Karl Denke was arrested in Münsterberg, a market town in Silesia, on Sunday, December 21, 1924. By half past nine that night he was dead by his own hand in a police cell. No charge was ever drawn up against him, no witness was heard, and no court weighed a single page of what the police gathered in the days that followed. Every number that has been attached to his name since then was written by someone other than a judge.
He is the first of fourteen. Some died before anyone could charge them. Some died in custody within days of arrest. One was declared not criminally responsible and committed. One walked out of a police station hours before he was due to answer, and one, a countess of the Kingdom of Hungary, was locked away for life on a nobleman’s order and never brought before a court at all. One was never accused by the state; her husband was, and a jury acquitted him. In most of these cases the deaths themselves are beyond dispute. What is missing in all of them is the trial, the one proceeding that would have forced each death to be named, proved and answered for separately.
The townspeople called him Father Denke, a quiet, churchgoing man who lived alone. He was arrested after a traveling journeyman went to the police at about one in the afternoon of December 21, according to the historian Lucyna Biały of the University of Wrocław, whose study rests on the local newspapers of 1924 and 1925. Denke was dead before the night was out.
What came to light in Münsterberg in the last days of December led investigators to attribute to him the deaths of twenty people whom they identified by name. Biały lists them by trade: carpenters, tailors, bakers, a butcher, a weaver, a locksmith, a gardener, laborers. They were men without homes or steady work who traveled the roads of Silesia, many of them recently out of prison or the hospital. Later researchers and the Polish press have put the possible total at thirty to forty. Münsterberg is now Ziębice, in Poland. None of the twenty deaths was ever examined in court.
Dean Arnold Corll was thirty-three when Elmer Wayne Henley Jr., a teenager from his circle, shot him dead in Pasadena, Texas, on August 8, 1973. The authorities ruled the shooting self-defense. Corll had never been arrested, and he was never charged.
The deaths that came to light in and around Houston that August were attributed to him by police and described in the statements of Henley and a second young associate, David Owen Brooks: at least twenty-eight boys and young men, aged thirteen to twenty, most of them from the Houston Heights, between 1970 and 1973. Skip Hollandsworth reported in Texas Monthly that police had written off many of the missing boys as runaways. The trials went to the accomplices. Henley was convicted of six murders in San Antonio in 1974; after the verdict was overturned on appeal, he was convicted again in Corpus Christi in June 1979. Brooks was convicted of one murder and sentenced to life in March 1975. In November 2025 the Texas parole board again denied Henley parole, KPRC reported. The one man the police named as the leader is the one man no jury ever heard about in his own right.
Elizabeth Báthory, widow of the soldier Ferenc Nádasdy, was seized at Čachtice (Csejte), in what is now western Slovakia, on December 29, 1610, by the men of the palatine of Hungary, György Thurzó. From the next day she was held in Čachtice Castle on his order. King Matthias II accepted her confinement for life after her relatives pleaded for leniency. She died there on August 21, 1614, never charged, never questioned in court, never tried.
The case against her was a mass of testimony. Investigators took statements from 327 witnesses, the Hungarian historian Gábor Várkonyi writes. Of those, 220 had nothing relevant to say and 43 gave statements that did not support the accusation; the remaining 64 had heard of deaths of girls and young women in her service, but not one had seen any. The numbers they offered ran, in the summary of the State Archive in Prešov, from two to 650. The famous figure of 650 traces to a single servant girl, who said a courtier had told her he had seen it written in the countess’s private book. The courtier said nothing of it in his own testimony, and the book was never produced. A document drawn from the inquiry, apparently prepared for a trial, was never used.
The trial that did take place was of her household. Four of her servants were tried at Bytča in January 1611, and three were executed. In Várkonyi’s reading, the countess’s case was shelved because the testimony would not have stood up, while the executions preserved the palatine’s authority and the appearance of justice.
Belle Gunness was born Brynhild Paulsdatter Storset in Selbu, Norway, on November 11, 1859, emigrated to Chicago in 1881, and from 1901 owned a farm outside La Porte, Indiana, where she drew Scandinavian immigrant men with matrimonial notices. On April 28, 1908, her house burned. In the weeks that followed, the deaths of more than a dozen people came to light in La Porte, among them Andrew Helgelien of South Dakota, Ole B. Budsberg of Iola, Wisconsin, and her foster daughter, Jennie Olson. The coroner, the sheriff and the prosecutor attributed them to her.
