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Girouard v. State

Maryland Court of Appeals
583 A.2d 718 (1991)



Steven Girouard (defendant) and his wife Joyce had been married for about two months when they got into a heated argument. During the argument Joyce, who was just over five feet tall and weighed 115 pounds, repeatedly insulted Steven, who was over six feet tall and weighed over 200 pounds. Joyce told Steven she did not love him and had never wanted to marry him, and she demanded a divorce. Joyce also informed Steven that she had filed charges against him for abuse with his commanding officer in the Army and told him he would probably be court-martialed. Steven lunged at Joyce with a kitchen knife and stabbed her 19 times, killing her. Steven was immediately distraught at what he had done. When the police arrived, they found Steven wandering around outside his apartment building stating that he could not believe what he had done. At trial, a psychologist testified that Steven had mental issues including an inability to understand his own capacity to express hostility and a need for acceptance and love. Steven was convicted of second-degree murder. He appealed, arguing that Joyce’s provocation should mitigate his murder conviction to manslaughter.

Rule of Law


Holding and Reasoning (Cole, J.)

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