How have courts interpreted deliberation and premeditation in cases where a defendant shot a police officer in the head with a single shot?

may follow each other with great rapidity and cold, calculated judgment may be arrived at quickly.' " ' " (People v. Sanchez (2001) 26 Cal.4th 834, 849.)

The case law is replete with examples of deliberation and premeditation occurring during a short period of time. In People v. Mayfield (1997) 14 Cal.4th 668,⁵ where the defendant wrested a gun from a police officer and shot the officer in the head during a brief altercation, it was held that "a rational trier of fact could conclude from the evidence that before shooting [the officer] defendant had made a cold and calculated decision to take [his] life after weighing considerations for and against." (Id. at pp. 767-768.) Likewise, in People v. Mendoza (2011) 52 Cal.4th 1056 (Mendoza), the high court found sufficient evidence of premeditation under circumstances where the defendant killed his victim within a few minutes of their initial encounter. (Id. at p. 1069-1074.) The Mendoza opinion also notes that a single gunshot to the head can support the inference of a deliberate intent to kill. (Id. at p. 1071.)