State v. Schurz

In State v. Schurz, 176 Ariz. 46, 55 n.5, 859 P.2d 156, 165 n.5 (1993), the Court observed in passing that "in addition to intention or knowledge, premeditation requires reflection." Thus, notwithstanding the statute's narrower definition of premeditation as solely the passage of time, the Court continued to treat premeditation as also including the act of reflection in addition to the passage of time.