Speaking from a case study perspective the of People v. Berry was a watershed moment in regards to the degree in which a provocation or how adequate the provocation needs to be to escalate a killing to a crime of heated passion. In other words the case revolves around how Mr. Berry killed his wife from what he clams a heat of passion reaction that resulted in her death, even though Mr. Berry was convicted beforehand of first degree murder the California supreme court for a just merit in Mr. Berry's argument that his wife badgered and provoked him over a two week period until he reached his breaking point and he strangled her to death. The California supreme court later changed Mr. Berry's first degree murder charge to that of voluntary manslaughter,
