Extreme fear and anger about efforts to terminate a love relationship are not a legally sufficient provocation to reduce responsibility for a death from murder to manslaughter.
Ms. Hayne and Mr. Pulsifer were residents of the Augusta Mental Health Institute. She had received residential treatment for 16 years and he for 6 years. He was diagnosed with schizoaffective disorder.
The couple had shared romance for about one year before her death. Staff at the Institute described the relationship as a high school type, characterized by sitting together, holding hands and kissing before returning to their rooms.
Hayne's family noted that she was regressing. Her mother requested the staff to limit the time the two spent together. Staff complied. The attempts were only marginally successful because Pulsifer had a set of keys that allowed entry to many of the buildings and rooms on the grounds.
One day, in front of staff, Pulsifer became angry with her and ripped an Easter card she had received from her parents. The next day, he learned she was afraid of him and that her mother would get a restraining order if he did not stay away from her. He agreed to stay away from her. He was placed on hourly check-in and she on one-half hour check-in.
The next day, Pulsifer told a staff member that he didn't understand the parents' stance toward him. He was described as confused, but not angry. He broke his promise and met with her that afternoon. They did not meet at all the next day.
On the fourth day, after a short morning meeting concluded with "love yas," they met secretly later in a storage room, courtesy of his keys. They talked for one-half hour and he stabbed her six times before she was due to check-in.
Pulsifer waived a jury trial on an intentional murder charge. He admitted causing Hayne's death, but claimed that attempts to end the relationship by the parents and staff provoked him into killing her. Thus, he was guilty only of manslaughter. The trial judge refused to consider the adequate provocation defense and found him guilty of murder.
The Supreme Judicial Court of Maine affirmed the trial court. It noted that the "reasonable man" standard applied to the facts and held that no reasonable man when confronted with Pulsifer's situation would react to his anger and fear by killing the object of his affection.