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Poehling v. People Citation: Poehling v. People, 24SCWC00002 (2024) Docket No.: 24SCWC00002 Argued: April 13, 2024 Decided: April 15, 2024 Before: San Andreas Supreme Court Advocates: Ambrose Napier, Raymond Scarpati, Jack Blackhawk (for the Appellant), Harper Meyer (for the Respondent) Facts of the case Poehling was a San Andreas Department of Corrections inmate and was detained at the San Andreas State Prison, Los Santos County. He had previously been convicted of financial crimes for which he was serving a life sentence. On February 5, 2024, at 9:42 p.m., Poehling was seen exiting a cell occupied by Charles Morrow, a fellow inmate. In his report, a Correctional Officer described Poehling as "nervous". Poehling reportedly remained in the cell for some time before leaving alone and joining a group of White-Pride affiliated detainees. Moments after, Poehling returned to Morrow's cell and dragged him to the middle of the unit. He then murdered Morrow by repeatedly stabbing him in the neck and body with a makeshift blade, and left it in Morrow's neck. Poehling was immediately arrested and was later indicted by the Los Santos County District Attorney's Office. He was charged with FA. 201, Capital Murder (P.C. § 201d). The trial court determined that he had acted with premeditation and malice aforethought, and considered Poehling's past convictions as an aggravating factor. Poehling was sentenced to the death penalty, but filed an extraordinary appeal before the San Andreas Supreme Court. The Supreme Court agreed to hear the case and granted certiorari on April 7, 2024. Questions (1) Should the tripartite test established in Rozanov v. People, 24GJAP00003 (2024) be considered as binding precedent, and was it designed as a mandatory framework to assist courts in their assessment of evidence supporting an inference that a killing resulted from a "pre-existing reflection" and "careful thought and weighing of considerations" rather than from a "mere unconsidered or rash impulse hastily executed"? (2) Can a trier of fact make reasonable inferences based on speculative assumptions, rather than circumstantial evidence? (3) Did the trial court err when it applied state law but failed to lay its reasoning upon existing, binding precedent from a state higher jurisdiction? Did the trial court err in considering precedents originating from other States and the District of Columbia as binding when it came to interpreting and applying state law? (4) Did the trial court violate the constitutional rights afforded to Poehling when considering his past convictions as an aggravating factor? Conclusion UNANIMOUS DECISION FOR POEHLING MAJORITY OPINION BY HAROLD STEINBACH, J. (1) Yes. The Court affirmed Rozanov and construed its tripartite test as a mandatory framework. Because the inclusion of premeditation in a criminal statute prohibiting murder demonstrated the legislature's intent to require, as an element of the violation, a "substantially greater reflection" than may be found in an intent to kill, premeditation cannot be defined as "malice aforethought". Associate Justice Steinbach, writing for a unanimous court, stated that "malice aforethought is an essential element of the crime of murder . . . but it is not synonymous with the element of premeditation. Otherwise, all murders would be premeditated . . . following the formation of a specific intent to kill. The mere intent to kill is not the equivalent of a premeditated intent to kill." In this case, the Court did not find any "substantial evidence" to support the trial court's finding that the murder had been premeditated. The conviction was thus modified and the degree of the violation reduced to that of second-degree murder. (2) No. A trier of fact can only draw reasonable inferences from circumstantial evidence rather than speculative assumptions. In Poehling's case, the trial court had wrongfully determined that "the use of a makeshift blade by Poehling [indicated] . . . he himself [had] created the blade; spent time crafting it; deliberating, reflecting, and reasoning over killing, proving premeditation". Associate Justice Steinbach wrote: "when we make fantastic leaps like this, without supporting evidence, we are no longer making reasonable inferences from the circumstantial evidence... but writing fairy tales". (3) Yes. The trial court only noted that it was unable to locate Rozanov and could therefore not apply its tripartite test. Instead, the trial court improperly attempted to rely on precedents originating from other jurisdictions while interpreting state law. These jurisdictions were applying other statutes; although the Court did not strictly forbid the use of their precedents as authoritative sources, it held that none of them could have been deemed as binding. Regardless, trial courts must prioritize and apply binding precedent originating from state courts in matters concerning state law. (4) Yes. The Court affirmed Kelley v. People (CFA 006-20) and reiterated that "any court must apply aggravating and mitigating factors prior to handing down a sentence of . . . capital punishment". The trial court had only taken one aggravating factor into consideration during sentencing—the defendant's past convictions for financial felonies. Under longstanding precedent, however, "[an] aggravating circumstance must genuinely narrow the class of persons eligible for the death penalty and must reasonably justify the imposition of a more severe sentence on the defendant compared to others found guilty of murder", see Zant v. Stephens, 462 U.S. 862, 877 (1983) and "if . . . an aggravating circumstance applies to every defendant eligible for the death penalty, the circumstance is constitutionally infirm", see Arave v. Creech, 507 U.S. 463, 474 (1993). Every person tried under San Andreas Penal Code § 201(d) must be serving a life sentence and carries thus prior convictions: felonies. As such, and in the case at hand, the use of prior convictions as an aggravating favor was held by the Court to be unconstitutional.

