People v. Chevalier, 131 Ill.2d 66, 544 N.E.2d 942 (1989), was a 1989 Illinois Supreme Court decision that affirmed murder convictions in two consolidated appeals, holding that mere words or verbal admission of infidelity was not sufficient provocation for a manslaughter.
The rule at the time was that adultery with the defendant's spouse was adequate provocation to reduce a murder charge to manslaughter.
In the Chevalier decision, the Illinois Supreme Court overturned previous intermediate appellate cases like People v. Ambro and People v. Carr, holding that mere words or verbal communication could not be adequate provocation to reduce a murder charge to manslaughter.
[5] During an argument, Chevalier shot and killed his wife after she made disparaging remarks about his sexual prowess and verbally admitted to infidelity.
[6] The court held that a verbal admission of infidelity was not sufficient provocation to reduce a murder charge to manslaughter.