## Facts

- John Knapp was tried for the first-degree murder of the Hagerstown town marshal and was sentenced to life imprisonment.
- Knapp testified and asserted a self-defense theory, claiming he reasonably feared the marshal.
- To support his claimed fear, Knapp testified he had heard that the marshal previously clubbed and seriously injured an elderly man during an arrest and that the man died shortly thereafter.
- On cross-examination, Knapp could not identify who told him the story, stating only that it came from “some people around Hagerstown.”
- In rebuttal, the State called a physician who testified that the elderly man died of senility and alcoholism and had no bruises or marks when he died.
- Knapp objected that the cause of the elderly man’s death was collateral and irrelevant because the pertinent point was only whether Knapp had heard and believed the story.

## Issues

1. Whether rebuttal testimony proving the alleged victim of a prior beating died from natural causes (and showed no injuries) was relevant and admissible to rebut the defendant’s claim that he had heard and relied on a story about the deceased marshal’s violence.

## Decision

- The Indiana Supreme Court affirmed the conviction and life sentence.
- The court held the physician’s rebuttal testimony was properly admitted as relevant.
- The court reasoned that showing the story was false tended to make it less likely the story would have been told and thus less likely the defendant actually heard it as claimed.
- The court treated the rebuttal evidence as bearing on the defendant’s credibility and the plausibility of his asserted basis for fearing the marshal, leaving the ultimate weight of the evidence to the jury.

## Legal Principles

- Evidence is relevant if it has any logical tendency, even if indirect or slight, to make a fact of consequence more or less probable.
- A collateral fact may be admissible when it supports a fair inference about a material matter, including a witness’s credibility.
- Proof contradicting the factual basis of an alleged out-of-court report may be admitted to challenge whether the report was likely made or received as claimed, even if the underlying truth of the report is not the ultimate issue.
- Limits on such proof generally concern weight and jury evaluation rather than categorical inadmissibility where logical relevance exists.

## Conclusion

The court upheld admission of rebuttal medical testimony disproving the incident underlying the defendant’s claimed fear, holding it relevant to whether the defendant actually heard the story and to his credibility, and affirmed the murder conviction.


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