The People v. Beltran

Summary

The court held that heat-of-passion provocation need only be sufficient to cause an ordinary person of average disposition to react rashly, without due deliberation and from passion rather than judgment; it need not be sufficient to cause that person to kill. Although the jury instruction was potentially clouded by counsel's arguments, the jury's clarifying question and the trial court's response correctly stated the governing standard, and the evidence of legally adequate provocation was weak. The court therefore reversed the Court of Appeal's judgment.