They began dating and exchanged gifts, phone calls, and love letters. MO Rev Stat 565.021 (2016).
crime OK Stat 21-701.7. In response to this ruling, the Pennsylvania General Assembly amended the definition of the crime in 2011 to reclassify it as general criminal homicide rather than specifically as third-degree murder, thus removing the requirement of malice.
Reasons to Oppose "3 Strikes, You're Defense attorney Jim Griffin delivers closing arguments on Thursday. A charge of manslaughter does not require specific intent to kill, while murder does. During the 1940s and 1950s, it was employed as a defence in murder trials. Access Arrest Records & Criminal Records. You have successfully registered for the webinar. WebAn included crime may be any of the following: (1) A crime which does not require proof of any fact in addition to those which must be proved for the crime charged. This is simple: the District of Columbia must be allowed to govern itself. In the case of a crime of passion, courts usually reduce the sentence that they give, from murder to manslaughter. When a murder is carried out in the heat of passion, it lacks premeditation and is performed voluntarily, making it voluntary manslaughter. He left them and promised to pick them up after the show.
Heat of Passion "Aggravated murder" defined.
DC conflict reflects wider efforts undermining local control AZ Rev Stat 13-1104.
crime law When a murder is committed in the heat of passion, it is done without premeditation, effectively reducing it to voluntary manslaughter. A crime of passion is not a planned and intentional crime. [115] A defense of diminished capacity may reduce first-degree murder to third-degree murder. Nanavati vs. the State of Maharashtra, 1962, http://indpaedia.com/ind/index.php/Crimes_of_passion:_India, Detailed analysis and lessons for India from the Australian Cartel case involving ANZ, Deutsche Bank and Citigroup, The most notorious serial killers in India. MT Code 45-5-102 (2017). For example, the 1849 Revised Statutes defined third-degree murder as a killing "perpetrated without any design to effect the death, by a person engaged in the commission of any felony". It states that culpable homicide is not murder if it is done without premeditation in the heat of passion during a sudden fight and without the offenders taking undue advantage or acting in a cruel or unusual manner, regardless of who started the first assault. A crime of passion doesnt always involve love and desire.
Environmental Crimes DE Code 634 Murder by abuse or neglect in the first degree; class A felony; 636 Murder in the first degree; class A felony. In Michigan, the top penalty the perpetrator can receive is life imprisonment. VA Code 18.2-31. Mr. Paul L. Whitfield (Unclaimed Webact by a sudden heat of passion caused by provocation recognized by law, and before there had been a reasonable time for the passion to cool and for reason to reassert itself. Premeditated crime is a type of crime committed while holding a grudge. Second degree murder in California carries a 15 to life sentence while voluntary manslaughter carries a maximum sentence of 11 years in State Prison. Both the conspirator and the murderers were given life imprisonment. Crime Of Passion Law California. A violent pub-goer who hits another person after an argument, or a wife who finds her husband is having an affair and attacks or murders him or his lover is an example of a crime of passion. NY PEN 125.25. Murder in the first degree. Most likely. It depends on what the divorce settlement gives her. If she gets to cheat on me and still gets EVERYTHING, she goes in the ground. And This is one of the preventative factors recognised by the legal system when a murder sentence is reduced to voluntary manslaughter. Naina Sahni (wife) was killed by her spouse, Sushil Sharma, in this Tandoor murder case. Consider reading the above if you want to know what does the crime of passion mean. States have adopted several different systems for classifying murders by degree.
