What is the required provocation for a jury to consider voluntary manslaughter?

Nevertheless, a deficit in one instruction may be supplied by another or cured by the instructions as a whole. (People v. Castillo (1997) 16 Cal.4th 1009, 1016.) Although the prosecutor characterized the requisite provocation as moving a reasonable person to kill, her overall description of voluntary manslaughter was accurate to the extent she focused on the objective circumstances that would cause a reasonable person to act rashly. CALCRIM No. 570 correctly advised the jury that to be sufficient, the provocation must have been such as to "cause[] an ordinary person of average disposition to act rashly and without due deliberation, that is, from passion rather than from judgment."¹⁶ And the trial court instructed the jury: "If you believe the attorneys'

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