No Body, No Problem: Murder Convictions in Missing Persons Cases


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The old Hollywood trope of “no body, no conviction” is usually accurate, but not always true. Generally, it is very difficult to prove the murder of a missing person.

But, between the tenacity of investigators and the legal precedent of the United States v. Scott, plenty of killers are convicted without a body.

In the Scott case, the judge essentially stated that when the prosecution uses enough credible circumstantial evidence, thereby excluding any other rational conclusion, a person can be convicted in the murder of a missing person.

In most homicide cases, the court requires direct evidence in order to convict a murderer. An obvious example of direct evidence would be the discovery of the strangled remains of the victim.

On the other hand, circumstantial evidence requires the jury to rely on inference and, then, connect the dots. So, it’s definitely more difficult to prove a murder relying solely on circumstantial evidence, but as long as the prosecutor provides enough credible dots, the jury can convict.

Here are two high-profile cases where bodies were not recovered, but killers were convicted.

The Chillingworth Murders

In June 1955, Judge Curtis E. Chillingworth and his wife Marjorie were brutally murdered near their Florida beach house. Three men were eventually held accountable for the murders, despite the victims’ bodies never being recovered.

In the early morning hours of June 15, 1955, Floyd “Lucky” Holzapfel and George “Bobby” Lincoln kidnapped the couple at gunpoint. Forced from their home – to a boat that was docked nearby – the couple was bound and gagged. The victims also had to endure having anchors tied around their necks.

The killers sailed away from the coast and threw the couple into the deep ocean waters.

Curtis and Marjorie were never seen again – alive or dead.

Within 12 hours of their murder, the investigation began. And that’s because the judge was a very responsible, punctual man. So, when he didn’t show up at court, colleagues became immediately alarmed.

When the police arrived at the couples’ home, they discovered blood stains on the area leading from the house to the beach.  They also found two rolls of adhesive tape and a smashed porch light.

After analyzing the crime scene, it became apparent that the couple was taken to sea.

Aerial support and dive teams had no luck in locating the bodies. The investigation went stale until police discovered that Holzapfel had been bragging around town that he knew who killed the judge and his wife.

The police eventually got a confession out of him.

Turns out, the brains behind the whole operation was a man named Joseph Alexander Peel – who was also a judge. But a crooked one, who had a long history of being admonished for his behavior by Chillingworth. And when Chillingworth threatened Peel with disbarment due to his unethical behavior, Peel decided that Chillingworth needed to be murdered. That’s when he hired Lincoln and Holzapfel.

After getting a full confession from Holzapfel, the police turned their attention to Lincoln, who was serving prison time on unrelated charges. Lincoln agreed to testify against Peel and Holzapfel in exchange for immunity. This immunity deal forced Holzapfel to plead guilty, with the hope of a reduced sentence.

In order to silence Lincoln, Peel hired two inmates to kill him, but the plot never came to fruition.

The trials didn’t last long. Peel was sentenced to two life sentences, even though the prosecutors asked for the death penalty.  In his old age, he was released from prison due to terminal cancer. Peel died nine days after his release.

Holzapfel got the death penalty, but his sentence was commuted to life imprisonment. Many years later, he eventually died behind bars.

Lincoln completed his prison sentence stemming from an unrelated crime and was eventually released.


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The Abduction and Killing of the Lyon Sisters

On March 25, 1975, pre-teen sisters Katherine and Sheila Lyon, were snatched from a suburban Washington D.C. mall.  Despite the massive investigation (one of the largest in the history of Metro D.C.), the girls were never seen again, and the case went cold for almost 40 years.

The case was resurrected in 2013 when the Montgomery County Police Department began focusing their attention on Lloyd Welch, a convicted sexual predator.

Detectives discovered that Welch had voluntarily involved himself in the initial investigation. It seems, that days after the girls’ disappearance, Welch had approached a security guard at the mall with information. Welch advised the guard that he had witnessed a man interacting with the girls on the day of the abduction.

When the police followed-up with Welch, he admitted that his whole story was a lie, and he was forced to take a polygraph test – which he failed. Yet, Lee was never questioned again, until 38 years later.

In 2013, during the reexamination of the case, Detectives zeroed-in on a 1977 mugshot of Welch. The mugshot had a strong resemblance to an earlier police sketch of man, who witnesses had seen staring inappropriately at the girls during their shopping trip to the mall.

Later that year, police visited Welch in prison, where he was serving time for child molestation. Investigators obviously feared that Welch would be apprehensive to speak with them, but that turned out to be false. Welch loved to talk. And, even though, he professed his innocence, his big mouth and intricate lies provided the police with a great deal of useful information.

As a result of Welch’s prison conversation with police, investigators were led to the doorstep of Henry Parker, who is Welch’s cousin. Parker revealed that, in 1975, he helped Welch burn two 60-70-pound duffle bags, which were covered in red stains and had a smell of ‘death’.

Investigators eventually pulled together enough evidence for Welch to confess to the murders. Then, in September 2017, Welch pled guilty to two counts of first-degree murder relating to the kidnapping and killing of the Lyon sisters. He was swiftly convicted and continues to serve time in prison.

Although the victims’ loved ones never had an opportunity to say good-bye, they did receive some sense of closure when justice was served with the conviction of the killers. Do you know of any cases where a body was never recovered, yet the killer was caught and convicted?




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About jchasenovelist

Published thriller author, criminologist, and blogger.
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