Commonwealth v. Carroll

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Commonwealth v. Carroll
Court Supreme Court of Pennsylvania
Citation 412 Pa. 525
194 A.2d 911 (1963)
Date decided 1963

Facts

Donald Carroll admittedly shot his wife in the back of the head twice with a pistol. He then wrapped her body in a blanket and sheets, tied them with clothesline, and took it to a desolate trash dump. He claimed they were arguing since dinner the night of the incident, and that they were lying in bed and she had just fallen asleep when the murder occurred. They had two boys, whom Donald claimed were sadistically abused by his wife. His wife had sustained mental/head injuries when she hit her head on the car door.


Procedural History

Carroll pled guilty generally to an indictment charging him with murder, was tried by a jury, and found guilty of first degree murder and sentenced to life in prison. He then appealed.


Issues Does the evidence against Carroll sustain no higher than second degree murder? Was the murder premeditated, and if not does this require the court to rule murder in the second degree?


Holding/Decision

Judgment and sentence confirmed (murder in the first degree).


Reasoning

The defendant claimed that he remembered the gun, deliberately took it down, and deliberately fired two shots into the head of his sleeping wife. This proves that he did indeed intentionally kill a human being with premeditation and deliberation (definition of first degree murder).


Conclusion

Life in prison…Courts cannot remit to psychiatrists the right to determine the intent or the state of mind of an accused at the time of the commission of homicide.


Concurrence

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 it from first to second degree.


Dissent

The defendant was mentally insane at the time, driven by his wife’s nagging, sadistic treatment of their children, and threats of leaving him. He did not premeditate the murder, because he is a good man, and a good man needs much more time to premeditate a murder. Accordingly, his clean-up was unplanned for and unprofessional.