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Any type of murder that does not meet the legal definition for manslaughter can/will be considered premeditated. Involuntary Manslaughter occurs where there is no intention to kill or cause serious injury but death is due to recklessness or criminal negligence. Murder occurs when there is a preplanned process of events, set in motion by an individual of sufficient mental capacity. So to answer the question; any method of murder will be seen as premeditated.

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Q: What method of murder is always charged as premeditated?
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