State v. Bingham

699 P.2d 262, 40 Wash. App. 553, 1985 Wash. App. LEXIS 2370
CourtCourt of Appeals of Washington
DecidedMay 8, 1985
Docket7464-8-II
StatusPublished
Cited by8 cases

This text of 699 P.2d 262 (State v. Bingham) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Bingham, 699 P.2d 262, 40 Wash. App. 553, 1985 Wash. App. LEXIS 2370 (Wash. Ct. App. 1985).

Opinions

Worswick, C.J.

We are asked to decide whether the time to effect death by manual strangulation is alone sufficient to support a finding of premeditation in the absence of any other evidence supporting such a finding. We hold it is not. Accordingly, we reverse the conviction of Charles Dean Bingham for aggravated first degree murder. We also overrule State v. Smith, 12 Wn. App. 720, 531 P.2d 843 (1975),1 to the extent that it can be read to hold otherwise.

Leslie Cook, a retarded adult living at the Laurisden Home in Port Angeles, was raped and strangled on February 15, 1982. Bingham was the last person with whom she was seen. The two of them got off the Port Angeles-Sequim bus together at Sequim about 6 p.m. on February 15. They visited a grocery store and two residences. The last of these was Enid Pratt's where Bingham asked for a ride back to Port Angeles. When he was refused, he said they would hitchhike. They took the infrequently traveled Old Olympic Highway. Three days later, Cook's body was discovered in a field approximately Vi mile from the Pratt residence.

At trial, the State's expert testified that, in order to cause death by strangulation, Cook's assailant would have had to maintain substantial and continuous pressure on her wind[555]*555pipe for 3 to 5 minutes. The State contended that this alone was enough to raise an inference that the murder was premeditated. The trial judge agreed because of State v. Smith, supra.2 Therefore, it allowed the issue of premeditation to go to the jury. The jury convicted Bingham of aggravated first degree murder, rape being the aggravating circumstance. On appeal, counsel for Bingham concedes that a finding of guilty of murder was justified; he challenges only the finding of premeditation, contending that the evidence was insufficient to support it. We agree.

Premeditation is a separate and distinct element of first degree murder. It involves the mental process of thinking over beforehand, deliberation, reflection, weighing or reasoning for a period of time, however short, after which the intent to kill is formed. State v. Brooks, 97 Wn.2d 873, 651 P.2d 217 (1982). The time required for manual strangulation is sufficient to permit deliberation. See RCW 9A.32.020(1); State v. Gaines, 144 Wash. 446, 258 P. 508 (1927), cert, denied, 277 U.S. 81 (1928). However, time alone is not enough. The evidence must be sufficient to support the inference that the defendant not only had the time to deliberate, but that he actually did so. To require anything less would permit a jury to focus on the method of killing to the exclusion of the mental process involved in the separate element of premeditation.

The concept of premeditation had a slow but sure beginning in Anglo-American legal history. More than 500 years ago, English jurists arrived at the not surprising conclusion that the worst criminals—and those most deserving of the [556]*556ultimate punishment—were those who planned to kill and then did so. Thus began the movement toward classification of homicides that resulted in restriction of the death penalty to those involving "malice prepensed" or "malice aforethought."3 When Washington's first criminal code was enacted in 1854, the Territorial Legislature abandoned this archaic language and used the phrase "deliberate and premeditated malice" in defining first degree murder. It thereby made a clear separation between a malicious intent and the process of deliberating before arriving at that intent.4

Our Supreme Court recognized the need for evidence of both time for and fact of deliberation in State v. Arata, 56 Wash. 185, 189, 105 P. 227 (1909). Although it reversed a first degree murder conviction because a portion of an instruction was erroneous, it approved the remainder of the instruction, saying:

In the case at bar, the court said, in substance, the law knows no specific time; if the man reflects upon the act a moment antecedent to the act, it is sufficient; the time of deliberation and premeditation need not be long; if it furnishes room for reflection and the facts show that such reflection existed, then it is sufficient deliberation, and closed the instruction upon this point with the statement: "There need be no appreciable space of time between the formation of the intention to kill and the [557]*557killing." By these few last words the court destroyed at once all that was good in the entire statement, and gave the jury a rule which this court has frequently held was erroneous. This was reversible error.

(Italics ours.) Arata, 56 Wash, at 189. This analysis seems implicitly to have been recognized, although imperfectly expressed, in more recent cases as well.5

The subject of premeditation appears frequently in Washington cases. However, it is seldom discussed in a way that affords clear, objective guidance to trial judges in determining the sufficiency of the evidence to support it. Nevertheless, review of these cases reveals that in each one where the evidence has been found sufficient, there has been some evidence beyond time from which a jury could infer the fact of deliberation. This evidence has included, inter alia, motive, acquisition of a weapon, and planning directly related to the killing. See State v. White, 60 Wn.2d 551, 374 P.2d 942 (1962), cert, denied, 375 U.S. 883 (1963); State v. Ross, 56 Wn.2d 344, 353 P.2d 885 (1960); State v. Lindamood, 39 Wn. App. 517, 693 P.2d 753 (1985); State v. Commodore, 38 Wn. App. 244, 684 P.2d 1364 (1984).

Unless evidence of both time for and fact of deliberation is required, premeditation could be inferred in any case where the means of effecting death requires more than a moment in time. For all practical purposes, it would merge with intent; proof of intent would become proof of premeditation. However, the two elements are separate. Premeditation cannot be inferred from intent. State v. Brooks, 97 [558]*558Wn.2d at 876; State v. Commodore, supra.6

Premeditation can be proved by direct evidence, or it can be proved by circumstantial evidence where the inferences drawn by the jury are reasonable and the evidence supporting the jury's findings is substantial. State v. Luoma, 88 Wn.2d 28, 558 P.2d 756 (1977). There was no such evidence here, either direct or circumstantial.

There was no evidence that Bingham had known Cook before February 15 or that he had a motive to kill her. By chance, they took the same bus. When Cook's companion on the bus refused to go to Sequim with her, Bingham offered to see that Cook got back to the Laurisden Home later. That was apparently still his intention when he asked for a ride at the Pratt residence.

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State v. Bingham
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Bluebook (online)
699 P.2d 262, 40 Wash. App. 553, 1985 Wash. App. LEXIS 2370, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bingham-washctapp-1985.