The Court of Appeals of Maryland heard the case of Steven Saunders Girouard v. State of Maryland in September 1989. The case involves the death of Joyce M. Girouard, who was married to Steven S. Girouard for two months. Steven fatally stabbed his wife and was convicted of second-degree murder. He argues that the circumstances of the case presented provocation adequate to mitigate the charge to manslaughter, and that the categories of provocation should be broadened. The State argues that abusive words alone cannot mitigate murder to manslaughter. The trial judge found provocation but held it inadequate to mitigate murder. The case was granted certiorari to determine whether the provocation was adequate. The lower court did not err in admitting testimony from a psychologist and psychiatrist.

The legal case discusses the "Rule of Provocation" and how it can reduce a murder charge to manslaughter. However, insulting words or gestures alone are not adequate provocation for a verdict of voluntary manslaughter, especially when the homicide was intentionally committed with a deadly weapon. The court held that the provocation in this case was not reasonable enough to justify a verdict of voluntary manslaughter. The defendant's mental state should not be the focus of the standard of reasonableness. The court affirmed the judgment with costs and left open the possibility of expanding the categories of adequate provocation to mitigate murder to manslaughter in the future.