California, United States of America
The following excerpt is from People v. Shaw, E053697 (Cal. App. 2013):
murder typically when there is evidence of all three types and otherwise requires at least extremely strong evidence of [planning] or evidence of [ motive] in conjunction with [evidence of] either [planning] or [manner of killing].' [Citations.]" (People v. Halvorsen (2007) 42 Cal.4th 379, 419-420.)
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