When provocation is the basis of a manslaughter case, the issue is whether the defendant’s loss of self-control was a reasonable reaction to the circumstances. If the provocation was sufficient to arouse the passions of an ordinary person to the point of losing self-control, then the adequacy point has been reached. A continuing course of ill-treatment by a victim against the defendant or a third person “with whom the defendant stands in a close relationship” can constitute adequate provocation. A physical threat with a gun or knife might be considered adequate provocation but words alone never constitute adequate provocation.
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