An impulsive overreaction during a sudden, volatile domestic crisis is not the “ill will, hatred, spite, or evil intent” that second-degree murder requires. The First District Court of Appeal reversed a second-degree murder conviction and ordered a manslaughter judgment entered instead.
Matthew Peoples shot his sister’s intoxicated, aggressive boyfriend during a domestic confrontation; the two men had no prior animosity and had gone camping together a week earlier. Peoples argued the State failed to prove the depraved-mind element distinguishing second-degree murder from manslaughter.
Viewing the evidence in the light most favorable to the State, the panel found it showed “an impulsive overreaction to a perceived threat,” not the depravity second-degree murder demands. It reversed and remanded for entry of a conviction for the lesser-included offense of manslaughter with a firearm and resentencing. A second argument, about marijuana evidence, was rejected as unpreserved and meritless.
**Why it matters:** the depraved-mind element is a real limit on second-degree murder. Where the killing reflects a sudden, impulsive reaction rather than enmity, manslaughter — not second-degree murder — is the proper conviction.
*Peoples v. State, No. 1D2025-2335 (Fla. 1st DCA Sept. 2, 2026).*