State v. Guthrie
West Virginia Supreme Court of Appeals
461 S.E.2d 163 (1995)
Dale Guthrie (defendant), a dishwasher who suffered from panic attacks and depression and obsessed over his nose, became enraged after a coworker snapped him in the nose with a dishtowel and stabbed the coworker in the neck, killing him; Guthrie testified he suffered an intense panic attack right before the stabbing. The trial court's jury instructions stated that premeditation could exist even if the intent to kill formed only an instant before the killing, effectively equating first- and second-degree murder. The jury convicted Guthrie of first-degree murder, and he appealed the instructions.
Whether first-degree murder requires that the defendant have some period of time between forming the intent to kill and the actual killing, showing the act was premeditated and deliberate rather than impulsive.