiciable, the party \u201cmust demonstrate that a decision in this\u00a0case will have a practical effect on its rights.\u201d\u00a0 Barton v. City of Lebanon<\/span>, 88 P.3d 323, 326.<\/p>\n

Pennsylvania<\/strong>:<\/p>\n

\u201cThe \u201ccorpus delecti<\/em> consists of the occurrence of a loss or injury resulting from some person\u2019s criminal conduct.\u201d\u00a0 Commonwealth v. McMullen<\/em>, 545 Pa. 361, 681 A.2d 717, 721 (1996).\u00a0 The corpus delecti<\/em> rules requires the Commonwealth to present evidence that: (1) a loss has occurred; and (2) the loss occurred as a result of a criminal agency.\u00a0 Commonwealth v. May<\/em>, 451 Pa. 31, 301 A.2d 368, 369 (1973).\u201d\u00a0 Commonwealth v. Taylor<\/span>, 831 A.2d 587, 591 (Pa. 2003).<\/p>\n

\u201cIt has long been fundamental to the criminal jurisprudence of this Commonwealth that a necessary predicate to any conviction if proof of the corpus delecti, i.e., the occurrence of any injury or loss and someone\u2019s criminality as the source of this injury or loss.\u00a0 See Commonwealth v. Burns, 490 Pa. 619, 627, 187 A.2d 552, 556-557 (1963); Commonwealth v. Turza, 340 Pa. 128, 133, 16 A.2d 401, 404 (1940).\u201d\u00a0 Commonwealth v. Maybee<\/span>, 239 A.2d 332, 333.<\/p>\n

\u201cThe two elements of \u201ccorpus delecti\u201d are that loss or injury has occurred and that loss or injury occurred through criminal agency; identity of party responsible for act is not element of corpus delecti.\u201d\u00a0 Com. v. Rieland<\/span>, 471 A.2d 490, 491.<\/p>\n

\u201c\u201cCorpus delecti\u201d consists of occurrence of injury or loss consistent with commission of crime by someone.\u201d\u00a0 Com. v. Daniels<\/span>, 422 A.2d 196, 199.<\/p>\n

\u201c\u201cCorpus delecti,\u201d meaning the body of the crime, consists of an occurrence of a specified type of loss or injury and someone\u2019s criminal activity as a source thereof.\u201d\u00a0 Com. v. Ware<\/span>, 329 A.2d 258, 274, 459 Pa. 334.
\n\u201cThe corpus delecti is established upon evidence of (1) the occurence of the specific\u00a0 kind of injury or loss; and,\u00a0(2) someone\u2019s criminality as\u00a0the source of loss.\u201d\u00a0 Com. Kasunic<\/span>, 620 A.2d 525, 529.<\/p>\n

\u201cPennsylvania appellate courts have repeatedly held that corpus delecti consists of the occurrence of injury or loss consistent with commission of a crime by\u00a0someone.\u201d\u00a0 Commonwealth v.\u00a0Daniels<\/span>, 422\u00a0A.2d 196, 199.<\/p>\n

\u201cIt is a well-settled principal of law that a crime is an offense against the sovereignty, a wrong which the government deems injurious not only to the victim but to the public at large, and which it punishes through a judicial proceeding in the Commonwealth\u2019s name.\u00a0 21 Am.Jur.2d 61, pp. 115-116.\u00a0 Though the same wrongful act may consititute both a crime and a tort, the tort is a private injury which is to be pursued by the injured party.\u00a0 Id<\/em>., at [section] 2, p. 116.\u00a0 Criminal prosecutions are not to settle private grievances but are to rectify the injury done to the Commonwealth.\u201d\u00a0 Com. v. Malloy<\/span>, 450 A.2d 689, 691.<\/p>\n

\u201cThe requirement of standing arises from the principal that judicial intervention is appropriate only when the underlying controversy is real and concrete.\u201d\u00a0 Pittsburg Palisades Park, LLC v. Com<\/span>., 888 A.2d 655.<\/p>\n

\u201cFor standing purposes, a \u201cdirect interest\u201d in the litigation requires a showing that the matter complained of caused harm to the party\u2019s interest\u2026for standing purposes, an \u201cimmediate interest\u201d in the outcome of the litigation involves the nature of the causal connection between the action complained of and the injury to the party challenging it.\u201d\u00a0 In re Hickson<\/span>, 821 A.2d 1238.<\/p>\n

\u201cStanding is not conferred via a party\u2019s relationship to the proceedings, but is conferred by a direct connection to a substantive injury, and by a causal connection between the action complained of and the injury to the person challenging it.\u201d\u00a0 Com v. J.H<\/span>., 759 A.2d 1269.<\/p>\n

