Commonwealth v. Carroll, 412 Pa. 525 (1963)

Case Name: Commonwealth v. Carroll
Citation: 412 Pa. 525 (1963)

Facts: Carroll was found guilty of first-degree murder for shooting his wife twice in the head. On appeal, Carroll raised the issue that the evidence could only sustain a conviction of second-degree murder. Some of the facts: Carroll served in the military and was constantly away from home. He took leave to be with his family. His wife had “sadistically” disciplined their children at times. The night of the murder Carroll and his wife argued for hours over a new job opportunity that would require Carroll to be away from home for four nights a week. Carroll’s wife said that she would leave him. There was a loaded gun on their window sill and Carroll shot her when she had fallen asleep.

Defendant’s argument:

  1. There was insufficient time for premeditation in the light Carroll’s good reputation.
  2. The time and place of the crime and the enormous difficulty of removing and concealing the body show an obvious lack of premeditation.
  3. Also,Carroll did not have the requisite premeditation based on a psychiatrist’s opinion. The psychiatrist stated that Carroll was dependant on his wife, he didn’t want her to leave, and that “rage,” “desperation,” and “panic” produced an impulsive automatic reflex type of homicide…as opposed to an intentional premeditated type of homicide.

State’s argument: No time is too short for the necessary premeditation to occur. The space of time between the premeditation and the fatal act is immaterial if the killing was in fact intentional, willful, deliberate and premeditated. Also, we do not have to believe everything a psychiatric says.

Holding: Judgment and sentence affirmed.

Reasoning: Society would be almost completely unprotected from criminals if the law permitted a blind or irresistible impulse or inability to control one’s self, to excuse or justify a murder or to reduce if from first to second degree.

Compare this to State v. Guthrie which provides different interpretation of premeditation


One Reply to “Commonwealth v. Carroll, 412 Pa. 525 (1963)”

  1. The court here only requires the intent and actus as oppossed to the court in Guthrie which requires prior calculation (or an intent to kill), a reasonable opportunity to reflect, and then the actus.

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