People v. Waters
Michigan Court of Appeals
324 N.W.2d 564 (1982)
Ronnie Waters (defendant) borrowed a friend’s handgun one evening, supposedly just for show. Waters and four friends then drove around and ended up outside a drive-in theater. Waters tucked the gun into his waistband, and the group snuck into the theater on foot. Inside the theater’s parking area, one of the group’s members asked a man in a car for a match. Although the parties later disputed exactly what was said, the man in the car did not provide a match. The group started to walk away, but Waters lingered, making statements indicating that he was upset about the man denying his friend a match. Waters then pulled out the gun, aimed using both hands, and shot the car’s window. This shot caused the window to break and the man to fall sideways into his wife’s lap. Several seconds later, Waters fired a second time. This second shot hit the man’s wife, killing her. After a bench trial, the court convicted Waters of first-degree murder. On appeal, Waters argued that (1) a killing must be premeditated and deliberate to qualify as first-degree murder and (2) the evidence did not support a finding that this killing was premeditated and deliberate.
Rule of Law
Holding and Reasoning (Cynar, J.)
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