Steven Girouard was convicted of second degree murder for stabbing his wife 19 times after she insulted him, threatened to file charges against him, and taunted him. The Court of Appeals was asked to determine if the circumstances of the case presented adequate provocation to mitigate the charge to manslaughter. The "Rule of Provocation" requires adequate provocation, killing in the heat of passion, a sudden heat of passion, and a causal connection between the provocation, the passion, and the fatal act. The court agreed with the trial judge that the taunting words spoken by Joyce were not enough to inflame the passion of a reasonable person to the point of killing her in hot-blooded blind passion. Therefore, Steven's actions constituted murder and not manslaughter.
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