California, United States of America
The following excerpt is from People v. Antwane, B240539 (Cal. App. 2013):
ordinarily reasonable person, they were insufficient to provoke defendant's two brothers. Furthermore, the desire for revenge does not qualify as a passion that will reduce a killing to manslaughter. (People v. Bufarale (1961) 193 Cal.App.2d 551, 562.)
Although no specific type of provocation is required (People v. Berry (1976) 18 Cal.3d 509, 515), the court may resolve the question when the provocation is so slight or so severe that reasonable jurors could not differ on the issue of adequacy. (People v. Brooks (1986) 185 Cal.App.3d 687, 693.)
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