Knapp v. State
79 N.E. 1076 (1907)
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Rule of Law:
When a defendant claiming self-defense testifies to having heard a rumor about the victim's violent character, the prosecution may introduce rebuttal evidence to prove the rumor's falsity, as the truth or falsity of the underlying rumor is relevant to assessing the probability that the defendant actually heard it.
Facts:
- The appellant was charged with murdering the town marshal of Hagerstown.
- At trial, the appellant claimed he acted in self-defense.
- To establish his fear of the deceased, the appellant testified that he had previously heard that the marshal had clubbed and seriously injured an old man during an arrest, and that this man died shortly after.
- When asked on cross-examination who told him this story, the appellant stated he could not recall the specific person, only that it was 'Some people around Hagerstown'.
Procedural Posture:
- Appellant was tried for murder in the court of first instance.
- At trial, the State was permitted, over the defense's objection, to introduce rebuttal testimony from a physician.
- The jury returned a verdict convicting the appellant of murder in the first degree.
- Appellant filed a motion for a new trial, which the trial court overruled.
- Appellant appeals the judgment of conviction to this court.
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Issue:
Does a trial court commit reversible error by admitting evidence to prove the falsity of a rumor about the deceased's character, when the defendant, claiming self-defense, testified that he had heard this rumor prior to the killing?
Opinions:
Majority - Gillett, J.
No. A trial court does not commit reversible error by admitting such evidence. While the direct question is whether the appellant heard the story, evidence showing the story had no basis in fact is relevant because it tends to make it less probable that his testimony about hearing it was true. The court reasoned that there is a natural human impulse to speak the truth, and therefore, a completely baseless story is less likely to be in circulation. Proving the falsity of the rumor tends to discredit the appellant, especially when he is unable to identify his source, suggesting that 'somewhere between the fact and the testimony there was a person who was not a truth speaker.' Admitting this rebuttal evidence prevents a 'gross perversion of right' by allowing the State to challenge a defendant's self-serving and unverifiable testimony.
Analysis:
This decision clarifies the scope of relevant rebuttal evidence in self-defense cases. It establishes that evidence of a 'collateral fact'—the actual truth of a rumor—can be admissible to impeach the credibility of a defendant who claims their actions were based on hearing that rumor. The ruling allows the fact-finder to make a logical inference: if a story is completely false, it is less probable that it was widely circulating as a rumor, which in turn makes it less probable that the defendant's testimony about hearing it is truthful. This precedent gives prosecutors a tool to challenge a defendant's subjective state-of-mind claims by attacking the objective reality on which those claims are purportedly based.
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