Stephenson v. State

Brief Fact Summary. A woman, who had been kidnapped by the Defendant, Stephenson (Defendant), committed suicide with a poison pill evidently in order to forego facing further physical and emotional abuse, including attempted rape, from her kidnapper.

Synopsis of Rule of Law. A homicide is committed where an intervening actor who causes the fatal blow is rendered irresponsible as a result of defendant’s unlawful conduct.

Facts. The Defendant abducted a woman and subjected her to various forms of sexual perversion, including the infliction of bite wounds. While abducted, the woman found an opportunity to buy poison tablets. She then took these in order to end her life. The Defendant delayed in getting her emergency medical treatment for the poison until the following day. She died several days later.

Issue. Is the Defendant liable for murder if death is caused through an intervening actor rendered irresponsible by the Defendant’s conduct?

Held. Yes. Judgment affirmed.
The woman whom the Defendant abducted was rendered mentally irresponsible for her actions in ingesting a poison pill insomuch as the Defendant had created an environment which impelled her to the act and from which she could not escape. The woman was at all times in the custody and absolute control of the Defendant and the possibility that the Defendant would attempt to rape her again was a pressing and overwhelming concern at the time she swallowed the pill. That she would try to take her own life, was the natural and probable consequence of the abuse the Defendant had subjected her to.

Discussion. The court in this case holds that merely creating conditions that make another person take their own life rises to the level of murder, where those conditions have the effect of making the victim mentally irresponsible for his own actions.