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Commonwealth v. Carroll
Pennsylvania Supreme Court
194 A.2d 911, 412 Pa. 525 (1963)
Donald Carroll (defendant) got married while he was serving in the Army. Within a few years, Carroll’s wife insisted that he be transferred back to the United States from an overseas assignment. This eventually led to Carroll having to resign from the Army. Carroll’s wife suffered a brain injury and was diagnosed as a schizoid personality type who sometimes felt like hurting their children and disciplined the children violently. In January 1962, Carroll went to an electronics school out of the state for nine days. This caused a serious argument. Carroll’s wife asked Carroll to place a loaded handgun on the windowsill near their bed, to feel safe. When Carroll returned, he told his wife that he had been assigned to teach at a school out of town for ten weeks. This would require Carroll to be away from home four out of seven nights each week for that period. Carroll and his wife argued for hours, from dinner into the early morning. Carroll’s children had also been injured; one had bruises on his feet, and the other had four stitches on his chin. Between 3:00 and 4:00 a.m., Carroll’s wife was lying with her back to Carroll and making comments to him. Carroll’s wife said she would leave him if he agreed to the teaching post. About five minutes after Carroll’s wife made her last statement, Carroll reached up, retrieved the gun, and shot her twice in the head. Carroll attempted to hide the murder by removing the body in a blanket and leaving it near a trash dump. The state (plaintiff) charged him with first-degree murder. Upon his arrest, Carroll stated that he grabbed the pistol and shot her twice in the back of the head. At trial, Carroll presented evidence that he was a hard worker with a very good reputation among his neighbors. A psychiatrist testified Carroll’s actions were likely the result of rage, desperation, and panic. The psychiatrist believed the shooting was more an impulsive reflex than an intentional premeditated act. The trial court convicted Carroll, and he appealed.
Rule of Law
Holding and Reasoning (Bell, C.J.)
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