This statement is true because premeditation does not necessarily require a lengthy period of planning or preparation. Courts generally interpret premeditation as the formation of a specific intent to kill, which can occur in a very short time, provided the defendant reflected on the decision, even if briefly. Deliberation, which involves a calm and measured weighing of the decision, is related but not synonymous. The common misconception is that premeditation demands a prolonged, detailed plan, which is incorrect. On the other hand, if the killing occurs as a purely impulsive act or during an uncontrollable emotional outburst (for example, due to adequate provocation), premeditation is generally lacking.
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