Lying in wait

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LYING IN WAIT. Being in ambush for the purpose of murdering another.
     2. Lying in wait is evidence of deliberation and intention.
     3. Where murder is divided into degrees, as in Pennsylvania, lying in wait is such evidence of malice, that it makes the killing, when it takes place, murder in the first degree. Vide. Dane's Ab. Index, h.t.

A Law Dictionary, Adapted to the Constitution and Laws of the United States. By John Bouvier. Published 1856.