In People v. Daniels (1991) 52 Cal.3d 815, the defendant committed a bank robbery in 1980. He fled in a car, pursued by two officers. When his car spun out of control, the defendant shot at one of the officers and ran. The officers fired, hitting the defendant and leaving him paralyzed below the waist. The defendant was convicted of various offenses, but posted bail pending appeal. In 1982, his conviction was affirmed. When he did not appear in court as scheduled, an arrest warrant was issued. Two police officers went to his location to arrest him, and the defendant shot and killed them, leading to capital charges. (Id. at pp. 837-838.) The California Supreme Court determined evidence of events surrounding the 1980 bank robbery was properly admitted in the capital case to show motive, as there was a direct relationship between the events surrounding the bank robbery, particularly the police shooting the defendant and rendering him a paraplegic, and the defendant murdering officers in retribution. (Id. at pp. 856-857.) In People v. Daniels (1991) the defendant was rendered a paraplegic when he was shot by police officers after a bank robbery. Over two years after he was shot, several police officers came to the defendant's residence to arrest him. Defendant shot and killed the officers as they walked towards the front door of the residence. On appeal, defendant contended his request for voluntary manslaughter instructions based on heat of passion should have been granted. Our Supreme Court held: "In the present case there is no evidence of provocation by the slain officers, and no evidence that defendant was in the 'heat of passion' when he killed them. The theory that defendant was bent on revenge for having been crippled by police gunfire after the bank robbery is insufficient to justify a manslaughter instruction. For such an instruction, the killing must be 'upon a sudden quarrel or heat of passion' ( 192); that is, 'suddenly as a response to the provocation, and not belatedly as revenge or punishment. Hence, the rule is that, if sufficient time has elapsed for the passions of an ordinarily reasonable person to cool, the killing is murder, not manslaughter.' The period of over two years and three months between defendant's injury and the killing of the police is, as matter of law, sufficient to allow passions to cool." ( Id. at p. 868.)