About S.A. LII ► Publications ► Laws ► Precedents ► Other resources ► Help us out ► Welcome! The San Andreas Legal Information Institute (S.A. LII) is a non-profit organization committed to provide the general public with access to free, popularized legal information. We also allow members of the profession to freely access more specific, relevant and up-to-date sources. Who are we? We are an independent group that promotes open access to law. Our staff, based in Los Santos (SA), consists of legal scholars, lawyers, judges and even students who are fully dedicated to our cause. We are mainly supported by private donations. What are we doing? Why? We strongly believe that, in a democratic society resting upon the rule of law, everyone should be able to fully understand the rules which shape our communities. Honesty, objectivity, accuracy and inclusiveness define us and our beliefs. In carrying out this vision, we: Publish laws, precedents, and other resources. Work with members of the community to release our own publications, including articles and other material designed to offer the general public an intelligible explanation of subjects related to law. How can you help us out? As previously stated, we essentially rely on private donations. If you want to support open access to law, you may consider the following: Donating; Sponsoring our work; Advertising on our website; Contributing to the creation of articles and other material; Promoting us.

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August 3, 2022 10:11 PM Information Detail - DAVIS SHERIFF'S STATION NEWSROOM The Los Santos County Sheriff's Department is seeking public's help in locating critical missing person, Annemarie Stallings The Los Santos County Sheriff's Department is seeking the public's assistance in locating Annemarie Stallings, a 21 year-old female resident of Los Santos County who was last seen on Tuesday, August 2, 2022 at approximatively 1:00 AM. She was last seen meeting some of her friends at Vespucci Beach in the City of Los Santos. She then left, asking to be alone, and subsequently disappeared. Ms. Stallings has been reported as mentally ill, violent and suicidal. Therefore, her disappearance could pose a threat to the general public. The Department is currently trying to locate Ms. Stallings. She is described as 5'4", slim, and has long black hair dyed blond. Also, several tattoos are present around her arms, on her chest and on her head. These all display various controversial symbols. Family members have not heard or seen her since and are concerned for her well-being. Anyone with information about this incident is encouraged to contact the Los Santos County Sheriff's Department, Davis Sheriff's Station, Deputy Sheriff Castaño at (475) 32-107. If you prefer to provide information anonymously, you may also call "Crime Stoppers" by dialing 991. In case of an emergency, please dial 911 immediately. DO NOT APPROACH. JOSEPH CLINE, SHERIFF Damian Suarez, Captain Davis Sheriff's Station Sheriff’s Information Bureau – Newsroom Los Santos County Sheriff’s Department Hall of Justice - First floor 211 Innocence Blvd, Los Santos, SA 90112 Website LSSD HQ: https://www.lssd.org/ Recruitment LSSD: http://www.careers.lssd.org FaceBrowser: @DVSSHERIFF https://face.gta.world/pages/dvssheriff Address/Location LSSD - Davis Station, Los Santos County Sheriff 301 Innocence Boulevard, City of Davis, SA 90220 Contact Emergency: 9-1-1 Non-emergencies: 9-0-1

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August 1, 2022 7:00 PM Newsletters & Events - DAVIS SHERIFF'S STATION NEWSROOM The Los Santos County Sheriff's Department announces safe needle site event The Pillbox Hill Medical Center will temporarily host a safe needle site on August 14, 2022, starting from 9:00 p.m. Personnel assigned to the Davis Sheriff's Station will provide security services to the facility to safeguard peace, tranquility and order for all attendees. Last year, and according to the Centers for Disease Control and Prevention (CDC), no less than 107,622 persons died from a drug overdose in the United States. The Los Santos County Sheriff's Department and its health partner are both willing to avoid such dramatic deaths by offering drug consumers a safe place where appropriate health care will be dispensed to them with no fear of penal consequences. JOSEPH CLINE, SHERIFF Damian Suarez, Captain Davis Sheriff's Station Sheriff’s Information Bureau – Newsroom Los Santos County Sheriff’s Department Hall of Justice - First floor 211 Innocence Blvd, Los Santos, SA 90112 Website LSSD HQ: https://www.lssd.org/ Recruitment LSSD: http://www.careers.lssd.org FaceBrowser: @DVSSHERIFF https://face.gta.world/pages/dvssheriff Address/Location LSSD - Davis Station, Los Santos County Sheriff 301 Innocence Boulevard, City of Davis, SA 90220 Contact Emergency: 9-1-1 Non-emergencies: 9-0-1

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