crime law DC Code 222103. When a crime of passion happens, the defendant pleads a provocation defence in order to reduce the charges severity. MN Statutes 609.195 Murder in the third degree. 125.25 Murder in the second-degree", "Alabama Code Title 13A (Criminal Code), Chapter 6 (Offences Involving Danger to the Person), Article 1 (Homicide)", "Alaska Statutes Title 11 (Criminal Law), Chapter 41 (Offenses Against the Person), Article 1 (Homicide)", "American Samoa Code Annotated, Title 46 (Criminal Justice), Chapter 35 (Offenses Against the Person)", "Arizona Revised Statutes Title 13 (Criminal Code), Chapter 11 (Homicide)", "Arkansas Code Title 5 (Criminal Offenses), Subtitle 2 (Offenses Against The Person), Chapter 10 (Homicide)", "California Penal Code, Part 1 (Of Crimes and Punishments), Title 8 (Offenses Against the Person), Chapter 1 (Homicide)", "Colorado Revised Statutes, Title 18 (Criminal Code), Article 3 (Offenses Against the Person), Part 1 (Homicide and Related Offenses)", "Connecticut General Statutes, Title 53a (Penal Code), Chapter 952 (Penal Code: Offenses), Part VI (Homicide)", "Delaware Code, Title 11 (Crimes and Criminal Procedure), Chapter 5 (Specific Offenses), Subchapter II (Offenses Against the Person), Part B (Acts Causing Death)", "Code of the District of Columbia, Title 22 (Criminal Offenses and Penalties), Chapter 21 (Murder; Manslaughter)", "Florida Statutes 2017, Title XLVI (Crimes), Chapter 782 (Homicide)", "Georgia Code, Title 16 (Crimes and Offenses), Chapter 5 (Crimes Against the Person), Article 1 (Homicide)", "Guam Code Annotated, Title 9 (Crimes & Corrections), Chapter 16 (Criminal Homicide)", "Hawaii Revised Statutes, Division 5 (Crimes and Criminal Proceedings), Title 37 (Hawaii Penal Code), Chapter 707 (Offenses Against the Person), Part II (Criminal Homicide)", "Idaho Statutes, Title 18 (Crimes and Punishments), Chapter 40 (Homicide)", "(720 ILCS 5/) Criminal Code of 2012, Title III (Specific Offenses), Part B (Offenses Directed Against the Person), Article 9 (Homicide)", "Indiana Code, Title 35 (Criminal Law and Procedure), Article 42 (Offenses Against the Person), Chapter 1 (Homicide)", "Iowa Code 2018, Title XVI (Criminal Law and Procedure), Chapter 707 (Homicide and Related Crimes)", "Kansas Statutes, Chapter 21 (Crimes and Punishments), Article 54 (Crimes Against Persons)", "2017 Kentucky Code, Title L (Kentucky Penal Code), Chapter 507 (Criminal Homicide)", "Louisiana Revised Statutes, Title 14 (Criminal Law), Part II (Offenses Against the Person), Subpart A (Homicide)", "Maine Revised Statutes, Title 17-A (Maine Criminal Code), Chapter 9 (Offenses Against the Person)", "2016 Maryland Code, Criminal Law, Title 2 (Homicide), Subtitle 2 (Murder and Manslaughter)", "Massachusetts General Laws, Part IV (Crimes, Punishments and Proceedings in Criminal Cases), Title I (Crimes and Punishments), Chapter 265 (Crimes Against the Person), Section 1 (Murder Defined)", "Michigan Compiled Laws, Chapter 750 (Michigan Penal Code), Chapter XLV (Homicide)", "2017 Minnesota Statutes, Chapter 609 (Criminal Code)", "2016 Mississippi Code, Title 97 (Crimes), Chapter 3 (Crimes Against the Person)", "Missouri Revised Statutes, Title XXXVII (Crimes and Punishment; Peace Officers and Public Defenders), Chapter 565 (Offenses Against the Person)", "Montana Code Annotated 2017, Title 45 (Crimes), Chapter 5 (Offenses Against the Person), Part 1 (Homicide)", "2017 Nebraska Revised Statutes, Chapter 28 (Crimes and Punishments)", "Nevada Revised Statutes, Title 15 (Crimes and Punishments), Chapter 200 (Crimes Against the Person), Part 1 (Homicide)", "New Hampshire Statutes, Title LXII (Criminal Code), Chapter 630 (Homicide)", "New Jersey Statutes, Title 2A (The New Jersey Code of Criminal Justice), Chapter 11", "2016 New Mexico Statutes, Chapter 30 (Criminal Offenses), Article 2 (Homicide)", "New York Penal Code, Part 3 (Specific Offenses), Title H (Offenses Against the Person Involving Physical Injury, Sexual Conduct, Restraint and Intimidation), Article 125 (Homicide, Abortion and Related Offenses)", "North Carolina General Statutes, Chapter 14 (Criminal Law)", "North Dakota Code, Title 12.1 (Criminal Code), Chapter 12.1-16 (Homicide)", "Commonwealth Code, Title 6 (Crimes and Criminal Procedure), Division 1 (Crimes Against the Person), Chapter 1 (Homicide)", "Oklahoma Statutes 2017, Title 21 (Crimes and Punishments)", "2017 Oregon Revised Statutes, Volume 04 (Criminal Procedure, Crimes), Chapter 163 (Offenses Against Persons)", "Pennsylvania Consolidated Statutes, Title 18 (Crimes and Offenses), Article B (Offenses Involving Danger to the Person), Chapter 25 (Criminal Homicide)", "Rhode Island General Laws, Title 11 (Criminal Offenses), Chapter 11-23 (Homicide)", "South Carolina Code of Laws, Title 16 (Crimes and Offenses), Chapter 3 (Offenses Against the Person), Article 1 (Homicide)", "South Dakota Codified Laws, Title 22 (Crimes), Chapter 22-16 (Homicide and Suicide)", "2016 Tennessee Code, Title 39 (Criminal Offenses), Chapter 13 (Offenses Against the Person), Part 2 (Criminal Homicide)", "Texas Penal Code, Title 5 (Offenses Against the Person), Chapter 19 (Criminal Homicide)", "Utah Code, Title 76 (Utah Criminal Code), Chapter 5 (Offenses Against the Person), Part 2 (Criminal Homicide)", "2017 Vermont Statutes, Title 13 (Crimes and Criminal Procedure), Chapter 53 (Homicide)", "Code of Virginia, Title 18.2 (Crimes and Offenses Generally), Chapter 4 (Crimes Against the Person), Article 1 (Homicide)", "Revised Code of Washington, Title 9A (Washington Criminal Code), Chapter 9A.32 (Homicide)", "West Virginia Code, Chapter 61 (Crimes and Their Punishment), Article 2 (Crimes Against the Person)", "Wisconsin Statutes, Chapter 940 (Crimes Against Life and Bodily Security), Subchapter 1 (Life)", "2016 Wyoming Code, Title 6 (Crimes and Offenses), Chapter 2 (Offenses Against the Person), Article 1 (Homicide)", "President Bush Signs Unborn Victims of Violence Act of 2004", "13-1105 First-degree murder; classification", "Florida Statutes, Sec. UN Women has urged states to review legal defences of passion and provocation, as well as other similar laws, to ensure that they do not lead to impunity in cases of violence against women, stating that such laws These defences should be stated clearly in laws that do not include or apply to crimes of honour, adultery, domestic assault, or murder. SD Codified Laws 22-16-7. NV Rev Stat 200.030. 125.27 Murder in the first-degree", "New York Penal Code, Sec. State Sen. Tom Brewer of Gordon renewed his effort Wednesday March 1, 2023, to get a "constitutional carry" gun bill passed in Nebraska. (b) Criminal homicide is murder, capital murder, manslaughter, or criminally negligent homicide. A sudden passion is described as a state of mind caused by and growing out of a trigger with the victim; occurring in the middle of a fight and not dependent on a previous fight, according to the Indian Penal Code, 1860.
Second Degree Murder Overview - FindLaw This article is written by Michael Shriney from the Sathyabama Institute of Science and Technology. Murder in the second degree. NH Statutes 630:1-b. UT Criminal Code 202.
Bostons COVID data continues to show encouraging signs Murder in the first degree; penalty. DC Code 222101. TN Code 39-13-202. Boston is continuing to report falling trends for several key COVID metrics, an encouraging sign as state health officials on Thursday reported a 13% drop in new virus cases. Murder of unborn child", "18 PA Cons Stat 1102. In 1956, Agniks, a mutual friend of Nanavati and Prem Ahuja, died (victim). He entered a teen chat group posing as a young, attractive Iraq-bound Marine and played the popular game Pogo. He pretended to be an 18-year-old kid when a girl called Talhotblond on her account started instant-messaging him. [12], The first division of the general crime of murder into graded subcategories was enacted into the law of Pennsylvania in 1794. (Paul Hammel/Nebraska Examiner) People are also reading MI Compiled Laws 750.316 First degree murder; penalty; definitions.
