People v. Superior Court (Henderson)

In People v. Superior Court (Henderson) (1986) 178 Cal.App.3d 516, in a footnote, the court stated, "The concept of 'heat of passion' allows a defendant to reduce a killing from murder to manslaughter only in those situations where the provocation would trigger a homicidal reaction in the mind of an ordinarily reasonable person under the given facts and circumstances." (Henderson, supra, 178 Cal.App.3d at p. 524, fn. 4.) The issue in Henderson was whether the magistrate's findings and conclusion after the preliminary hearing that the killing occurred in the heat of passion precluded a prosecution for murder. (Id. at p. 520.)