Rhode Island<\/strong>:<\/p>\n

\u201cBefore it may obtain\u00a0a conviction for a\u00a0criminal offense, the state must prove corpus delecti beyond a reasonable doubt.\u00a0 In re Pereira<\/em>, 111 R.I. 712, 714, 306 A.2d 821, 823 (1973); State v. Maloney<\/em>, 111 R.I. 133, 138 n.1, 300 A.2d 259, 262 n.1 (1973).\u00a0 The corpus delecti comprises two elements: a penally proscribed act or injury and the unlawfullness of some person in causing the injury.\u201d\u00a0 State v. Halstead<\/span>, 414 A.2d 1138, 1143\u00a0(R.I. 1980).<\/p>\n

\u201cTo have standing, the plaintiff must allege to the court\u2019s satisfaction that the challenged action has caused him injury in fact, economic or otherwise.\u201d\u00a0 McKenna v. Williams<\/span>, 874 A.2d 217.<\/p>\n

\u201cStanding is not determined by whether injury caused by challenged action is substantial or insubstantial, but only whether there is some injury as opposed to no injury.\u201d\u00a0 Weybosset Hill Investments, LLC v. Rossi<\/span>, 857 A.2d 231.<\/p>\n

\u201cBy definition, a justiciable controversy must contain a plaintiff who has standing to pursue the action; that is to say, a plaintiff who has suffered \u201cinjury in fact\u2026Injury in fact maybe characterized as \u201can invasion of a legally protected interest which is (a) concrete and particularized * * * and (b) actual or immenent, not \u2018conjectural\u2019 or \u2018hypothetical.\u2019\u201d\u00a0 Meyer v. City of Newport<\/span>, 844 A.2d 148, 151 (R.I. 2004).<\/p>\n

South Carolina<\/strong>:<\/p>\n

\u201cin order to authorize a conviction, the state must prove these [corpus delecti] elements beyond a reasonable doubt\u2026\u201d\u00a0State v. Thomas<\/span>, 73 S.E.2d 722, 723.<\/p>\n

\u201cBefore any action can be maintained, a justiciable controversy must be present\u2026(A justiciable controversy exists when a concrete issue is presented, there is a definite assertion of legal rights and a positive legal duty which is denied by the adverse party.\u201d)\u2026A plaintiff must have standing to institute an action.\u00a0 Joytime Distrbs. & Amusement Co., Inc. v. State<\/em>, 338 S.C. 634, 639, 528 S.E.2d 647, 649.\u201d\u00a0 Sloan v. Greenville County<\/span>, 590 S.E.2d 338, 346, 347.<\/p>\n

\u201c\u201dA Court of law can know no other persons as parties, than those whose rights are made to appear by the record\u2026\u201d\u00a0 M\u2019Elwee v. House<\/em>, 17 S.C.L. (1 Bail.) 108, 109 (1828).\u201d\u00a0\u00a0Nelson v. QHG of South Carolina Inc.<\/span>, 580 S.E.2d 171, 178 (2003).<\/p>\n

South Dakota<\/strong>:<\/p>\n

\u201cThe corpus delecti rule requires that the corpus delecti or the body or substance of the crime charged be proved independent from the accused\u2019s extrajudicial confession or admissions.\u00a0 The corpus delecti of a crime consists of two elements: (1) the fact of the injury or loss or harm, and (2) the existence of a criminal agency as its cause. [citing] People v Jennings, 53 Cal 3d 334, 279 Cal Rptr 780, 807 P2d 1009, 92 CDOS 2576, 91 Daily Journal DAR 4222, reh den. cert den (US) 116 L Ed 2d 464, 112 S Ct 443\u2026People v Pensinger, 52 Cal 3d 1210, 278 Cal Rptr 640, 805 P2d 899, 91 CDOS 1514, 91 Daily Journal DAR 2504, mod 53 Cal 3d 729a, 91 Daily Journal DAR 4745 and stay gr (Cal) 1991 Cal LEXIS 3318 and reh den. cert den (US) 116 L Ed 2d 290, 112 S Ct 351, 91 Daily Journal DAR 12909, reh den (US) 116 L Ed 2d 821, 112 S Ct 923; State v Pullos, 76 Idaho 369, 283 P2d 590; People v Friedland (1st Dist) 202 Ill App 3d 1094, 148 Ill Dec 415, 560 NE2d 1012; Brown v State, 239 Ind 184, 154 NE2d 720, cert den 361 US 936, 4 L Ed 2d 360, 80 S Ct 375; Joseph v State, 236 Ind 529, 141 NE2d 109, 69 ALR2d 824, cert dism 359 US 117, 3 L Ed 2d 673, 79 S Ct 720; People v Aiken, 66 Mich 460, 33 NW 821; People v Gould, 156 Mich App 413, 402 NW2d 27; State v Simler, 350 Mo 646, 167 SW2d 376; State v Hill, 47 NJ 490, 221 A2d 725; State v Robinson (App. Scioto Co) 83 Ohio L Abs 259, 168 NE2d 328; State v Brown, 103 SC 437, 88 SE 21\u2026there must be sufficient proof of both elements of the corpus delecti beyond a reasonable doubt.\u201d\u00a0 29A American Jurisprudence Second Ed<\/span>., Evidence \u00a7 1476.<\/p>\n

