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United States v. Watson

United States v. Watson

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Published by crlstinaaa
United States v. Watson

Hofstra Law School, Prof. Burke
Fall 2008

Criminal Law: Cases and Materials, Kaplan, Weisberg, Binder, 6th Edition.
United States v. Watson

Hofstra Law School, Prof. Burke
Fall 2008

Criminal Law: Cases and Materials, Kaplan, Weisberg, Binder, 6th Edition.

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Published by: crlstinaaa on Jan 12, 2009
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03/04/2013

Premeditated Murder (First Degree) Case: United States v. Watson, 501 A.2d 791 (1985) [p.

330-334]

Facts: Officer was pursuing the Δ for stealing a car. Δ ran into an apartment, made a phone call, and waited for the officer to arrive. When the officer came, the Δ resisted arrest, fought with the officer, and took his gun. But rather than escaping, the Δ shot the officer while he was on the floor. The officer twice told Δ that "it wasn’t worth it," but Δ ignored and still killed him. Δ was convicted of first degree murder. Δ now appeals, arguing there was insufficient evidence of premeditation and deliberation. Holding: The court held that there was in fact sufficient evidence, whereby a jury could conclude that that Δ had acted with premeditation and deliberation. Evidence was sufficient circumstantial evidence from which premeditation could be inferred: • When he ran into the apartment, he sat down at the table, and waited for officer to arrive. So, he had time to think about what he would do. • Δ did not flee when he had the opportunity to do so, and instead shot the officer when he was on the floor, and did not pose a threat to him. o 3 feet away from officer when he shot him - he could walk away o Successfully overpowered officer, had the gun, and could have left • Officer twice told him "it wasn’t worth it" but Δ still shot him o Officer pleading for his life - telling Δ its not worth it. But Δ still shoots him. Basically, he is making a decision after hearing what officer is telling him. • Timing - talked about girls leaving the room - they run 16-20 seconds before they heard the shot There was sufficient time for the Δ to think about what he was doing, so sufficient evidence of deliberate acts. Class Notes o No legal minimum to how long premeditation should take - just some time to think about it o Time - not just quantitative o Also qualitative - it was down time, quiet waiting for officer to show up; that he had overpowered officer, and quality time in deciding whether to kill him _________________________________________ Notes: [p. 334-340] o Duration o "no specific amount of time is necessary to demonstrate premeditation and deliberation and the government need not show a lapse of days, hours, or even minutes, but some appreciable time must elapse. o State v. Bingham (1986) - Δ strangled a mentally retarded woman to death. Lower court said that because the strangulation lasted at least 3 minutes, there was premeditation. State Supreme Court reversed, holding that both the time for and the fact o deliberation are required, and that a reasonable jury cannot infer deliberation simply from the length of time. o Criteria of Premeditation o Appellate courts will often cite evidentiary factors in determining whether the evidence was sufficient to support a jury verdict of 1st degree murder o Earlier hostility between the Δ and the victim (like a pattern of abusing the victim, spouse) o Self-interested motive (like a fight about money) o The manner and circumstances of the killing (interruption and subsequent continuation of the killing, where Δ adjusted gun during murder; where murder weapon, a hammer, was wrapped in cloth) o Δ's behavior before the killing (stalking victim)

Origin of the murder weapon (Δ bringing a loaded gun) o Deliberation vs Premeditation o Kazalyn v. State (1992) - Defined premeditation - a design, a determination to kill, distinctly formed in the mind at any moment before or at the time of the killing. o Byford v. State (2000) o Deliberation is the process of determining upon a course of action to kill as a result of thought, including weighing the reasons for and against the action and considering the consequences of the action. o A deliberate determination may be arrived at in a short period of time. But in all cases the determination must not be formed in passion, or if formed in passion, it must be carried out after there has been time for the passion to subside and deliberation to occur. A mere unconsidered and rash impulse is not deliberate, even though it includes the intent to kill. o Mental Disorder o Commonwealth v. Gould (1980) - Δ convicted of 1st degree murder; he was diagnosed as a paranoid schizophrenic, and believed he was killing her justly. Δ plead insanity. Court held that Δ entitled to offer evidence of his mental condition in order to try to persuade the jury that even if he was guilty of an intentional killing, he was unable to premeditate one.
o

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