Natalie Holloway Case

Aruban officials have said previously a murder conviction is possible without a body, but the case requires strong evidence such as a confession, reliable statements and forensic evidence of wrongdoing. Aruba is a Dutch protectorate and as such operates under Dutch law.

. . . A half-century ago, no-cause-of-death and no-body prosecutions were unheard of. That changed when a Los Angeles jury in 1957 did not buy paint salesman L. Ewing Scott's "no body, no crime" defense. He served 21 years of a life sentence for having murdered his wife and confessed a year before his death in 1987.

Since then, such cases have slowly gained more acceptance. Nowadays, they are among the highest-profile cases in the nation. Los Angeles County alone has prosecuted dozens. . . .

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N0-BODY CASES

Here are some examples of prosecution in slayings in which authorities did not recover the bodies:

MARCH 2003 -- A mistrial is declared in the murder case of Bruce Koklich. He is suspected of murdering the late state Sen. Paul Carpenter's daughter, whose body has not been found. A second trial is scheduled to start May 22.

FEBRUARY 2003 -- A Santa Clara County jury convicts Gustavo Covian in the 1998 murder-for-hire slaying of Young Kim, whose body has never been recovered. The victim's wife, who allegedly paid Covian $100,000, and two others are expected to stand trial soon.

JANUARY 2003 -- Authorities in the Philippines arrest Joseph Eli Morrow on suspicion of killing his wife after a violent argument in Menlo Park 11 years earlier. Her body has never been found.

SEPTEMBER 2000 -- Thomas Sax and Tommy Ray Daigle blame a 21-year-old man for the drunken driving arrest of a friend, then beat and strangle him and dump the body in a garbage bin in Florida. Authorities search a landfill for nearly a week in vain. Sax and Daigle are convicted of murder anyway.

JULY 2000 -- A Merced County jury convicts Adolfo Romo Martinez of murdering his companion, Lilia Anguiano of Los Banos. Neighbors saw them talking together shortly before she disappeared; her body has never been found.

2000 -- Sante Kimes and her son, Kenneth Kimes, are convicted in New York for killing their wealthy landlady, whose corpse has never been found.

1999 -- Prominent Delaware lawyer Thomas Capano is sentenced to death for killing his mistress because she wanted to end their secret affair. He dumped her body in the Atlantic Ocean and it was never recovered.

1986 --Richard Crafts bludgeons his wife to death in Connecticut, stores her body in a freezer, dismembers it with a chain saw and runs the frozen pieces through a two-ton wood chipper, scattering the pieces into the Housatonic River. Investigators eventually recover minuscule bits of bone and hair. Though DNA matching was not then available, Crafts is convicted.

1985 -- Dr. Robert Bierenbaum dumps his wife's body in the Atlantic Ocean from a private airplane and it is never recovered. Fifteen years later, a jury -- convinced by a stream of circumstantial evidence -- convicts him.

1982 -- Mark Christopher Crew fleeces his bride out of her life savings, shoots and dismembers her, and dumps body parts off the Dumbarton Bridge across San Francisco Bay. He is eventually sentenced to death.