\u201cGenerally, for a litigant to have standing to bring an action before the court, litigant must show that he personally as suffered some actual or threatened injury as a result of putatively illegal conduct of defendant.\u201d\u00a0 Parsons v. South Dakota Lottery Com\u2019n<\/span>., 504 N.W.2d 593, 595.<\/p>\n

\u201c\u2018Generally, for a litigant to have standing to bring an action before the court, litigant must show that he personally as suffered some actual or threatened injury as a result of putatively illegal conduct of defendant.\u2019\u201d\u00a0 Parsons v. South Dakota Lottery Commissioner<\/em>., 504 N.W.2d 593, 595 (S.D. 1993) (quoting Gladstone, Realtors v. Bellwood<\/em>, 441 U.S. 91, 99\u2026\u201d\u00a0 Mahan v. Avera St. Luke\u2019s<\/span>, 621 N.W.2d 150, 154 (S.D. 2001).<\/p>\n

Tennessee<\/strong>:<\/p>\n

\u201cIn order to establish the corpus delecti of\u00a0a crime, the State must establish beyond a reasonable\u00a0doubt (1) that a certain result has been produced and (2) that someone is criminally responsible for the act.\u00a0 State v. Jones<\/em>, 15 S.W.3d 880, 890-891.\u201d\u00a0 State v. Ellis<\/span>, 89 S.W.3d 584, 600.<\/p>\n

\u201cCorpus delecti of crime requires showing that certain result has been produced and that result was created through criminal agency.\u201d\u00a0 State v. Ervin<\/span>, 731 S.W.2d 70.<\/p>\n

\u201cFirst we must address the issue of standing, a judge-made doctrine based on the idea that \u2018[a] court may and properly should refuse to entertain an action at the instance of one who rights have not been involved or infringed.\u2019 59 AmJur.2d Parties \u00a7 30 (1987).\u00a0 In state law it parallels the constitutional restriction on federal court jurisdiction to \u201ccases and controversies.\u201d U.S. Const. Art. 3 \u00a7 2.\u00a0 It has been said that no case or controversy is presented where the plaintiff lacks standing to sue.\u00a0 Gilligan v. Morgan<\/em>, 413 U.S. 1\u2026\u201cIn determining whether the plaintiff has a personal stake sufficient to confer standing, the focus should be on whether the complaining party has alleged an injury in fact, economic or otherwise\u2026\u201d\u00a0 Mayhew v. Wilder<\/span>, 46 S.W.3rd 760, 767.<\/p>\n

\u201cIn order to establish standing, a party must demonstrate three essential elements.\u00a0 Metropolitan Air Research Testing Auth. Inc., v. Metropolitan Gov\u2019t of Nashville and Durston County<\/em>, 842 S.W.2d 611, 615\u2026First, the party must demonstrate that it has suffered an injury which is \u2018distinct and palpable,\u2019\u2026and not conjectural or hypothetical\u2026Second, the party must establish a causal connection between the injury and the conduct of which he complains\u2026Third, it must be likely that a favorable decision will redress the injury\u2026These elements are indispensable to the plaintiff\u2019s case, and must be supported by the same degree of evidence at each stage of litigation as other matters on which plaintiff bears the burden of proof.\u00a0 Lujan<\/em><\/a>, 504 U.S. at 560\u2026\u201d\u00a0 Petty v. Daimler\/Chrysler Corp<\/span>., 91 S.W.3d 765.<\/p>\n

