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Commonwealth v. Carroll

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Facts: Defendant argued a lot with his wife. They had a loaded pistol near the head of the bed. Right after a very long argument, he reached for the gun and shot her in the back of the head.

Procedural History: Charged with first degree murder. Found guilty and sentenced to life in prison. Appealed.

Issue: Was the murder done with malice aforethought?

Arguments: The D's rage, desperation, and panic produced a "reflex" that led to murder.

Holding: This was a willful, deliberate, and premeditated murder.

Reasons: "no time is too short" to qualify as premeditated.

Judgment: Affirmed