This section contains the nature of the case and procedural background.

Reynolds (D) was at a party where he met his estranged wife with another man. D became drunk and fired his pistol into the air three times. The third bullet killed his estranged wife. D and his girlfriend left the party with the dead body in the back seat of D's car. D was charged with murder. D presented evidence to show that his hand was struck, causing his wife to be killed. The State showed evidence that D had had a quarrel with his wife over her boyfriend the night before. The trial court instructed the jury on first-degree murder, voluntary manslaughter, and justifiable homicide, but refused to instruct on involuntary manslaughter. D was convicted of voluntary manslaughter. D appealed.

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