Ex Parte Heigho
Idaho Supreme Court
110 P. 1029 (1910)
After hearing Barton may have made disparaging remarks about him, Edgar Heigho (defendant) and Frank Miller went to Barton's home and rang the doorbell. Barton's mother-in-law, Sylvia Riegleman, warned Barton not to open the door because Heigho had a gun; Barton opened it anyway, confirmed he had said nothing untrue, and Heigho punched him. Barton hit back, his wife separated the two, and Heigho and Miller were ordered off the property. Meanwhile Riegleman remained at the door crying that Heigho was going to kill Barton, then collapsed clutching the porch banister and died shortly after; an autopsy found she suffered a ruptured aneurysm. Heigho was charged with manslaughter for causing Riegleman's death by fright or terror, and he petitioned the Idaho Supreme Court to dismiss the charge.
Whether a defendant may be charged with manslaughter for causing a victim's death through fright, terror, or nervous shock alone, without any direct physical act directed at the victim.