United States v. Bell

Video and witness testimony showed Bell (defendant) entering fellow inmate Pendelton's cell holding an object while his cellmate Dixon kept watch outside, followed roughly 70 seconds later by Bell's calm return and Dixon's brief entry to retrieve and dispose of clothing and a sharpened rod, after which Pendelton was found stabbed to death with no signs of a struggle in his cell; Bell was convicted of first-degree murder and appealed, arguing the government failed to prove the premeditation required for that charge.