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State v. Guthrie

461 S.E.2d 163 (1995)

tl;dr: Premeditated murder is a killing that takes place after the killer has considered and weighed the decision to kill.

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Dale Edward Guthrie was found guilty of first-degree murder for stabbing his coworker, Steven Todd Farley, in the neck after Farley made fun of him with a dishtowel. Guthrie has various psychiatric disorders, but a psychiatrist testified that he was sane at the time of the offense. The court reviewed the sufficiency of evidence, trial court's instructions on first-degree murder, and refusal to give the defendant's instruction on circumstantial evidence. The court upheld the lower court's verdict, but had doubts about first-degree murder and suggested a lesser-included crime. The court adopted the federal standard of review for sufficiency of evidence claims and relied on common law to interpret the terms "wilful," "deliberate," and "premeditated." The defendant's mental state is in question, but guilt cannot be based on conjecture.

The court clarifies the difference between first and second-degree murder and approves a proper instruction defining premeditation in a first-degree murder case. The prosecution violated American Bar Association Standards for Criminal Justice by using objectionable comments and cross-examination of the defendant's father. Evidence related to race, gender, or religion is admissible if it is relevant to the case and its probative value outweighs the danger of unfair prejudice. The trial court must balance the probative value of evidence against the risk of undue prejudice and confusion. The case will go for a new trial due to the objectionable comments by the prosecution. The court clarifies the difference between premeditation and intent to kill, but the suggested definition of premeditation may create confusion and should be clarified.

IRACIssue, Rule, Analysis, Conclusion

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Facts & Holding

Facts:Guthrie worked as a dishwasher at a restaurant. His coworker,...

Holding:The court held that the instruction was improper, because it...

State v. Guthrie

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