## Facts

- Lawrence C. Ollens was charged with aggravated first-degree murder arising from the robbery and stabbing death of William Tyler, a Tacoma taxicab driver, on November 9, 1985.
- At a pretrial evidentiary review, the State relied primarily on the medical examiner’s testimony about the victim’s wounds and their sequence.
- The victim died from multiple stab wounds and blood loss, including potentially fatal wounds to the heart/lung and to the liver area, plus a stab wound to the thigh.
- The victim’s throat was slit, creating an approximately six-inch gash that required more than one motion and nearly severed major structures; the examiner indicated the stab wounds occurred before the throat cutting.
- The examiner testified the victim could have remained alive and struggling for 2–3 minutes after the neck wound.
- The victim had numerous defensive wounds indicating a struggle while he was alive.
- The State also proffered a witness who would testify that Ollens admitted he killed the victim after the victim appeared to reach for a weapon, and that Ollens cut him because he believed it was “either the man’s life or his.”
- Relying on a reading of prior precedent, the trial court dismissed the aggravated first-degree murder charge for insufficient evidence of premeditation; the State appealed.

## Issues

1. Whether, viewing the evidence most favorably to the State, a rational trier of fact could find premeditation beyond a reasonable doubt such that the aggravated first-degree murder charge could proceed to the jury.

## Decision

- The Washington Supreme Court reversed the pretrial dismissal of the aggravated first-degree murder charge.
- The court held the State’s evidence was sufficient to permit a jury to find premeditation beyond a reasonable doubt.
- The case was remanded for further proceedings.

## Legal Principles

- In reviewing sufficiency at a pretrial stage, the court asks whether any rational trier of fact could find the challenged element beyond a reasonable doubt when the evidence is viewed in the light most favorable to the State.
- Premeditation requires a mental process of deliberation or reflection, however brief, and may be proved by circumstantial evidence.
- Premeditation may be inferred from the manner of killing and surrounding circumstances; no categorical rule bars inference of premeditation from multiple wounds or method of attack.
- A killing involving multiple distinct acts with a weapon, including sequential stabbing and a separate throat-slashing act, may provide a basis for inferring opportunities for reflection and renewed intent.
- Prior precedent addressing a single continuous act (such as manual strangulation) does not control cases involving distinct, successive acts using a weapon.

## Conclusion

The court held that the sequence and number of knife attacks, the separate throat-slashing act, evidence of a struggle, and related circumstances provided enough evidence for a jury to decide premeditation, making pretrial dismissal of the aggravated first-degree murder charge improper.


State v. Ollens, 107 Wash. 2d 848, 733 P.2d 984 (1987)