United States v. Watson
District of Columbia Court of Appeals
501 A.2d 791 (1985)
After officers spotted Watson (defendant) driving a stolen car, he fled into an apartment, made a phone call asking if police were "still out there," and was then confronted by Officer Lunning with his gun drawn. During a struggle, Lunning's gun fell, Watson gained control of it, and after Lunning twice said "it wasn't worth it," Watson shot and killed him. Watson was convicted of first-degree murder and appealed the denial of his motion for acquittal, arguing the killing happened too quickly to have been premeditated and deliberate.
Whether a defendant can be convicted of first-degree murder for a deliberate and premeditated killing when the interval between forming the plan and the actual killing is very brief.