Houston v. State, 583 S.W.2d 267 (1980), was a case decided by the Supreme Court of Tennessee that held that "repeated shots or blows" was sufficient circumstantial evidence to prove premeditation and deliberation for first degree murder.
Subsequent history
Houston was overruled by the case State v. Brown, which required more evidence than repeated blows to show deliberation.
References
Houston v. State Wikipedia(Text) CC BY-SA