People v. BeltranAnnotate this Case
Defendant was charged with murder and use of a deadly weapon. The trial court gave instructions on first and second degree murder, as well as voluntary manslaughter based upon a sudden quarrel or heat of passion. The jury found Defendant guilty of second degree murder with a use enhancement. The court of appeal reversed Defendant's conviction, concluding that the voluntary manslaughter instruction was prejudicially erroneous. The Supreme Court reversed after clarifying what kind of provocation will suffice to constitute heat of passion and reduce a murder to manslaughter, holding (1) provocation is adequate only when it would render an ordinary person of average disposition "liable to act rashly or without due deliberation and reflection, and from this passion rather than judgment; and (2) although the jury instruction properly conveyed the standard for determining heat of passion, the argument of counsel may have introduced ambiguity, but the jury asked a clarifying question, and the trial court's response dispelled any confusion. Remanded.