\u201cTo establish one\u2019s\u00a0standing to bring an action, \u201ca party must demonstrate (1) that it has sustained a distinct and palpable injury, (2) that the injury was caused by the challenged conduct, and (3) that the injury is apt to be redressed by a remedy the court is prepared to give.\u201d\u00a0 City of Chattanooga v. Davis<\/span>, 54 S.W.3d 248, 280 (Tenn. 2001).\u00a0 [By the way, this is a criminal case, Marc Stevens]<\/p>\n

Texas<\/strong>:<\/p>\n

\u201cWigmore explains the American concept of the corpus delecti<\/em> rule thus:<\/p>\n

[Every crime] reveals three component parts, first<\/em>, the occurrence<\/em>\u00a0 of the specific kind of injury or loss (as in homicide, a person deceased; in arson, a house burnt; in larceny, property missing); secondly<\/em>, somebody\u2019s criminality (in contrast, e.g., to accident) as the\u00a0source of the loss,\u2013these two together involving the commission of a crime by somebody<\/em>; and thirdly<\/em>, the accused\u2019s identity<\/em> as the doer of the crime.<\/p>\n

In most American jurisdictions, including Texas, the corpus delecti<\/em> rules requires some corroboration of the first two elements-an injury or loss and a criminal agent\u2026\u201d\u00a0 Salazar v. State<\/span>, 86 S.W.3d 640,\u00a0645.<\/p>\n

\u201cIt is too elementary that injury must be plead and proved before a cause of action arises to require the citation of authorities.\u201d\u00a0 Whitesboro Nat. Bank v. Wells<\/span>, 182 S.W.2d 516, 518.<\/p>\n

\u201cIt is axiomatic that standing is the first prerequisite to maintaining a suit.\u00a0 Hunt v. Bass<\/em>, 664 S.W.2d 323, 324\u2026Persons have standing to sue if they can show that (1) they have sustained some direct injury as a result of a wrongful act; (2) there is a direct relationship between their alleged injury and the claim sought to be adjudicated; (3) they have a personal stake in the controversy; (4) the challenged action as caused them an injury in fact, whether economic or otherwise\u2026Because standing is a jurisdictional requirement, it may be addressed for the first time on appeal.\u201d\u00a0 Sierra Club v. Cedar Point Oil Co<\/span>., 73 F3d 546, 555\u2026\u201d<\/p>\n

\u201cThe Supreme Court held that because the named plaintiff was unable to allege and show that he personally had been injured by the defendant\u2019s actions, his lack of individual standing precluded the trial court\u2019s exercise of subject matter jurisdiction\u2026The court explained that [o]ur state constitution contemplates, that plaintiffs seeking redress in the courts must first demonstrate standing.\u00a0 Because the Texas constitution requires the presence of a proper party to raise issues before the court, standing is a threshold inquiry regardless of whether the plaintiff brings an individual or class action.\u201d\u00a0 Polaris Industries, Inc. v. McDonald<\/span>, 119 S.W.3d\u00a0\u00a0 331, 338, 339.<\/p>\n

\u201cA \u201ccause of action\u201d constists of a plaintiff\u2019s primary right and the defendant\u2019s act or omission which violates that right. Stone Fort Nat. Bank of Nacogdoches v. Forbes<\/em>, 126 Tex. 568, 91 S.W.2d 674, 676 (1936); Martinez v. Goodyear Tire & Rubber Co<\/em>., 651 S.W.2d 18, 19\u2026Moreover, a \u201ccause of action\u201d comprises every fact which is necessary for a plaintiff to prove in order to obtain judgment.\u201d\u00a0 Krchnak v. Fulton<\/span>, 759 S.W.2d 524, 526.<\/p>\n

\u201cThe requirement in this State that a plaintiff have standing to assert a claim derives from the Texas Constitution\u2019s separation of powers among the departments of government, which denies the judiciary authority to decide issues in the abstract, and from the Open Courts provision, which provides court access only to a \u201cperson for an injury done him\u201d. A court has no jurisdiction over a claim made by a plaintiff without standing to assert it.\u00a0 For standing, a plaintiff must be personally aggrieved; his alleged injury must be concrete and particularized, actual or imminent, not hypothetical.\u00a0 A plaintiff does not lack standing simply because he cannot prevail on the merits of his claim; he lacks standing because his claim of injury is too slight for a court to afford redress.\u201d \u00a0 Daimler Chrysler Corporation, v. Bill Inman et al<\/span><\/a>, NO. 03-1189, Texas Supreme Court, 2008.<\/p>\n

\u201cThe dissent argues that standing requires only, one, a real controversy that, two, will be determined.\u00a0 Those are requirements for standing, but so is concrete injury, because if injury is only hypothetical, there is no real controversy.\u201d \u00a0 Daimler Chrysler Corporation, v. Bill Inman et a<\/span><\/a>l, NO. 03-1189, Texas Supreme Court, 2008.<\/p>\n

