Commonwealth v. Carroll

Brief Fact Summary. Following a violent argument he had with his wife, Carroll (D) shot her at the back of her head.

Synopsis of Rule of Law. A defendant words or conduct or the attendant circumstances, together with all reasonable inferences therefrom, the intentional use of a deadly weapon on a vital part of another person, which represents the specific intent to kill, are necessary in proving a first-degree murder.

Facts. While attempting to leave the car of her husband after the heated argument they had, Carroll’s wife (D) had a fractured skull which led to a mental disorder diagnosed as a schizoid personality type. Subsequently, the couple had another round of heated argument when Carroll (D) was to be absent for nine days due to his selection by an electronics school. Carroll (D) later shot his wife at the back of her head later that night. He pled guilty to the murder indictment and the court sentenced him to life imprisonment for being guilty of first-degree murder. Carroll appealed.

Issue. Can the defendant’s words or conduct or the attendant circumstances, together with all reasonable inferences, the intentional use of a deadly weapon on a vital part of another person, represents the specific intent to kill necessary in proving a first- degree murder?

Held. (Bell, C.J) Yes. A defendant words or conduct, or the attendant circumstances, together with all reasonable inferences, the intentional use of a deadly weapon on a vital part of another person, which represents the specific intent to kill, are necessary in proving a first-degree murder. The findings of the court were that of a first-degree murder but this was contended by Carroll (D) to be a second-degree murder. If the killing was intentional, deliberate, willful and premeditated, then whether the intent to kill or the killing were within a brief or long space of time is immaterial.

Discussion. This case stands to prove that “no time is too short” to prove premeditation.