McClung v. Commonwealth
In McClung v. Commonwealth, 215 Va. 654, 212 S.E.2d 290 (1975), the defendant could not testify at all about the death of the victim, and there were no other eyewitnesses. 215 Va. at 655, 212 S.E.2d at 291.
Because the victim abused her, however, the Supreme Court of Virginia decided that "the jury could have concluded that the victim's conduct under these circumstances was sufficient to provoke a reasonable person to fear or rage, or both." Id. at 656-57, 212 S.E.2d at 292.