## Facts

- Dale Edward Guthrie and Steven Todd Farley worked as dishwashers at a restaurant in Nitro, West Virginia.
- On February 12, 1993, Farley repeatedly teased Guthrie and snapped him with a dishtowel; the towel struck Guthrie’s nose, and Guthrie became enraged.
- Guthrie removed his gloves, approached Farley, pulled a knife from his pocket, and stabbed Farley in the neck and arm.
- Farley stated he was “just joking” and died from the neck wound.
- Guthrie presented psychiatric evidence (including panic attacks, chronic depression, and borderline personality disorder) and testimony supporting a theory that he acted in a panic or heat of passion rather than with premeditation and deliberation.
- A jury convicted Guthrie of first-degree murder; he received life imprisonment with a recommendation of mercy.
- On appeal, Guthrie challenged the jury instructions defining premeditation and deliberation, along with other alleged trial errors and the sufficiency of the evidence.

## Issues

1. Whether instructions stating that premeditation may exist “only for an instant,” and equating “willful, deliberate, and premeditated” with mere intent to kill, misstated the law and eliminated the statutory distinction between first- and second-degree murder.
2. Whether the evidence, viewed most favorably to the prosecution, was sufficient to permit a rational jury to find first-degree murder under correct instructions.
3. Whether additional alleged errors (including prosecutorial conduct and cumulative error) warranted relief.

## Decision

- The Supreme Court of Appeals of West Virginia reversed the conviction and remanded for a new trial.
- The court held the challenged instructions were erroneous because they allowed the jury to treat any intentional killing as “willful, deliberate, and premeditated,” collapsing the statutory distinction between first- and second-degree murder.
- The court clarified that premeditation and deliberation require evidence of reflection and decision-making beyond instantaneous intent, though no fixed minimum time is required.
- The court held the evidence was legally sufficient for a properly instructed jury to find first-degree murder; reversal was based on instructional error, not evidentiary insufficiency.
- The court addressed other claimed errors but found none independently required reversal apart from the faulty instructions.

## Legal Principles

- First-degree murder requires proof of “willful, deliberate, and premeditated” killing; second-degree murder involves malice but lacks premeditation and deliberation.
- Premeditation and deliberation are distinct from intent to kill; they require proof that the defendant had an opportunity for, and engaged in, some reflection before the act.
- An instruction that permits premeditation to be established by an intent to kill formed “only for an instant,” or that defines premeditation/deliberation as mere intent, misstates the law and misleads the jury on the element separating murder degrees.
- Jury instructions must correctly state the law, be supported by the evidence, and, read as a whole, must not mislead the jury as to the controlling legal standards.
- Sufficiency review asks whether, viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could find the essential elements proved beyond a reasonable doubt; reversal for insufficiency is reserved for records with no evidentiary basis for guilt beyond a reasonable doubt.

## Conclusion

The court ordered a new trial because the jury was improperly instructed that premeditation could be instantaneous and that an intentional killing is necessarily deliberate and premeditated, thereby removing the meaningful distinction between first- and second-degree murder, while also holding that the evidence could support a first-degree verdict if the jury is correctly instructed.


State v. Guthrie, 194 W. Va. 657, 461 S.E.2d 163 (W. Va. 1995)