California, United States of America
The following excerpt is from People v. Dapremont, B299366 (Cal. App. 2020):
2. There is an exception to this general rule for "execution-style" murders, such as when the victim is found lying in a ditch in an open field with gunshot wounds to the back of the head. (See, e.g., People v. Hawkins (1995) 10 Cal.4th 920, 956-957.) In such cases, evidence of "manner" alone may be sufficient. But this exception is not applicable here.
3. Note that this is a distinct crime from murder by torture criminalized at section 189, subdivision (a). "Murder by torture requires (1) an act or acts causing death that involve a high degree of probability of death, (2) a causal relationship between the torturous act and death, (3) a willful, deliberate, and premeditated intent to inflict extreme and prolonged pain on a person for the purpose of revenge, extortion, persuasion, or for any other sadistic purpose, and (4) commission of the act or acts with such intent." (People v. Edwards (2013) 57 Cal.4th 658, 715-716.)
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