Wednesday, December 18, 2013

Commonwealth v. Carroll case brief

Commonwealth v. Carroll case brief summary
194 A.2d 911 (1963)

Defendant challenged a judgment of the Court of Oyer and Terminer and General Jail Delivery of Allegheny County (Pennsylvania), which convicted him of murder in the first degree. The trial court sentenced defendant to life imprisonment and denied his motions for a new trial and in arrest of judgment.

Defendant pled guilty generally to an indictment charging him with the murder of his wife. After a non-jury trial, the trial court found him guilty of first-degree murder and sentenced him to life imprisonment.


  • The court affirmed the judgment. 
  • The evidence favorable to the commonwealth was sufficient to prove first degree murder even if all of defendant's statements and testimony were believed. 
  • The short period of time in which defendant allegedly formed the intent to kill his wife did not bar a finding of premeditation. 
  • No length of time was a prerequisite for such a finding, which was a fact to be determined from all the circumstances in evidence. 
  • The time and place of the crime, the difficulty of removing the body, and the lack of an escape did not negate a finding of premeditation. 
  • The judge was not required to believe a psychiatrist's testimony as to defendant's state of mind at the time of the crime. 
  • Such an opinion was entitled to very little weight, especially when defendant's own actions and testimony belied it. 
  • It was the trial court's task, not the psychiatrist's, to determine the defendant's state of mind and his criminal responsibility.

The court affirmed the judgment convicting defendant of murder in the first degree and sentencing him to life imprisonment.

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