In making the objective determination as to what constitutes sufficient provocation for a finding of voluntary manslaughter, reliance may be placed upon the cumulative impact of a series of related events. The ultimate test for adequate provocation remains whether a reasonable man, confronted with this series of events, became impassioned to the extent that his mind was incapable of cool reflection.
Defendant shot at two women he found making love in a park, killing one of them. The trial court convicted him of murder. He appealed his conviction to the Superior Court of Pennsylvania alleging that the trial court erred in refusing to permit him to introduce evidence of his psychosexual history to show that such an event was, for him, sufficient provocation to find that he was guilty of the lesser offense of voluntary manslaughter.
Did the court properly refuse the introduction of evidence of his psychsexual history?
The Court held that the trial court properly refused to permit the introduction of evidence of defendant's psychosexual history for purposes of showing provocation sufficient to reduce his murder offense to manslaughter. The Court held that a trial court must determine whether sufficient evidence of provocation is present by considering the actions of the victim. Furthermore, it held that the law does not recognize homosexual activity as sufficient legal provocation to reduce a murder to voluntary manslaughter. The court found that the accused could not, by recalling some past injury, establish a foundation for a manslaughter verdict. The court rejected defendant's claim that his waiver of Miranda rights was involuntary because he did not know he what he was being questioned for. After defendant raised the issue of the validity of his confession, the prosecution met its burden of proving that defendant knew why he was being questioned because he talked with a person who told the officers that defendant knew about the murder.