What is the current state of the law on the "heat of passion" theory of voluntary manslaughter?

California, United States of America


The following excerpt is from People v. Luna, B244722 (Cal. App. 2014):

quarrel or heat of passion theory of voluntary manslaughteri.e., one who acts in self-defense does not actually and subjectively act under the heat of passion. (See People v. Steele, supra, 27 Cal.4th at p. 1252.)

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