Case Name: State v. Guthrie
Citation: 194 W. Va 657 (1995)
Facts: Guthrie was convicted of first-degree murder and received a life sentence. Guthrie killed his co-worker after he was teased and whipped with a towel. Guthrie removed a knife from his pocked and stabbed the victim in the neck and as he fell, the arm. Guthrie had documented psychiatric problems including: two daily panic attacks, chronic depression, and an obsession with his nose (body dysmorphic disorder). Guthrie testified that he suffered a panic attack immediately preceding the stabbing.
Defendant’s argument: The jury instructions equated the terms “willful, deliberate, and premeditated” with “an intent to kill.” What is the point of having all of these different words if they all mean the same thing?
State’s argument: Premeditation can occur instantaneously and deliberation is only required for a moment. “No time is too short for the necessary premeditation to occur.” See Commonwelath v. Carroll.
Holding: Reversed and remanded for a new trial.
Reasoning: The jury instructions do not inform the jury of the difference between first- and second-degree murder. “To allow the State to prove premeditation…by only showing that the intention came into existence for the first time at the time of such killing completely eliminate the distinction between the two degrees of murder.” An elaborate plan or scheme to take life is not required, but the notion of instantaneous premeditation and momentary deliberation is not satisfactory for proof of first-degree murder.