One law expert acknowledged that a "dry bones" case is a real bear to prove. IMO, the only tougher one is a murder with no body. I've heard of only one of these being successful, in New York. However, she's been convicted in "the court of public opinion" and regardless of the legal status, much like OJ, she will not be accepted. She engaged in some dodgy behavior for sure; but the jury is not permitted to solely use that as a basis for conviction. Without cause or time of death, proving murder is very difficult.