Crime of Passion Law and Legal Definition | USLegal, Inc. All Rights Reserved. The Elements of a Crime of Passion WebAnd in the year 2002, I obtained a Bachelor of Science in Mathematics from Oklahoma State University. Passion is a defense to some crimes, or will result in a lower crime or sentence. WebIn U.S. v. Browner, the Fifth Circuit defined heat of passion as a passion of fear or rage in which the defendant loses his normal self-control as a result of circumstances that would Rep. Pramila Jayapal, a Washington Democrat, is deeply disappointed in Bidens decision. [8], The federal Unborn Victims of Violence Act, enacted in 2004 and codified at 18 U.S. Code 1841,[9] allows for a fetus to be treated as victims in crimes. The state of Hawaii has no death penalty. The Tenth Circuit in the aforementioned case of Visinaiz defined heat of passion as such a state of passion, or hot blood, or rage, anger, resentment, terror or fear as to indicate the absence of deliberate design to kill or as to cause one to act on impulse without reflection. First and second degree murder defined; punishment. [113], Third-degree murder was introduced to Pennsylvania law in a 1974 amendment, at the same time as second-degree murder was redefined as felony murder; prior to that, second-degree murder had been defined as any murder not a first-degree murder. Murder in the first degree, MD Code 2-204. OR Rev Stat 163.115 - Murder; affirmative defense to certain felony murders; sentence of life imprisonment required; minimum term. Murder in the first-degree is a class A felony in the state of Washington. Posted on March 2, 2023 by Constitutional Nobody. Third-degree murder and third-degree murder of an unborn child are punishable by a maximum of 40 years' imprisonment. First degree murder, penalty person under eighteen years of age, penalty.
Vermont bishop testifies against clergy reporting bill - ABC News Crimes of Passion: The Definition, History, and Laws The Tenth Circuit in the aforementioned case of Visinaiz defined heat of passion as such a state of passion, or hot blood, or rage, anger, resentment, terror or fear as to indicate the absence of deliberate design to kill or as to cause one to act on impulse without reflection. Mitigated deliberate homicide.
Closing arguments continue in the Alex Murdaugh trial Initially, Ahuja and Sylvia had a friendly connection that evolved into an illicit intimate relationship. First Degree Murder", "MN Stat 609.195. His daughter became aware of the chat and affair of her father, and she alerted her mother. Following Nanavatis return from work, Sylvia changed her behaviour, becoming indifferent and unresponsive toward him. If the jury or judge is considering
Biden says he'll sign bill blocking D.C. criminal law overhaul Murder of the first degree. WebWith experiences that include programs within the United Nations and shadowing lawyers, I have a strong passion for the law field and am seeking to find a legal internship for the summer of 2023. Under it, murder is any killing committed purposely and knowingly, manslaughter is any killing committed as a result of recklessness, and negligent homicide is any killing resulting from negligence.
of Passion Law and Legal Definition Nanavati, regularly left Bombay on his ship, leaving his wife and children at home. [119] The 1956 Criminal Code in 940.03 defined third-degree murder as causing the death of another "in the course of committing or attempting to commit a felony as a natural and probable consequence of the commission of or attempt to commit the felony", and provided that the sentence for the underlying felony could thus be extended by 15 years. President Biden said Thursday he would sign a GOP-led resolution to block changes to Washington, D.C.'s local criminal code that reduce maximum penalties for some violent crimes. (Paul Hammel/Nebraska Examiner) People are also reading Federal penalties will apply if found guilty. arrangement has been made a general five-year statute of limitations covers all other federal crimes.11 Some of the exceptions to the general rule identify longer periods for particular crimes.12 Others suspend or extend the applicable period under certain circumstances such as the flight of the accused,13 14or during time of war. "Statistical Abstract of the United States", "Felony Defendants in Large Urban Counties, 2002", "Nebraska Bans Death Penalty, Defying a Veto", "The Death Penalty in 2019: Year End Report", "18 U.S. Code 1841 Protection of unborn children", "U.S. Code: Title 18 Crimes and Criminal Procedure", "Koon v. United States, 518 US 81, 116 S. Ct. 2035, 135 L. Ed. [14] By 1953 three statesnamely Florida, Minnesota, and Wisconsinhad further created the subcategory of third-degree murder.[15]. When emotions take control, people may react emotionally rather than listening to the reasonable voice in their brain that tells them what they are about to do is wrong. I am aware of no state which exonerates an otherwise criminal act because it was done in passion. Proving that a criminal act was done in passion m In the United States, the law for murder varies by jurisdiction. Premeditated crime is an intentional crime.
