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Loy v. State

Wyoming Supreme Court
185 P. 796 (1919)


Charles Loy was a white guest at a Laramie, Wyoming hotel who shot and killed an African American porter during a brief altercation. Loy said the porter came at him in a threatening manner while touching his coat pocket. Loy claimed self-defense, but he was charged with first-degree murder. The trial judge gave a detailed jury instruction explaining that to convict, the jury had to find that Loy acted with premeditated, deliberate intent to kill the porter. The judge said premeditation meant to “think beforehand” and required an interval, however brief, between forming an intent to act and acting on it. The judge explained that premeditation or deliberation need not have lasted any particular length of time before Loy pulled the trigger, just long enough to allow someone to think it over and appreciate and understand the nature of the act and its probable consequences. The jury convicted Loy of first-degree murder and sentenced him to life in prison. Loy appealed on self-defense grounds.

Rule of Law


Holding and Reasoning (Beard, C.J.)

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