Sunday, November 17, 2013

Rowland v. State case brief

Rowland v. State case brief summary
35 So. 826 (1904)

Defendant sought review of his conviction by the Circuit Court of Prentiss County (Mississippi) for the murder of his wife.

Defendant discovered his wife and another man in the very act of adultery. As his wife and the other man rushed out of the room, defendant fired at the man and killed his wife.


  • On appeal, the court found that the deceased and the other man were surprised by defendant under such conditions and amid such surroundings as to demonstrate with absolute certainty that they were then actually committing adultery. 
  • This fact alone, in legal contemplation, was adequate provocation to reduce the grade of the homicide, if then instantly committed, from murder to manslaughter.

The court reversed defendant's conviction for murder and remanded to the trial court.

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