It is as terrible as homicide, with the culprit acting on uncontrollable anger and impulse. Montgomery was later charged for Brian Barretts murder and pleaded for guilty. Five states Arkansas, Indiana, South Carolina, Utah, and Wyoming do not have anti-hate crime laws. The benefit of eliminating State Sen. Tom Brewer of Gordon renewed his effort Wednesday March 1, 2023, to get a "constitutional carry" gun bill passed in Nebraska. [85], In Arizona, a person is charged with murder when the offender knowingly and intentionally causes the death of a person or unborn child. WY Code 6-2-101. WebHeat of Passion Law and Legal Definition. [83] Remedies were limited to criminal penalties for the assault on the mother and tort action for loss of the anticipated economic services of the lost child, for emotional pain and suffering, or both. Boston is continuing to report falling trends for several key COVID metrics, an encouraging sign as state health officials on Thursday reported a 13% drop in new virus cases. The trial of India's first upper-class "crime of passion" - a gripping tale of love and honour - had enough twists and turns, leading to an unexpected pardon for the naval officer. Involuntary manslaughter is punished less severely than other forms of homicide but still is a serious crime. In either jurisdiction, MI Compiled Laws 750.317 Second degree murder; penalty. WebThe essential prerequisites for such a reduction are that the accused must be provoked to a point of great anger or rage, such that the person loses his or her normal capacity for self-control; the circumstances must be such that a reasonable person, faced with the same degree of provocation, would react in a similar manner; and finally, there Premeditated crimes have been committed with malicious intentions. Murder in the second degree. GU Code 16.30. 399, Sec. Vermont's leading Roman Catholic bishop testified Friday against a bill that would remove an exemption to the states child abuse and neglect reporting laws for MN Statutes 609.19 Murder in the second degree.
Bidens about-face on the DC crime law angers Democrats California has developed standards that include a subjective factor. A crime of passion is a murder committed on the spot without a second thought. He confessed to the nearby police station. The murder must be premeditated. Nanavati had the burden of establishing that it was an accident rather than a culpable homicide raised in the High Court. The punishment was life imprisonment given by the Delhi High Court. You can click on this link and join: Follow us onInstagramand subscribe to ourYouTubechannel for more amazing legal content. Murder in the first degree. Crimes of passion are decided to commit in the heat of passion. WebCrime of passion is a criminal defendant's excuse for lacking the premeditation element of a crime due to sudden anger or heartbreak. WebFrom an early time in Anglo-American common law, such killings have been treated differently from the meditated variety. A history of sexual abuse, assault, or conflict between the offender and the victim; The previous acts of violence that may have been quieted by the family; A background of professional and personal functioning that can remove the false impression that such violence is foreign or new to the character of the person involved; Anger and threats are a past impact as a habitual response to lifes conflicts; The crime of passion is committed in the heat of agony, at random and unexpectedly.
crime law [106][107] Both third-degree murder and third-degree murder of an unborn child are punishable by a maximum of 25 years' imprisonment. Murder in the first degree. Second-degree murder. Murder in the second degree. In many US jurisdictions there is a hierarchy of acts, known collectively as homicide, of which first-degree murder and felony murder are the most serious, followed by second-degree murder and, in a few states, third-degree murder, followed by voluntary manslaughter and involuntary manslaughter [13] This enactment is often explained in terms of a desire to narrow the scope of application of capital punishment in that state and in the other states which subsequently graded murder into "first" and "second" degrees. Sharma was sentenced to life in jail under the Code of Criminal Procedure after his case was appealed to the Supreme Court. The incident took place in their Delhi residence. This frequently occurs in murder or attempted murder cases, when a spouse or a lover discovers his or her beloved having sexual relations with someone else and shoots or stabs one or both the coupled pair. They have three children from their marriage: a nine-and-a-half-year-old boy, a five-and-a-half-year-old girl, and a three-year-old boy.
Crime of Passion 940 than the one charged. Murder in the second degree; penalty. [102][107], In Nevada, first-degree murder is the unlawful killing of a human being with malice aforethought, either expressed or implied. The Model Penal Code classifies homicides differently, without degrees.