Utah<\/strong>:<\/p>\n

\u201cGenerally,\u00a0 \u201c\u2018[t]o establish guilt\u2019 \u201d in a criminal case, \u201cthe prosecution [must] show that [1] the injury or harm specified in the crime occurred, [2] this injury or harm was caused by someone\u2019s criminal activity, and [3] the defendant was the [perpetrator].\u2019 \u201d State v. Talbot<\/em>, 665 P.2d 1274, 1276 (Utah 1983) (citation omitted).\u00a0 The corpus delecti, or body of the crime, involves only the first two elements, however.\u201d\u00a0 State v. Mauchley<\/span>, 67 P.3d 477, 482 (Utah 2003).<\/p>\n

\u201c\u201dCorpus delecti rule\u201d states that person may not be convicted of crime if no independent evidence, outside defendant\u2019s own statement, exists; to satisfy doctrine, state must produce independent evidence that injury or harm specified in crime occurred and that injury or harm was caused by someone\u2019s criminal activity.\u201d\u00a0 State v. Archuleta<\/span>, 850 P.2d 1232, 1241.<\/p>\n

\u201cMr. Justice Cooley, in Post v. Campau, 42 Mich. 96, 3 N.W. 272, said: \u201cThe elements of a cause of action are, first, a breach of duty owing by one person to another; and second, a damage resulting to the other from the breach.\u201d\u00a0 In Foot v. Edwards, 3 Blatchf. 313, Fed. Cas. No. 4,908, Mr. Justice Ingersoll said: \u201cThe commission of an act by the defendant, and damage to the plaintiff in consequence thereof, must unite, to give a good cause of action.\u00a0 No one of these facts by itself is a cause of action against the defendant.\u201d\u00a0 In City of North Vernon v. Vogler, 103 Ind. 319, 2 N.E. 821, it is said: \u201cIn every valid cause of action two elements must be present-the injury and the damage.\u00a0 The one is the legal wrong which is to be redressed; the other, the scale or measure of the recovery.\u201d\u00a0 Fields v. Daisy Gold Min. Co<\/span>., 73 P. 521, 522, 26 Utah, 373.<\/p>\n

\u201cAn issue is \u201cripe\u201d for adjudication only when it has sharpened into an actual or imminent clash of legal rights.\u201d\u00a0 Pett v. Autoliv ASP, Inc<\/span>., 106 P.3d 705.<\/p>\n

\u201cIn general, standing is available only to a person who has sustained some injury to her personal, legal, or property rights.\u201d\u00a0 In re E.H<\/span>., 137 P.3d 809, 819.<\/p>\n

\u201cTo satisfy the \u201cbasic requirements\u201d of the traditional standing test, \u201ca party must alleged that he or she has suffered or will immediately suffer an injury that is fairly traceable to the conduct at issue such that a favorable decision is likely to redress the injury.\u201d\u00a0 Chen v. Stewart<\/span>, 123 P.3d 416, 437 (Utah 2005).<\/p>\n

\u201cIn order\u00a0 to have standing, a plaintiff must be able to show that he has suffered some distinct and polpable injury that gives him a personal stake in the outcome of the legal dispute.\u201d\u00a0 Council of Holliday City v. Larkin<\/span>, 89 P.3d 164.<\/p>\n

\u201cUnder principals of standing, a party may generally assert only his or her own legal rights, and cannot raise the claims of third parties who are not before the court.\u201d\u00a0 Provo City Corp. v. Thompson<\/span>, 86 P.3d 735.<\/p>\n

\u201cThe requirement that a plaintiff demonstrate particularized injury is the traditional test for standing.\u201d\u00a0 Washington County Water Conservancy Dist. v. Morgan<\/span>, 82 P.3d 1125.<\/p>\n

Vermont<\/strong>:<\/p>\n

\u201ccourts must look behind names that symbolize the parties to determine whether a justiciable case or controversy is presented.\u201d\u00a0 State v. CNA Ins. Companies<\/span>, 779 A.2d 662 (Vt 2001) [quoting United States v. Interstate Commerce Commission<\/span><\/a>, 337 U.S. 426 (1949)].<\/p>\n

\u201cWe examined, accordingly, the substance of the plaintiff\u2019s constitutional and civil rights claims, concluding that they implicated no legally protected right under the constitution.\u00a0 We affirmed, therefore, the trial court\u2019s dismissal both on lack of standing and on the merits.\u201d\u00a0 Daye v. State<\/span>, 769 A.2d 630, 633 (Vt. 2000).<\/p>\n

