Knapp v. State

168 Ind. 153, 79 N.E. 1076 (1907).

One-Sentence Takeaway: Evidence of a collateral fact is admissible to prove the controverted fact if a logical and reasonable inference of the existence of the controverted fact can be drawn therefrom.


Defendant was convicted of killing a police officer.  To support his theory of self-defense at trial, Defendant testified that he had heard before the killing that the same police officer had clubbed and seriously injured an old man during an arrest and that old man died shortly afterwards.  However, Defendant did not recall who told him that story.

To refute Defendant’s testimony, the prosecution presented testimony of a physician that the old man had died of senility and alcoholism and that there were no bruises or marks on the old man’s body to suggest any abuse by the police officer.

Defendant objected and argued that the physician’s testimony should not have been admitted into evidence because the relevant question for self-defense was whether Defendant had, in fact, heard the story and therefore reasonably feared the police officer, and not whether the story was true or false.

The Indiana Supreme Court held that the trial court had properly admitted the physician’s testimony into evidence because it “tended to discredit [Defendant], since it showed that somewhere between the fact and the testimony there was a person who was not a truth speaker, and, [Defendant] being unable to point to his informant, it must at least be said that the testimony complained of had a tendency to render his claim as to what he had heard less probable.”

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