Excusable Homicides: Understanding Crimes of Passion In U.S. v. Visinaiz, it was held that in order to satisfy the element of malice aforethought in a murder prosecution, the government must prove the absence of heat of passion beyond a reasonable doubt. Paternal jurisdiction over family members was abolished once the Napoleonic Code was modified in the 1970s, decreasing the number of cases where crime passionnel could be charged. The court interpreted it to fall under the fourth exemption to Section 300. 1, eff. This is called felony murder. DISCLAIMER: You may not use our service or the information it provides to make decisions about consumer credit, employment, insurance, tenant screening, or any other purpose that would require Fair Credit and Reporting Act (FCRA) compliance. This carries a penalty of imprisonment for up to five years; but if the act is committed by the caretaker of a child Open Navigation National Crime Victim Law Institute Open search Click on the state below to view its current victims rights laws. Arkansas, South Carolina and Wyoming are the only states without hate crime statutes. Kiran Bedi highlighted that crimes of passion have been committed in India and that prisons are full of women and men who have committed these crimes, such as throwing acid on a woman after being rejected to love someone with the intention to hurt her. Advertisement Most states have vandalism laws, but only 19 prohibit cross burning. The local ordinance's passage followed two decades of efforts to redo D.C.'s crime laws. First-degree intentional homicide. There are other specific guidelines, for example, the killing of a police officer or firefighter is an automatic first-degree charge, and intent to kill more than one person is automatically a first-degree charge.
Wisconsin Legislature: 939.645 The information contained in this website may be out of date, or may contain errors or omissions. AS Code 46.3502. [1], Sentencing also varies widely depending upon the specific murder charge. [9], If murder is committed within the borders of a state, that state has jurisdiction, and in a similar way, if the crime is committed in the District of Columbia, the D.C. Superior Court (the equivalent of a state court in the District) retains jurisdiction, though in some cases involving U.S. government property or personnel, the federal courts may have exclusive jurisdiction.[10]. Otherwise, it is considered a Class 4 felony.
Crime of Passion - Definition, Examples, Cases, Processes It's also important to note that an individual can be found guilty of felony murder even if they didn't personally kill anyone. NH Statutes 630:1-a. NE Rev Stat 28-303 (2017). In the state of California, a crime of passion is defined as an act of violence that is committed in the heat of the moment, in Murder in the second degree. [98][99] A first-degree murder involves one or more specific elements: Louisiana states homicide in the third-degree is manslaughter. She enclosed a family photo with a note informing Jessi that she was talking with a 46-year-old man.
law (a) A person commits criminal homicide if he intentionally, knowingly, recklessly, or with criminal negligence causes the death of an individual. Then one day, Brian planned to meet Jessi at her house, which Montgomery was aware of. So he went straight to his flat and into his bedroom. On this Wikipedia the language links are at the top of the page across from the article title.
Judge Roger Benitez investigated after girl handcuffed All information is provided without warranty of any kind. Second degree murder, penalty. Every year, 1 million people are killed as a result of violent acts, and 15% of women are injured as a result of violent acts. Murder in the first degree, WA Rev Code 9A.32.050. Murder in the second degree. CT Gen Stat 53a-54b. An emotionally charged judge also might convict the impassioned defendant. A person who finds his / her spouse in bed with another man or woman is a simple case. MO Rev Stat 565.020 (2016). Whether the crime is an act of passion, aggression or retaliation it is still a crime in the USA. The "passion" may be used as a defense to indicat
Crime Of Passion Section 300 of the Indian Penal Code, which defines murder, outlines four exceptions to the rule that culpable homicide is not murder. WebSince 2016, perceptions of political, media, and religious freedoms in the country have improved. It first came from Washington in 1993 where it was passed. In Commonwealth v. Ludwig (2005), the Supreme Court of Pennsylvania ruled that this meant that conviction for the crime required the same element of malice as in any other third-degree murder. WV Code 61-2-1. Merchant Marine in international waters and U.S. military bases worldwide. Penalties; applicability of sentencing structures; mandatory minimum sentences for certain reoffenders previously released from prison", "FL Stat 775.082. WebAlabama Crimes: Laws & Penalties Alaska Crimes: Laws & Penalties Arizona Crimes: Laws & Penalties Arkansas Crimes: Laws & Penalties California Crimes: Laws & Penalties Colorado Crimes: Laws & Penalties Connecticut Crimes: Laws & Penalties Delaware Crimes: Laws & Penalties District of Columbia Crimes: Laws & Penalties
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