She was never arrested, charged or tried, because the coroner ruled that she had died in the fire. Many in La Porte refused to believe it then, and the doubt persists. Her former hired man was tried in November 1908 for the murder of Gunness and her three children; the jury convicted him of arson only. In 2007 a University of Indianapolis team set out to settle her identity with DNA, and the results were reported as inconclusive. Ted Hartzell, writing in American History in 2008, put the total that most researchers accept at ten to fourteen; the figures over forty that circulated in 1908 were rumor.
Joe Ball was a World War I veteran and a former bootlegger who ran a tavern in Elmendorf, southeast of San Antonio. On September 24, 1938, as two Bexar County deputies prepared to take him to San Antonio for questioning about women who had gone missing, he shot himself. He had not been arrested, and no charge had been filed.
His handyman then gave investigators an account that attributed to Ball the deaths of two women who had worked for him: Minnie Gotthardt of Seguin, who ran his bar and disappeared in the summer of 1937, and Hazel Brown, twenty-two, of McDade, who disappeared in 1938. Minnie Gotthardt’s death came to light at Ingleside, Texas, on October 14, 1938. The handyman received two years in jail as an accessory. Reports at the time spoke of more than a dozen other missing barmaids, and later published counts ran from five to twenty-five or more, but none of those further deaths was ever shown, Michael Hall wrote in Texas Monthly in 2002.
Manuel Delgado Villegas, called El Arropiero after his father’s trade selling arrope, a sweet fruit syrup, was arrested at El Puerto de Santa María, in the province of Cádiz, on January 18, 1971, in the inquiry into the death of his girlfriend, Antonia Rodríguez, thirty-eight. In custody he confessed to forty-eight killings in Spain and abroad. Police investigated twenty-two of the cases he described and came to treat seven as proved, according to Infobae and Vice; Telecinco, in 2026, put the number at eight. Among the names in those reports are Adolfo Folch (Garraf, 1964), Margaret Boudrie, twenty-one (Ibiza, 1967), Venancio Hernández (near Chinchón, 1968) and Anastasia Borrella, sixty-eight (Mataró, 1969).
He then spent about six and a half years in custody without a defense lawyer. In 1978 the Audiencia Nacional, Spain’s national court, closed the case without a trial, declared him not criminally responsible on psychiatric grounds and committed him to the penitentiary psychiatric hospital at Carabanchel, in Madrid. He was later moved to a hospital near Barcelona, spent his last years at liberty in Mataró, and died of lung disease at Can Ruti hospital in Badalona on February 2, 1998. The forty-eight is his own figure. The seven, or eight, belongs to the police.
Frederick Walter Stephen West, a Gloucester builder born at Much Marcle, Herefordshire, in 1941, was arrested on February 25, 1994, on suspicion of the murder of his daughter Heather, who had not been seen since 1987. He was charged with twelve murders: Catherine (Rena) Costello, his first wife; her daughter Charmaine; Anne McFall; Lynda Gough; Carol Ann Cooper; Lucy Partington; Therese Siegenthaler; Shirley Hubbard; Juanita Mott; Shirley Robinson; Alison Chambers; and Heather West. He admitted some of the deaths to police and denied others.
On January 1, 1995, he died by suicide in his remand cell at Winson Green prison in Birmingham, and his death ended every case against him. His wife, Rosemary West, was convicted of ten of the murders at Winchester Crown Court on November 22, 1995, and sentenced to life imprisonment; the European Commission of Human Rights later rejected her complaint about the fairness of that trial. The deaths of Rena Costello and Anne McFall were charged against him alone and came before no jury.
Bruno Lüdke, a laundry owner’s son from Köpenick, on the eastern edge of Berlin, came into the hands of the Berlin criminal police in 1943. The Nazi state had already classified him as hereditarily feeble-minded and had him sterilized by force. Under interrogation he confessed, and the police attributed to him the deaths of more than fifty women between 1924 and 1943. The case was classified as a secret state matter. He did not leave custody alive: he died in Vienna on April 8, 1944, after pseudo-medical experiments carried out on him in Nazi custody.
Until the 1990s the confessions were widely taken at face value. Robert Siodmak’s film Nachts, wenn der Teufel kam, which premiered in Düsseldorf on September 19, 1957, with Mario Adorf as Lüdke, presented him as a mass murderer. The historians Axel Doßmann and Susanne Regener, in their 2018 study Fabrikation eines Verbrechers, concluded that the series was an arbitrary construction of the Nazi criminal police. On August 28, 2021, Federal President Frank-Walter Steinmeier and Adorf joined in laying a Stolperstein, one of the small memorial stones for victims of Nazism, for him in Köpenick. He was not a perpetrator, Steinmeier said; he was a victim. The number attached to Lüdke did not drift upward like so many others. It was false from beginning to end.
