State v. HinrichsenAnnotate this Case
After a jury trial, Defendant was convicted of two counts of first degree murder. The trial court sentenced Defendant to terms of life-to-life imprisonment for each murder conviction. Defendant appealed, arguing, primarily, that because sudden quarrel provocation negates the malice element of murder, the step instruction for first degree murder violated his due process rights because the jury was not instructed that the State had to prove that the killings were not the result of a sudden quarrel brought about by a sufficient provocation. The Supreme Court affirmed the convictions and sentences, holding (1) when the jury found beyond a reasonable doubt that Defendant acted with premeditated and deliberate malice, the jury necessarily simultaneously found no sudden quarrel provocation beyond a reasonable doubt; and (2) Defendant’s remaining arguments lacked merit.