California, United States of America
The following excerpt is from People v. Parker, B247064 (Cal. App. 2014):
Breverman, supra, 19 Cal.4th at p. 154.) The test of whether there is sufficient provocation or heat of passion such that it can negate malice and thereby reduce murder to voluntary manslaughter is objective. (People v. Steele (2002) 27 Cal.4th 1230, 1253.) That heat of passion must be such that it would be aroused naturally in an ordinarily reasonable person in the same circumstances. (CALJIC No. 8.42.)
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