People v. Beltran, 56 Cal. 4th 935

Defendant Beltran and Tempongko dated; he abused her repeatedly and once barricaded her in a room, prompting police involvement.
Tempongko obtained a restraining order; defendant later arrived at her residence despite being prohibited by the order.
Tempongko’s new partner and children were present; a phone exchange and subsequent events escalated fear in Tempongko.
On October 22, 2000, Tempongko was found murdered in her apartment with multiple stab wounds after a confrontation with Beltran.
Defendant claimed he killed in heat of passion; trial court gave voluntary manslaughter instruction based on heat of passion with a modified CALCRIM 570.
Jury convicted Beltran of second degree murder with a deadly weapon; Court of Appeal reversed, prompting this review on provocation standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper standard for adequate provocation	People argues average person would be moved to kill.	Beltran contends Logan standard focuses on reaction, not necessarily killing.	Standard is Logan: adequate provocation obscures reason, not necessarily which act.
Whether CALCRIM No. 570 modification was proper	Instruction properly guided jurors to evaluate provocation under Logan.	Instruction risked focusing on killing rather than rash reaction.	Instruction, as clarified, correctly directed jurors to assess rashness and passion.
Impact of prosecutorial comments and defense argument on instructional clarity	Prosecutor’s examples did not alter the correct Logan standard.	Arguments muddied whether average person would kill.	No reversible error; clarification instruction mitigated potential prejudice.
Harmless error standard when instruction is arguably imperfect	Any error should be reviewed under Chapman harmless error standard for federal claims.	Ambiguity could prejudice Beltran.	Under Watson/Breverman, no reasonable probability the outcome would differ given strong evidence of murder and clarified instruction.
Relation to self-defense imperfect defense concept	Logan framework remains distinct from imperfect self-defense.	N/A	Logan standard governs provocation; imperfect self-defense remains a separate mitigator, but not controlling here.

People v. Logan, 175 Cal. 45 (1917) (core test: reason disturbed by passion to rashly act, not judgment)
People v. Valentine, 28 Cal.2d 121 (1946) ( Log an standard applied; removes insult limitation from pre‑code era)
Maher v. People, 10 Mich. 212 (1862) (ordinary average disposition criterion for adequate provocation)
People v. Barton, 12 Cal.4th 186 (1995) (heat of passion framework; state of mind obscured by passion)
People v. Logan; People v. Koontz, 27 Cal.4th 1041 (2002) (reaffirmation of Logan standard in modern context)
People v. Lasko, 23 Cal.4th 101 (2000) (heat of passion analysis in context of instruction)