\u201cTo satisfy the standing requirement, a plaintiff must show (1) injury-in-fact, (2) causation, and (3) redressibility; thus, the plaintiff must allege a personal injury traceable to the defendant\u2019s conduct that the court can remedy\u2026\u201d\u00a0 Brigham v. State<\/span>, 889 A.2d 715.<\/p>\n

\u201cThe main standing requirement is that the plaintiff show threat of injury to a protected interest.\u201d\u00a0 Blum v. Friedman<\/span>, 782 A.2d 1204, 1207.<\/p>\n

\u201cthe phrase \u201cjudicial power\u201d implies the construction of laws and the adjudication of legal rights.\u201d\u00a0 Gould v. Parker<\/span>, 42 A.2d 416, 418.<\/p>\n

Virginia<\/strong>:<\/p>\n

\u201cBut basic concepts of our criminal jurispridence cannot be treated lightly in a zealous, and albeit a commendable, desire to reduce crime and convict culpits.\u00a0 Among these safeguards is the requirement that the State must establish the existence of the corpus delecti<\/em>\u00a0and prove its case beyond a reasonable doubt by admissible evidence.\u201d\u00a0 Pepoon v. Commonwealth<\/span>, 66 S.E.2d 854, 859.<\/p>\n

\u201cPoint of standing is to ensure that person who asserts a position has substantial legal right to do so and that his rights will be affected by disposition of the case.\u201d\u00a0 Cupp v. Board of Supr\u2019s of Fairfax County<\/span>, 318 S.E.2d 407.<\/p>\n

\u201cThe purpose of requiring standing is to make certain that a party who asserts a particular position has the legal right to do so and that his rights will be affected by the disposition of the case.\u201d\u00a0 Goldman v. Landslide<\/span>, 552 S.E.2d 67, 71 (Va. 2001).<\/p>\n

Washington<\/strong>:<\/p>\n

\u201cAll political power is inherent in the people, and governments derive their just powers from the consent of the governed, and are established to protect and maintain individual rights.\u201d Washington constitution article I \u00a7 1<\/a>.<\/p>\n

\u201cCorpus delecti is usually proven by following two elements: injury or loss, and someone\u2019s criminal act as cause thereof\u2026\u201d\u00a0 State v. Smith<\/span>, 801 P.2d 975, 115 Wash.2d 775.<\/p>\n

\u201c\u201cCorpus delecti\u201d consists of injury or loss and someone\u2019s criminal act which caused it.\u201d\u00a0 State v. Espinoza<\/span>, 774 P.2d 1177, 1182, 112 Wash.2d 819.<\/p>\n

\u201cCorpus delecti usually consists of two elements: (1) \u00a0an injury or loss\u2026 and (2)somone\u2019s criminal act as the cause thereof.\u201d\u00a0 City of Bremerton v. Corbett<\/span>, 773 P.2d 1135, 138,\u00a0106 Wash.2d 569.
\n\u201cIn order to establish the corpus delecti<\/em> of any crime there must be shown to have existed a certain act or result forming the basis of the criminal charge and the existence of a criminal agency as the cause of such act or result.\u201d\u00a0 State v. Goranson<\/span>, 408 P.2d 7, 9, [quoting State v. Meyer, 37 Wash.2d 759, 763, 226 P.2d 204 (1951)].<\/p>\n

\u201cThe term corpus delecti means the body of the crime, or, to state it differently, that the crime charged has actually been committed by some one.\u00a0 It is made up of two elements: first, that a certain result has been produced, as that a human being has died; and second, that some one is criminally responsible for the result.\u00a0 State v. Henderson, Or., 184 P.2d 392.\u201d\u00a0 State v. Jeannet<\/span>, 192 P.2d 983, 984.<\/p>\n

\u201cThe doctrine of standing prohibits a litigant from raising another\u2019s legal rights.\u00a0 Allen v. Wright<\/em>, 468 US 737, 750-751.\u201d\u00a0 Huberman v. Public Power Supply System<\/span>, 744 P.2d 1032, 1055.<\/p>\n

\u201cIf a plaintiff lacks standing to bring a suit, courts lack jurisdiction to consider it.\u201d\u00a0 High Tide Seafoods v. State<\/span>, 725 P2d 411, 415 (Wash. 1986).<\/p>\n

\u201cInjury in fact element of standing is satisfied when a plaintiff alleged the challenged action will cause a specific and personal harm.\u201d\u00a0 Kucera v. State, Dept. of Transp<\/span>., 995 P.2d 63.<\/p>\n

