Commonwealth v. Carroll
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.