On November 17, 1991, Margaret Kastanis and her three children died in the family’s home in West Jordan, Utah. Her husband was charged with four counts of capital murder. At his trial in the summer of 1993, the prosecution called him a time bomb of stress who had killed his family in a rage. The defense answered that Margaret Kastanis, depressed and psychotic, had killed the children and then herself. The assistant medical examiner had ruled her death a homicide.
After twenty-one days of testimony and about eight hours of deliberation, the jury acquitted him on July 14, 1993. Jurors told the Deseret News that they believed his account, and that West Jordan police had made up their minds about him early. One juror recalled that they kept reminding one another that Margaret Kastanis was not on trial. She never was. She was never charged, and no court made any finding against her. The deaths of the three children are attributed to her only by the defense case a jury accepted. Theirs was a single event on a single day, not a series, and it stands among these cases for one reason: the person to whom the deaths were finally attributed could never be asked to answer for them.
Vlado Taneski had spent years as the local correspondent in Kicevo, in western Macedonia, for newspapers in Skopje, and he had covered the deaths of older women from his own town. Police arrested him at home on Friday, June 20, 2008. They said his articles contained details they had never released, and that DNA tests tied him to two of the deaths. He was charged with the murders of Zivana Temelkoska and Mitra Simjanoska, whose deaths had come to light in Kicevo in May 2008 and January 2005, and police were examining the death of Ljubica Licoska and the disappearance of Gorica Pavleska. Two other men had already been convicted of the Simjanoska killing and sentenced to life.
A court in Gostivar ordered him held for thirty days, and he was moved to the prison in Tetovo. Early on Monday, June 23, 2008, he died there. The autopsy recorded drowning, and the police and the Justice Ministry called the death a suicide. A handwritten note beneath his pillow denied the killings. His wife said he maintained his innocence. No court ever heard the evidence the police described.
Itzcoatl Ocampo, a former Marine who had served in Iraq, was twenty-three when he was arrested in Anaheim, California, on January 13, 2012, the day John Berry, a sixty-four-year-old Vietnam veteran, died there. On February 16, 2012, an Orange County grand jury indicted him on six counts of murder with special circumstances: Raquel Estrada, fifty-three, and her son Juan Herrera, thirty-four, in Yorba Linda on October 25, 2011, and four homeless men in Placentia, Anaheim and Yorba Linda between December 20, 2011, and January 13, 2012, James Patrick McGillivray, Lloyd Middaugh, Paulus Smit and John Berry. Before his arrest, police had held Raquel Estrada’s surviving son in the Yorba Linda deaths; he was released, and in 2015 the City of Brea paid him $700,000 to settle his civil rights suit, admitting no liability.
Ocampo pleaded not guilty. The district attorney announced in May 2012 that he would seek the death penalty, the defense prepared an insanity case, and the trial was set for May 2014. On November 27, 2013, he fell ill in his single cell at the Orange County Central Men’s Jail, and he died at a Santa Ana hospital the next day, at twenty-five. The prosecutor wrote to the families of the six that he appeared to have tried to take his own life; the sheriff’s department declined to call the death a suicide. In June 2015 the district attorney released its custodial death report, which, The Atavist Magazine reported, assigned no criminal blame to law enforcement. None of the six charges was ever decided.
Masten Milimu Wanjala, reported to be twenty, was arrested at Kitengela, south of Nairobi, in July 2021 over the deaths of two Nairobi schoolboys, Charles Opindo Bala, thirteen, and Junior Mutuku Musyoki, twelve. On July 14 the Directorate of Criminal Investigations announced that he had confessed to killing at least ten children over about five years, a figure later given as twelve or thirteen. A Nairobi court allowed the police to hold him for thirty days while they investigated, and he was later held at Jogoo Road police station. In October the Director of Public Prosecutions said he was due to be charged with the murders of three children.
The charge was never put to him. On October 13, 2021, the day he was to take a plea, police announced that he had escaped from the station overnight. Two days later, on October 15, a crowd killed him at Mukhweya village in Bungoma County, his father’s home area. Three officers who had been on duty that night were charged with aiding a prisoner to escape and with neglect of duty. Every death attributed to Wanjala rests on what the police said he told them.
Albert Henry DeSalvo, a laborer from Malden, Massachusetts, confessed in 1965 to the eleven deaths of women in the Boston area between June 1962 and January 1964 that investigators had grouped as the work of the Boston Strangler, and to two others. He later recanted, and he was never charged with any of them. What he stood trial for was a separate set of crimes. On January 18, 1967, a Middlesex Superior Court jury convicted him on eight indictments, among them armed robbery and assault and battery by means of a dangerous weapon, committed against four women in 1964, all of whom survived. He was sentenced to life, and the Supreme Judicial Court affirmed the judgments on January 4, 1968.
