The charges for murder vary by State. Here’s a New York lawyer explaining Murder 1 vs Murder 2 as it relates to New York State law. Murder 2 is regular premeditated murder. Murder 1 is murder with the intent of influencing or intimidating government ie. Terrorism. The lawyer in this interview suggests the Terrorism charge is, ironically, politically motivated, but it will be difficult to actually prove beyond a doubt that Luigi’s intentions were to change government policies and not just get even with someone he disliked.

In most places murder 1 is premeditated murder and murder 2 is manslaughter. Murder 1 in New York is different.