United States v. Bell

The United States government (plaintiff) prosecuted William Bell (defendant), a prisoner held in cell 103 of a federal penitentiary, for the first-degree murder of Brian Pendelton, in violation of 18 U.S.C. § 1111. Pendelton was held in cell 105 of the same penitentiary. At the time in question, all the cells in Bell's cellblock were unlocked. Witness testimony and a video recording introduced at trial established that Bell, wearing a white t-shirt and holding an object in his hand, left cell 103 and entered cell 105. Bell's cellmate Lenard Dixon also left cell 103 and sat down in a chair outside and facing away from cell 105. At one point, Dixon turned to look inside cell 105. About 70 seconds later, Bell emerged from cell 105 and returned to cell 103. Bell was stripped to the waist and held his t-shirt in one hand and a long, slender object in the other. Dixon entered cell 105 and emerged about 25 seconds later. Pendelton crawled into the cellblock corridor, bleeding to death from a stabbing wound to his neck. Dixon stepped past Pendelton with a pile of clothing and a sharpened rod in his hands. Dixon took these items to the prison dayroom, where he stuffed them in a trashcan and covered them with other trash. Bell emerged from cell 103, once again wearing a white t-shirt, and proceeded to the prison shower room. Bell and Dixon conducted themselves calmly and unhurriedly throughout the incident. There were no signs of a struggle inside cell 105. The jury convicted Bell and he appealed to the Seventh Circuit Court of Appeals, contending that the government failed to prove the premeditation required for a first-degree murder conviction.