In a case in which appellant was convicted, following a jury trial, of first-degree murder (Pen. Code, § 187), the Court of Appeal found that the finding of premeditation and deliberation lacked substantial evidence, and accordingly reduced the murder to second degree. While the Court noted that there was some evidence of motive, the Court explained that was insufficient to support the verdict considering the lack of evidence showing any planning and the manner of killing not evidencing premeditation.