Not true.
“Premeditation” for murder purposes can be formed in an instant.
The classic example is shooting someone in self defense, and double tapping them once they are down. The first shot is legal, second is murder I.
The key is intent or purpose to commit an unlawful killing (in MPC states) or “malice a forethought” in common law.
Compare to 2nd degree “reckless indifference” murder and manslaughter “heat of passion” murder.
This is Murder I, because the intent or purpose was to commit an unlwful killing. The perp was not facing lethal force. His decision to pull the trigger in that situation is the pre-meditation. (He is aware that doing so will result in a death, and does it anyway without the requisite justification of “no possibility of retreat” to stand his ground and discharge)
“The Court is too political so we are going to add a shitload of partisans”