Law School Case Brief
United States v. Brown - 518 F.2d 821 (7th Cir. 1975)
In considering defendant's motions for judgment of acquittal and to withdraw from the jury's consideration of the charge of first and second degree murder, the test to be applied by the trial court was whether there was substantial evidence from which the jury might find defendant guilty beyond a reasonable doubt when the evidence and all legitimate inferences therefrom were viewed in the light most favorable to the government.
Defendant Robert Lee Brown, an inmate at the United States Penitentiary at Terra Haute, Indiana, was charged with first-degree murder for “willfully, deliberately, and premeditatively” attacking and killing another inmate. According to the evidence, defendant stabbed the victim in the corridor of the penitentiary. The jury found defendant guilty of first-degree murder. On appeal, defendant asserted that there was insufficient evidence of premeditation, and asked the Court to reduce his conviction from first-degree murder to second-degree murder.
Was there insufficient evidence of premeditation, thereby warranting the reduction of defendant’s conviction to second-degree murder?
The Court held that sufficient evidence of premeditation existed to support the jury's verdict of guilty of first degree murder under 18 U.S.C.S. § 1111. The facts and circumstances surrounding defendant's resumption of the stabbing of the victim in the corridor established premeditation and justified the jury's finding that the killing was willful, deliberate, malicious, and premeditated, with malice aforethought. According to the Court, no basis existed for reducing the conviction to one of lesser degree or for setting aside a verdict which so manifestly might have been reached by a jury upon the evidence before it.
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