Girouard v. State
Citation
321 Md. 532 (Md. Ct. App. 1991)
Facts
Steven Girouard stabbed his wife to death after she taunted him about his sexual performance, told him she did not love him, said she had reported him to his military superiors, and dared him to kill her.
Issue
Whether words alone — no matter how extremely offensive or provocative — can constitute legally adequate provocation to reduce an intentional killing from murder to voluntary manslaughter.
Holding
The Court held that words alone cannot constitute adequate provocation under Maryland common law and affirmed Girouard’s second-degree murder conviction.
Rule
Mere words, even extremely offensive ones, do not constitute legally adequate provocation to reduce an intentional killing to voluntary manslaughter under the common law heat-of-passion doctrine; the common law categories of adequate provocation are limited and do not include verbal taunting alone.