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.
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.
- There was insufficient time for premeditation in the light Carroll’s good reputation.
- The time and place of the crime and the enormous difficulty of removing and concealing the body show an obvious lack of premeditation.
- 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