P. v. Vanbatenburg
A jury convicted William Vanbatenburg of the first degree murder of Beverly Snellings. The jury also found true, as a special circumstance, that the murder was committed by means of lying in wait. Based on this verdict, the trial court sentenced Vanbatenburg to life in prison without possibility of parole. On appeal Vanbatenburg argues that the lying in wait special circumstance must be reversed because it is not supported by sufficient evidence and because the phrase by means of lying in wait as used in the special circumstance statute is unconstitutionally vague on its face and as applied. Court find no merit to these arguments and affirm the judgment.
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