How has the Attorney General argued for a voluntary manslaughter instruction in a motor vehicle accident case?

The Attorney General argues that there is no evidence defendant acted under a strong passion and, in any case, the provocation he claimseither being approached suddenly by a car with flashing lights and a revved engine, or being the victim of a collision, followed by a heated verbal exchangeis legally inadequate to reduce murder to manslaughter or attempted murder to attempted manslaughter. (See People v. Gutierrez (2009) 45 Cal.4th 789, 826 ["a voluntary manslaughter instruction is not warranted where the act that allegedly provoked the killing was no more than taunting words, a technical battery, or slight touching"].) We agree with the Attorney General.

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