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Knapp v. State

    Brief Fact Summary. Knapp is the (D). He claims self defense and had been told the victim actually killed a different person. In this case the prosecution was allowed to prove that the victim did not cause the other person’s death.

    Synopsis of Rule of Law. Relevancy is determined on a specific item of evidence by proof of the relevancy could reasonably help to resolve the main issue at trial

    Facts. Knapp (D) killed a deputy sheriff in Hagerstown who attempted to arrest him and D claimed that he murdered in self-defense. People around the town had told D that the deputy killed the old man. The prosecutor then showed that the deputy did not kill the old man, that the old man died of natural causes. D was convicted of murder and he then appealed, claiming that the real issue was whether D had heard that the deputy had killed the old man.

    Issue. Is evidence relevant of a particular item if it tends to support whether proof of that evidence would assist to resolve the to a central issue of a case?

    Held. Yes, the judgment is affirmed.
    D was correct in asserting that the real issue was whether or not D had heard that the deputy had killed the old man. Yet their may be some evidence that does not have a direct connection to the trial. In this case D claimed that he had heard that the deputy killed the old man. If in fact the deputy had not killed the old man, it is less likely that someone would have told D such a story. People have a tendency to tell the truth.

    The problem for the prosecutor was that he could not show what D had, or had not, heard. Obviously, there are multiple ways prosecution could handle the case. He attacked the problem by showing that the deputy had not killed the old man, which in turn meant that somewhere between the truth and D’s testi-mony there was a person who was not telling the truth. This, coupled with D’s being unable to identify the informant, was his claim of what he heard was less probable. No error having been shown, therefore conviction is affirmed.


    Discussion. The court shows that admissibility of evidence in this case indicates that if even a slight inference can be made, then the court should admit the evidence of a collateral fact. In actual practice, the courts tend to weigh the value of the evidence against the amount of time that will be consumed by its introduction. The more there is a direct connection to the case; the court will be more liberal.


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