About: State v. Dumlao

State v. Dumlao is a 1986 criminal Hawaii Intermediate Court of Appeals case appealing a murder conviction on the ground that the court's decision to not issue a jury instruction for voluntary manslaughter based on was a reversible error. The court found that the Model Penal Code required a subjective analysis of whether provocation is adequate from the defendant's perspective. Based on medical testimony that Dumlao suffered from "paranoid personality disorder", which included symptoms of "unwarranted suspiciousness" and hypersensitivity, the Court granted Dumlao's appeal, holding that his actions on the night he killed his mother in law had been "reasonable" from his perspective.