Wednesday, April 4, 2012

Commonwealth v. Carrol case brief (412 Pa. 525)

Commonwealth v. Carrol
412 Pa. 525, 194 A.2d 911, 1963 Pa. 459
Supreme Court of Pennsylvania

FACTS
-Bell, the defendant, was an army officer with a good reputation in his community. His wife was mentally disturbed and she often abused his children and said insulting words to the D.
-One night, after the D told his wife that he had received an offer for a teaching job, they got into verbal argument and the wife said many insulting words to him.
-Later that night, the D grabbed a gun, which he claims he put on the side of the bed upon his wife's request, and shot the wife twice in the back of her head. Then he wrapped the body in sheets and he was arrested soon after.
-The defendant pled guilty and he was found guilty of first degree murder. The defendant now argues that his crime can not be any more severe than a second degree murder and he does not deserve to be guilty of first degree murder.

Issue: Was the defendant guilty of first degree murder (premeditated/deliberate murder)? 

Holding: Yes

RULES
First degree murder in Pennsylvania includes: "killings by poison, lying in wait or any other kind of willful deliberate and premeditated killing."

ANALYSIS
The defendant in this case has made the argument that he was mentally incapable of pre-planning the murder.  D also made the argument that his psychiatrist has testified that he (D) was temporarily in the state of blindness when he shot his wife and this statement should be considered when determining pre-meditation.
-The court used Commonwealth v. Drum to rule that the D did not need time to pre plan the murder in order to consider his actions pre-meditated.
-The court held that any small amount of time is good enough to plan a murder.
-Court further held that a psychiatrist's testimony should not be considered because after the murder the D recollected how he killed his wife and therefore, he was not in a state of blindness.
-The court held that the defendant deliberately grabbed the gun and deliberately shot two fatal shots to the head of his wife and these are the actions which require first degree sentence.

Conviction
:  The sentence of first degree murder was affirmed.

Link to Case:  Commonwealth v. Carrol

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