California, United States of America
The following excerpt is from People v. Alfaro, B256607 (Cal. App. 2015):
Words, without violence or a threat of violence, may be sufficient provocation to reduce murder to manslaughter. (See People v. Valentine (1946) 28 Cal.2d 121, 140-143 [words alone sufficient]; People v. Manriquez (2005) 37 Cal.4th 547, 583-584
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