Stephenson v. State, 179 N.E. 633 (Ind. 1932)

Facts: Stephenson, a Klan leader, abducted, raped, and brutally beat Madge Oberholtzer. While in his custody and after he refused her medical care, she ingested mercury poison in a suicide attempt. She died weeks later from a combination of the poisoning, her injuries, and infection.
Issue: Whether the victim's voluntary self-administration of poison broke the causal chain between ∆'s assault and her death.
Rule: A victim's act done in response to ∆'s wrongful conduct, where ∆'s conduct rendered her mind irrational and incapable of free will, does not break the causal chain. ∆ remains the proximate cause.
Analysis: ∆'s acts left the victim physically and emotionally devastated. Her suicide was a foreseeable, dependent response to the unlawful imprisonment and rape, not a free, independent intervening cause.
Judgment: Murder conviction affirmed.

Reading: pp. 159–63. See Ch. 4—Causation.