What evidence supports a finding of premeditation and deliberation for first degree murder?

The People presented ample evidence that, if believed, established a brutal killing that took time and effort to accomplish. There was evidence that defendant harmed Houston in multiple ways, all of them brutal beyond a degree of harm that would have simply ended her life. The evidence showed strangulation as well as multiple instances of both sharp force and blunt force trauma, inflicted over a substantial period of time. Each time defendant employed a different mode of violence, he evinced a new commitment to his homicidal objective. (See People v. Perez (1992) 2 Cal.4th 1117, 1127-1128 ["Some period of time necessarily must have elapsed between the first and second set of wounds. While this conduct, in itself, may not necessarily support a finding of premeditation, in conjunction with the manner of killing, it could easily have led the jury to infer premeditation and deliberation"].)

Further, the evidence of the type, severity, and number of wounds on Houston's body contradicted defendant's assertions that the trauma to Houston's neck was self-inflicted and that the bruises on her face and body resulted from a fall off the bed and convulsions on the floor, all within a five to 10 minute time period. (See People v. Turner, supra, 50 Cal.3d at pp. 688-689, fn. 4.) The evidence provided by the People's expert regarding the amount of time it took to inflict all of Houston's injuries (at least one hour, probably more) and to strangle her to death (several minutes) also supports a finding of premeditation. (See People v. Hovarter (2008) 44 Cal.4th 983, 1019-1020 [evidence that the victim "was strangled with a rope and that her death from asphyxiation would have taken between five and eight minutes" permitted a rational factfinder to infer that the manner of killing demonstrated deliberation, as such a "prolonged manner of taking a person's life, which requires an offender to apply constant force to the neck of the victim, affords ample time for the offender to consider the nature of his deadly act"]; People v. Davis (1995) 10 Cal.4th 463, 510 [sufficient evidence of premeditation and deliberation for first degree murder where, among other facts, defendant strangled the victim for "over a period of up to five minutes" (italics omitted)].)

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