United States v. Quintero

Lopez Quintero (defendant) was tried for first-degree murder of his two-year-old daughter after evidence showed he regularly beat her, initially admitted killing her before switching to a story that she died falling from a truck bed, and then burned and dismembered her body to conceal the crime. The trial judge acquitted him of first-degree murder, and despite the government's argument that no two-year-old could provoke the sudden quarrel needed for voluntary manslaughter, the jury acquitted him of second-degree murder but convicted him of voluntary manslaughter; Quintero appealed, arguing the government failed to prove he acted upon sudden quarrel or heat of passion, so he could be convicted of nothing more than involuntary manslaughter.