Stephenson v. State
205 Ind. 141, 179 N.E. 633 (1932)

  • Stephenson (and his chauffeur) kidnapped a girl he knew, took her to a hotel, and repeatedly raped and beat her. She was able to get and take some poison in an attempt to end her suffering, shame, and humiliation.
  • Eventually Stephenson released her, but she died.
  • Stephenson was arrested and charged with murder.
  • The Trial Court found Stephenson guilty of second-degree murder. He appealed.
    • Stephenson argued that he didn’t give her the poison, he didn’t even know about it. Therefore there was an intervening human action that insulated him from culpability.
  • The Indiana Supreme Court upheld the conviction.
    • The Indiana Supreme Court found that the girl was under the control of Stephenson.
    • Therefore, the Stephenson’s actions caused the girl to become “distracted and mentally irresponsible” and therefore his actions were causally related to her death. (aka causation)
  • Basically, if you commit a crime and someone commits suicide as a result of that crime, you can be held criminally culpable, but only if your actions caused the person to become ‘irresponsible’.
    • On the other hand, if you cheat someone out of their life savings and they become depressed and commit suicide, you are probably not culpable.
    • One way to read that is to say that if he had let the girl go, and she went home and committed suicide because of what Stephenson had previously done to her, then he would not be culpable. But she took the poison while in his control, potentially to avoid what he might do to her in the future. That’s different.