MURDER?

What would ordinarily be murder may be mitigated to voluntary manslaughter where it is committed in the "heat of passion" as a result of "adequate provocation" and without a "reasonable time to cool." On the other hand, the element of premeditation will elevate the charge to murder in the first degree. It seems safe to say that few abortions are done on the spur of the moment or in the heat of passion and that virtually all are contemplated in advance and methodically planned and arranged. Under a traditional homicide analysis, then, since both malice aforethought and premeditation are typically present, the vast preponderance of abortions should be considered as murders in the first degree.

[From 'A Resource Manual']