Duhaime's Law Dictionary

Complicated Design Evidence Definition:

Circumstantial proof of deliberation in a first degree murder case, that in the absence of evidence of planning, the complicated manner of the crime shows that the murder could not have been spur-of-the-moment.

Related Terms: First Degree Murder, Deliberate

In State v Miller, Justice Robert Ulrich of the Missouri Court of Appeals provided a complete summary of the criminal law as regards first degree murder, the necessary element of deliberation and the relevance of complicated-design evidence:

"A person commits the crime of murder in the first degree if he knowingly causes the death of another person after deliberation upon the matter. Deliberation required for conviction for murder in the first degree is defined as cool reflection for any length of time no matter how brief. The deliberation necessary to support a conviction of first-degree murder need only be momentary; it is only necessary that the evidence show that the defendant considered taking another's life in a deliberate state of mind. A deliberate act is a free act of the will done in furtherance of a formed design to gratify a feeling of revenge or to accomplish some other unlawful purpose and while not under the influence of violent passion suddenly aroused by some provocation. Deliberation may be inferred from the circumstances surrounding the murder.

"Absent a confession by the actor that reveals his or her intent, a person's mental state can be known only through the person's actions. Evidence of a person's conduct raises inferences that point toward or away from a conclusion that the person possessed a culpable mental state. Evidence of conduct that is relevant to the issue of deliberation in a first degree murder case falls into a least four broad categories.

"First, there may be direct evidence that the defendant did or said certain things in advance of the act to facilitate the crime. This is planning evidence.

"Second, there may be evidence of a pre-existing relationship between the victim and the defendant prior to the murder that provides a motive for the killing. This is bad-blood evidence.

"Third, there may be no direct evidence of planning, but the complicated manner in which the defendant carried out the crime shows that the murder could not have been committed as a result of a spur-of-the-moment decision to act. This is complicated-design evidence.

"Fourth, there may be evidence that the defendant failed to take action that a person who did not possess a guilty mind would be expected to take. Most often this conduct occurs after the crime is committed. This is failure-to-act evidence."


  • State v. Miller, 220 SW 3d 862 (2007)
  • State v. Roberts, 948 SW 2d 577 (Supreme Court of Missouri, 1997)

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