Commonwealth v. Carroll
Pennsylvania Supreme Court
412 Pa. 525, 194 A.2d 911 (1963)
Following a long, heated overnight argument after Carroll (defendant) told his mentally ill wife he would be away for a ten-week teaching assignment, Carroll took a loaded pistol from the windowsill and fired two shots into the back of his sleeping wife's head, later concealing her body near a dump; he pleaded guilty generally to murder and was convicted of first-degree murder by a judge sitting without a jury, and he appealed arguing there was insufficient time for premeditation.
Whether, in Pennsylvania, the specific intent to kill, required to prove first-degree murder, may be found from a defendant's words or conduct, from the circumstances together with reasonable inferences, and from the intentional use of a deadly weapon upon a vital part of another human being.