\u201cDoctrine of standing prohibits the litigant from raising another\u2019s legal rights.\u201d\u00a0 Haberman v. Washington Public Power Supply System<\/span>, 744 P.2d 1032.<\/p>\n

Washington DC<\/strong>:<\/p>\n

\u201cIt is an elementary matter of jurisprudence that an individual must have standing in order to maintain an action.\u00a0 Basic to standing is the requirement that the individual be injured in fact by the conduct of the other party.\u00a0 See, e.g., Lee v. District of Columbia Board of Appeals and Review<\/em>, 423 A.2d 210 (D.C. 1980).\u00a0 We find no injury to Burleson flowing from United\u2019s conduct.\u00a0 Burelson is without standing to maintain his action against United.\u201d\u00a0 Burelson v. United Title & Escrow Co. Inc<\/span>., 484 A.2d 535, 537.<\/p>\n

West Virginia<\/strong>:<\/p>\n

\u201cIt is well-recognized, and we now so hold, that [s]tanding\u2026is comprised of three\u00a0 elements; first, the party\u2026[attempting to establish standing] must have suffered an \u201cinjury-in-fact\u201d \u2013 an invasion of a legally protected interest which is (a) concrete and particularized and (b) actual or imminent and not conjectural or hypothetical.\u00a0 Second, there must be a causal connection [between] the injury and the conduct forming the basis of the suit.\u00a0 Third, it must be likely that the injury will be redressed through a favorable decision of the court.\u201d\u00a0 Findley v. State Farm Mut. Auto. Ins. Co<\/span>., 576 S.E.2d 807,821.<\/p>\n

\u201c\u201dGenerally, standing is defined as \u2018[a] party\u2019s right to make a legal claim or seek judicial enforcement of a duty or right.\u201d” Findley v. State Farm Mut. Auto. Ins. Co<\/em>.,\u00a0 213 W.Va. 80, 94, 576 S.E.2d 807,821 (2002)\u2026One aspect of standing is that one generally lacks standing to assert the rights of another.\u201d\u00a0 State ex rel. Lueng v. Sanders<\/span>, 584 S.E.2d 203, 212 (W.Va. 2003).<\/p>\n

Wisconsin<\/strong>:<\/p>\n

\u201cAll men are born equally free and independent, and have certain inherent rights; among these are life, liberty, and the pursuit of\u00a0 happiness; to\u00a0 secure these\u00a0 rights, governments are instituted\u00a0 among men,\u00a0 deriving their\u00a0 just powers from the consent of the governed.\u201d\u00a0 Wisconsin constitution article I \u00a7 1<\/a> .<\/p>\n

While the corpus delecti must be proved beyond all reasonable doubt, yet it may be established by circumstantial as well as direct evidence.\u00a0 Schwantes v. State<\/span>, 106 N.W. 237, 127 Wis. 169.<\/p>\n

\u201cLaw of standing is to be construed liberally; where an actual injury is demonstrated, even a trifling interest may be sufficient to confer standing.\u201d\u00a0 Milwaukee Brewers Baseball Club v. Wisconsin Dept. of Health and Social Services<\/span>, 387 N.W.2d 245.<\/p>\n

\u201cWisconsin employs a two-step standing analysis.\u00a0 The analysis requries the court to determine (1) whether the plaintiff has suffered a threatened or actual injury, and (2) whether the interest asserted is recognized by law.\u201d\u00a0 Schwittay v. Sheboygan Falls Mut. Ins. Co.<\/span>, 630 N.W.2d 772, 776.<\/p>\n

Wyoming<\/strong>:<\/p>\n

\u201cA party has standing \u201conly if he has a tangible and legally protectable interest at stake in the litigation; his interest must be injured or threatened with injury\u2026\u201d\u00a0 Billings v. Wyoming Bd. of Outfitters<\/span>, 88 P.3d 455, 479 (Wyo. 2004).<\/p>\n

\u201cthe duty of this court, as of every judicial tribunal<\/em><\/strong>, is limited to determining rights<\/em><\/strong> of persons or of property, which are actually controverted in the particular case before it.\u201d\u00a0 Tyler v. Judges of the Court of Registration<\/span>, 179 U.S. 405, 21 SCt. 206, 208.<\/p>\n

