United States v. Watson

Brief Fact Summary.

Watson (Defendant) was convicted of murder although he was alone with the victim in the moments before the shot was fired.

Synopsis of Rule of Law.

A jury can find a defendant guilty of murder even when no evidence is presented concerning the events immediately before the fatal assault.

Facts.

A police officer saw Defendant driving a stolen car and gave chase. The chase ended in Defendant’s home where three girls were present. The officer attempted to subdue Defendant, but Defendant fought back, eventually coming up with the officer’s gun. Defendant pinned the officer down and pointed the weapon at his chest. The girls fled the room at this point. Words were exchanged between Defendant and the officer and a shot was fired. The officer died and Defendant was tried for murder. Defendant presented a manslaughter defense, but the jury convicted him of murder. Defendant appealed.

Issue.

Can a jury find a defendant guilty of murder without evidence of what happened immediately before the fatal assault?

Held.

(Rogers, Assoc. J.)Yes. A jury can find a defendant guilty of murder even when no evidence is presented concerning the events immediately before the fatal assault. The crime of murder requires some amount of premeditation. When the death arises out of an altercation, premeditation comes in the form of deliberation. The act must come from a conscious choice and not in the heat of the fight. Direct evidence of the fatal moment is not required in order for a jury to find that such deliberation occurred, however. A jury may use circumstantial evidence to determine that the defendant deliberated before committing the fatal act. Here, the jury had evidence that Defendant had pointed the gun at the officer for a significant period of time before pulling the trigger. Time to deliberate is probative of whether deliberation occurred, even if it is not definitive proof of deliberation. The jury could reasonably have found that Defendant deliberated. Affirmed.

Discussion.

Some criticize the legal definition of premeditation as being too broad, allowing for both a fatal assault during a fight after a brief moment of deliberation and a cold-blooded ambush of an unsuspecting victim to be treated as the same category of crime. In some jurisdictions, first-degree murder is divided into different categories and only certain aggravated scenarios are eligible for the death penalty.