State v. Snowden
79 Idaho 266, 313 p.2d 706, 1957 Ida. LEXIS 216 (1957)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
To satisfy the element of premeditation for first-degree murder, the intent to kill need not exist for any particular length of time; it is sufficient that the intent was formed upon pre-existing reflection, even if that reflection occurred moments before the killing.
Facts:
- Defendant Raymond Allen Snowden spent an evening drinking and visiting bars.
- At the HiHo Club, Snowden met and danced with Cora Lucyle Dean, whom he had seen before but did not know well.
- Snowden and Dean left the club together and began arguing over cab fare.
- During the argument, Dean swung at and kneed Snowden.
- In response, Snowden stated he "blew his top," pushed Dean next to a truck, pulled out a pocket knife, and cut her throat.
- Snowden proceeded to stab Dean numerous times, mutilating her body and inflicting a fatal wound that severed her spinal cord.
- After the killing, Snowden took Dean's wallet, disposed of the knife and his bloody clothes, and cleaned himself up.
Procedural Posture:
- The defendant, Raymond Allen Snowden, was charged by information with the crime of murder in the first degree.
- Snowden entered a plea of guilty in the district court (trial court).
- The district court then held a hearing to hear evidence to determine the degree of the crime and to consider any mitigating circumstances.
- Following the hearing, the trial court found the offense to be murder in the first degree and entered a judgment sentencing Snowden to death.
- Snowden, as the appellant, appealed the judgment to the Supreme Court of Idaho.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the formation of an intent to kill, conceived moments before the fatal act as a result of a brief period of reflection, satisfy the 'willful, deliberate, and premeditated' element required for a first-degree murder conviction?
Opinions:
Majority - McQuade, Justice
Yes, the formation of an intent to kill, conceived moments before the fatal act, satisfies the 'willful, deliberate, and premeditated' element for first-degree murder. The court reasoned that premeditation does not require planning for any appreciable length of time; it is sufficient that the killing was done with reflection and conceived beforehand. Citing State v. Shuff, the court explained that 'the deliberate purpose to kill and the killing may follow each other as rapidly as successive impulses or thoughts of the mind.' Snowden's actions of deliberately opening his pocket knife and then repeatedly cutting and hacking the victim until she was dead demonstrated a clear and deliberate intent to take her life. The court also found malice could be implied from the deliberate and cruel nature of the act, which showed an 'abandoned and malignant heart,' and from the use of a deadly weapon. The defendant's claims of intoxication and mental disturbance were found insufficient to negate his capacity to form the requisite intent, especially given his methodical actions to conceal the crime afterward.
Analysis:
This case is a foundational example of the legal principle that premeditation can be formed in an instant. It establishes that the focus of the inquiry is on the quality of the thought, not the quantity of time. The court's willingness to infer premeditation from the defendant's sequential actions—such as drawing a weapon before attacking—significantly broadens the scope of first-degree murder. This precedent makes it more difficult for defendants to argue that a killing was a spontaneous, second-degree murder if there is any evidence of a moment of reflection, however brief, before the fatal act.