In addition to the federal cases cited above:<\/strong><\/p>\n

\u201cThe plaintiff must show that he himself is injured by the challenged action of the defendant.\u00a0 The injury may be indirect, see United States v. SCRAP, 412 U.S. 669, 688, 93 S.Ct. 2405, 2416, 37 L.Ed.2d 254 (1973), but the complaint must indicate that the injury is indeed fairly traceable to the defendant\u2019s acts or omissions.\u00a0 Simon v. Eastern Ky. Welfare Rights Org., 426 U.S. 26, 41-42, 96 S.Ct. 1917, 1925-1926, 48 L.Ed.2d 450 (1976); O\u2019Shea v. Littelton, 414 U.S. 488, 498, 94 S.Ct. 669, 677, 38 L.Ed2d 674 (1974); Linda R. S. v. Richard D., 410 U.S. 614, 617, 93 S.Ct. 1146, 1148, 35 L.Ed.2d 536 (1973).\u201d\u00a0 Vil. of Arlington Hts. v. Metro Housing Dev<\/span><\/a>., 429 U.S. 252, 262.<\/p>\n

\u201cComponent parts of every crime are the occurrence of a specific kind of injury or loss, somebody\u2019s criminality as source of the loss, and the accused\u2019s identity as the doer of the crime; the first two elements are what constitutes the concept of \u201ccorpus delecti.\u201d\u00a0 U.S. v. Shunk<\/span>, 881 F.2d 917, 919 C.A. 10 (Utah).<\/p>\n

\u201cMost American courts take the view that the phrase \u201ccorpus delecti\u201d<\/em> includes first, the fact of an injury or a loss and secondly, the fact of somebody\u2019s criminality (in contrast e.g.<\/em> to accident) as the cause of the injury or loss.\u201d\u00a0 United States. v. Echeles<\/span>, 222 F.2d 144, 155 (C.A. 10th Cir Ill.).<\/p>\n

\u201cOn the contrary, we share the view most American courts that the\u00a0phrase \u201ccorpus delecti\u201d<\/em>includes but two elements: first, the fact of an injury or loss; and secondly, the fact of somebody\u2019s <\/em>criminality as the cause of the injury or loss.\u201d\u00a0 French v. United States<\/span>, 232 F.2d 736 738, (C.A. 5th Cir. La.).<\/p>\n

\u201cTo paraphrase one of the leading cases: \u2018Most American courts take the view that the phrase \u201ccorpus delecti\u201d<\/em> includes first, the fact of an injury or a loss and secondly, the fact of somebody\u2019s criminality (in contrast e.g.<\/em> to accident) as the cause of the injury or loss\u2026\u2019\u00a0 Manning v. United States, 10 Cir., 215 F.2d 945, at page 947; United States v. Echeles, 7 Cir., 1955, 222 F.2d 144; United States v. Di Orio, 3 Cir., 1940, 150 F.2d 938; George v. United States, 1942, 75 U.S.App.D.C. 197, 125 F.2d 559, 563; United States v. Markman, 2 Cir., 1952, 193 F.2d 574, 576.\u201d\u00a0 Sandez v. United States<\/span>, 239 F.2d 239, 244 (C.A. 9th Cir. Calif.).<\/p>\n","protected":false},"excerpt":{"rendered":"

MarcStevens.net | Standing is the same wherever you go, the important elements are (1) the violation of a right, a legal injury; and (2) damage.\u00a0 The only \u201cauthority\u201d one should need is to look at the Declaration of Independence for the only reason for the establishment of an American government: \u201cWe hold these truths to […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[294],"tags":[391,134,118,36,147],"class_list":["post-5567","post","type-post","status-publish","format-standard","hentry","category-article","tag-adventures-in-legal-land","tag-coercive-monopoly","tag-corpus-delicti","tag-police-state","tag-no-state-project"],"_links":{"self":[{"href":"https:\/\/oooorgle.com\/BeyondTheCorral\/wp-json\/wp\/v2\/posts\/5567","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/oooorgle.com\/BeyondTheCorral\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/oooorgle.com\/BeyondTheCorral\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/oooorgle.com\/BeyondTheCorral\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/oooorgle.com\/BeyondTheCorral\/wp-json\/wp\/v2\/comments?post=5567"}],"version-history":[{"count":0,"href":"https:\/\/oooorgle.com\/BeyondTheCorral\/wp-json\/wp\/v2\/posts\/5567\/revisions"}],"wp:attachment":[{"href":"https:\/\/oooorgle.com\/BeyondTheCorral\/wp-json\/wp\/v2\/media?parent=5567"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/oooorgle.com\/BeyondTheCorral\/wp-json\/wp\/v2\/categories?post=5567"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/oooorgle.com\/BeyondTheCorral\/wp-json\/wp\/v2\/tags?post=5567"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}