Girouard v. State
Maryland Court of Appeals
583 A.2d 718 (1991)
During an argument, Steven Girouard's (defendant) wife Joyce -- five feet tall and 115 pounds to his six feet and 200-plus pounds -- repeatedly insulted him, said she never wanted to marry him, demanded a divorce, and told him she'd filed abuse charges against him with his Army commanding officer that would likely lead to a court-martial; Steven then stabbed her nineteen times with a kitchen knife, killing her, and was immediately distraught, wandering outside afterward saying he couldn't believe what he'd done. A psychologist testified at trial that Steven had mental issues affecting his ability to understand his own capacity for hostility, but he was convicted of second-degree murder and appealed, arguing Joyce's provocation should reduce the conviction to manslaughter.
Whether a spouse's verbal insults, relationship rejection, and threat of adverse legal consequences constitute adequate provocation to mitigate an intentional killing from murder to manslaughter.