In Santos v. State, 591 So. 2d 160 (Fla. 1991), the defendant murdered his former girlfriend and their infant daughter after numerous domestic disturbances between the parents. See 591 So. 2d at 160. The Supreme Court of Florida held that the fact that the killing arose from a domestic dispute tended to negate cold, calculated premeditation. Id. at 162. Further, this Santos interpretation is undermined by Lynch v. State, 841 So. 2d 362 (Fla. 2003). Twelve years after the Santos decision, this Court made it clear in Lynch that it "does not recognize a domestic dispute exception in connection with death penalty analysis." Id. at 377.