He was killed at Walpole State Prison in November 1973. Three inmates were tried for his death, and none was convicted. In July 2013 the Suffolk County district attorney announced that DNA testing linked DeSalvo to the January 1964 murder of Mary Sullivan, nineteen, the last death in the series. He had been dead for four decades, and the link has never been tested in court. The eleven deaths stand where they stood in 1965, joined to his name by his own withdrawn confession.
Enriqueta Martí, a poor healer and beggar in Barcelona’s Raval district, was arrested on February 27, 1912, when police recovered a missing five-year-old girl, alive, in her keeping. Within days the city’s newspapers had made her the vampire of the Raval, a woman who killed children to make remedies. She was held in the Reina Amalia women’s prison to await trial and died there on May 12, 1913, before any trial took place. 3Cat, betevé and Nació Digital attribute her death to uterine cancer, and Barcelona Metropolitan reports that her death certificate gives that cause; the popular story that other inmates beat her to death is treated by historians as legend.
The historians Jordi Corominas and Elsa Plaza went back to the newspapers and court papers of 1912 and concluded that no killing was ever shown. The single act the record supports is the abduction of one girl, who went home to her family.
Set side by side, these cases share no century, country or method. What they share is a figure with nobody obliged to defend it. Denke’s twenty names and Lüdke’s fifty-odd women were both produced by police files; one list has stood for a hundred years, and the other was shown by historians to be an invention of the men who held the prisoner. Báthory’s 650 rests on one servant’s hearsay. Delgado Villegas gave forty-eight, and the police could stand behind seven. Corll’s two accomplices went to trial, and Corll did not. Margaret Kastanis’s husband was tried for four deaths and acquitted; she was never charged with any. In each case the record stops at the point where a courtroom would have begun, and whatever the first investigator, newspaper or confession said is still, in the end, all there is.
• 1610, December 29: Elizabeth Báthory is seized at Čachtice; held there until her death on August 21, 1614.
• 1611, January: four of her servants are tried at Bytča; three are executed.
• 1908, April 28: Belle Gunness’s house near La Porte, Indiana, burns; the coroner rules her dead.
• 1908, November: her former hired man is tried for murder and convicted of arson only.
• 1912, February 27: Enriqueta Martí is arrested in Barcelona.
• 1913, May 12: Martí dies in the Reina Amalia prison before trial.
• 1924, December 21: Karl Denke is arrested in Münsterberg and dies by suicide in his cell that night.
• 1938, September 24: Joe Ball dies by suicide in Elmendorf, Texas, before any charge.
• 1943: Bruno Lüdke is taken into custody by the Berlin criminal police.
• 1944, April 8: Lüdke dies in Vienna after pseudo-medical experiments.
• 1957, September 19: Nachts, wenn der Teufel kam opens in Düsseldorf.
• 1967, January 18: Albert DeSalvo is convicted in Middlesex Superior Court of offenses against four surviving women.
• 1971, January 18: Manuel Delgado Villegas is arrested at El Puerto de Santa María.
• 1973, August 8: Dean Corll is shot dead in Pasadena, Texas.
• 1973, November: DeSalvo is killed at Walpole State Prison.
• 1975, March: David Owen Brooks is sentenced to life.
• 1978: the Audiencia Nacional commits Delgado Villegas as not criminally responsible.
• 1979, June: Elmer Wayne Henley Jr. is convicted again of six murders.
• 1991, November 17: Margaret Kastanis and her three children die in West Jordan, Utah.
• 1993, July 14: her husband is acquitted of all four deaths.
• 1994, February 25: Fred West is arrested in Gloucester.
• 1995, January 1: West dies by suicide at Winson Green prison before trial.
• 1995, November 22: Rosemary West is convicted of ten murders.
• 1998, February 2: Delgado Villegas dies in Badalona.
• 2008, June 20: Vlado Taneski is arrested in Kicevo; he dies in custody in Tetovo on June 23.
• 2012, January 13: Itzcoatl Ocampo is arrested in Anaheim.
• 2013, July: the Suffolk County district attorney announces the DNA link between DeSalvo and Mary Sullivan.
• 2013, November 28: Ocampo dies in custody before trial.
• 2018: Doßmann and Regener publish Fabrikation eines Verbrechers.
• 2021, August 28: a Stolperstein for Lüdke is laid in Köpenick.
• 2021, October 13 and 15: Masten Wanjala escapes police custody in Nairobi and is killed by a crowd in Bungoma County.
• 2025, November 7: Henley is denied parole.