Jonel H. Guihama v. United States

Whether courts must consider the circumstances under which a confession was obtained—including extensive psychological pressure and coercive interrogation tactics—when determining if that confession is adequately corroborated under Mil. R. Evid. 304(c), in an analysis separate from and independent of the Miranda, 384 U.S. 436 (1966) voluntariness determination; and whether the rule provides constitutionally adequate safeguards against false confessions when courts permit corroboration to rest solely on innocent background facts that would exist regardless of whether any crime occurred, particularly where alleged victims deny any memory of abuse and the only independent evidence consists of routine family interactions?