California, United States of America
The following excerpt is from The PEOPLE v. HOWARD St., A120412, No. 152819 (Cal. App. 2010):
7. Although, unlike the provocation necessary to reduce murder to manslaughter, the provocation necessary to negate premeditation or deliberation need not be objectively reasonable (People v. Padilla (2002) 103 Cal.App.4th 675, 678), the jury here was not instructed that provocation necessary for either purpose must be sufficient to cause an ordinary person to act rashly.
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