Stephenson v. State

Stephenson v. State, Supreme Court of Indiana, 179 N.E. 633 (Ind. 1932), is a criminal case involving causation in criminal law, significant for its political and legal consequences.[1] David Curtiss Stephenson, leader of the Ku Klux Klan in Indiana abducted Madge Oberholtzer, injured her, and repeatedly raped her.[1] She ingested poison and later died. Publicity for the case may have reversed ascendency of the Klan nationally.[1] The case is legally significant in that it found "if a defendant engaged in the commission of a felony such as rape... inflicts upon his victim both physical and mental injuries, the natural and probable result of which would render the deceased mentally irresponsible and suicide followed, we think he would be guilty of murder".[1]


  1. Criminal Law Cases and Materials, 7th ed. 2012, John Kaplan, Robert Weisberg, Guyora Binder
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