Is Proving Premeditation of Murder Using Circumstantial Evidence Possible ?

In Holton v. State, 573 So. 2d 284, 289 (Fla. 1990), this Court held that the circumstantial evidence presented by the State was sufficient to support a jury finding of premeditation and a verdict of first-degree murder. Holton, 573 So. 2d at 289. The victim in Holton was found with a ligature securely tied around her neck. Id. The medical examiner determined that death was caused by strangulation. Id. Scratch marks on the defendant's chest indicated the victim had struggled during the attack. Id. The victim's house had been burned, presumably to conceal the crime. Id. This Court held that the evidence was sufficient to prove premeditation. "Because the circumstantial evidence standard does not require the jury to believe the defense version of facts on which the state has produced conflicting evidence, the jury properly could have concluded that Holton's version of the facts was untrue." Id. at 290.