Knapp v. State

Supreme Court of Indiana · 1907 · Evidence

168 Ind. 153 (1907)

Updated August 22, 2026

Evidencerelevanceself-defenserebuttal evidenceheard rumors of victim's violencecredibilityjury instructionsrequested instructions

Facts

The defendant testified that he killed in self-defense. To show he had reason to fear the deceased, he testified that before the killing he had heard that the deceased, the marshal of Hagerstown, had clubbed and seriously injured an old man who later died. On cross-examination, the defendant said only that he heard this from "some people around Hagerstown" and could not identify who told him. In rebuttal, the State introduced a physician's testimony that the old man died of senility and alcoholism and had no bruises or marks on his body.

Issue

Whether the State could rebut the defendant's testimony that he had heard a story about the deceased's prior violence by proving the underlying story had no factual basis. The case also asked whether the trial court erred in refusing or rephrasing requested jury instructions concerning juror independence and witness intoxication.

Rule

Evidence is relevant and competent if it conduces to the proof of a pertinent hypothesis and tends, even in a slight degree, to elucidate the inquiry or assist in reaching a probably true determination. Thus, when a defendant claims he heard a report of the deceased's prior violent conduct, the State may introduce evidence showing there was no factual basis for the report if that tends to make the defendant's claim less probable. A requested instruction may be refused unless it is correct to its full extent and ought to be given precisely as tendered; general credibility instructions may suffice instead of special instructions on ordinary matters of observation and experience.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

During a homicide trial in Columbus, Ohio, Devin Mercer claims self-defense. To explain why he feared Nolan Price, Devin testifies that before the shooting he had heard around town that Nolan once beat a handcuffed man so badly that the man died, but on cross-examination Devin cannot identify who told him. The prosecution offers a coroner from Dayton to testify that the handcuffed man actually died of pneumonia and had no trauma injuries.

Should the court admit the coroner's testimony?

Explanation. The majority treats relevance as a matter of logical tendency. Evidence is competent if it conduces to a pertinent hypothesis and tends even slightly to assist the inquiry. Where the defendant says he heard a report of the victim's prior violence but cannot identify the source, proof that the event never happened tends to discredit the claim that he really heard such a report. It need not conclusively disprove him.