California, United States of America
The following excerpt is from People v. Olivarez, D058082, Super. Ct. No. RIF129919 (Cal. App. 2011):
p. 204.) Lying-in-wait first degree murder " 'requires only a wanton and reckless intent to inflict injury likely to cause death.' " (People v. Poindexter (2006) 144 Cal.App.4th 572, 580, fn. 10.)
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