Stephenson v. State

Stephenson (defendant), with accomplices, abducted Madge Oberholzer, a social acquaintance, and assaulted and attempted to rape her while holding her captive on a trip toward Chicago. Later, while briefly left alone, Oberholzer secretly obtained and swallowed poison in an attempt at suicide; she became violently ill, but Stephenson refused her repeated requests to see a doctor and instead drove her back toward Indianapolis before eventually returning her to her family, where a doctor treated her for poisoning. Over the following ten days, most of her wounds healed, but one became infected, and she died from the combined effects of the poison, infection, shock, and lack of early treatment. Stephenson was convicted of murder and appealed, arguing her act of taking the poison broke the chain of causation between his conduct and her death.