People v. Valentine

People v. Valentine, 28 Cal.2d 121, 169 P.2d 1 (1946) is a landmark California Supreme Court voluntary manslaughter case where the court holds that mere words may be adequate provocation.

Background

California courts had been divided on the question of whether mere words could be adequate provocation for nearly a century when Valentine was decided. The 1857 case People v. Butler was the earliest case that applied the traditional categorical test for adequate provocation, relying on the Crime and Punishments Act of 1850, which was based on traditional common law principles. Adequate provocation under the 1850 statute required "a serious and highly-provoking injury inflicted upon the person killing, sufficient to excite an irresistible passion in a reasonable person".[1][2][3] Beginning with People v. Hurtado in 1883, a second line of cases had taken a broader approach by allowing juries to decide whether certain facts fulfilled the requirement of adequate provocation. The California Supreme Court's decision in Valentine resolved this split in favor of the broader approach.[3]

Facts

Valentine shot his neighbor Boyd after Boyd accused him of trespassing.

Court's decision

The Court held that verbal provocation may be adequate provocation in some cases, and that the question of whether facts support a finding of heat of passion should properly be resolved by a jury.[4]

References
  1. People v. Valentine, 28 Cal.2d 121
  2. The Crimes and Punishments Act of 1850 (ยง 23)
  3. Pillsbury, Samuel H. (2000-07-01). Judging Evil: Rethinking the Law of Murder and Manslaughter. NYU Press. ISBN 978-0-8147-6875-4.
  4. Laurie J. Taylor, Provoked Reason in Men and Women: Heat-of-Passion Manslaughter and Imperfect Self-Defense, 33 UCLA L. Rev. 1679 (1986)
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