California, United States of America
The following excerpt is from People v. Pratt, A132470 (Cal. App. 2014):
In People v. Levitt, supra, 156 Cal.App.3d at page 516, the appellate court held that, "notwithstanding the jury's verdicts of manslaughter," there was sufficient evidence to support the trial court's finding of planning and premeditation. The defendant's planning activity "rendered him more culpable than other manslaughterers . . . ." (Ibid.) The same is true here. The fact that defendant planned the killing and its aftermath at least to some degree renders her more culpable than other persons convicted of voluntary manslaughter. There was no error in relying on planning and sophistication as an aggravating circumstance.
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