Mississippi Code

Miss. Code Ann. § 97-3-35 (2026)

Homicide; killing without malice in the heat of passion

✓ current as of July 2026
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The killing of a human being, without malice, in the heat of passion, but in a cruel or unusual manner, or by the use of a dangerous weapon, without authority of law, and not in necessary self-defense, shall be manslaughter.

Codes, Hutchinson's 1848, ch. 64, art. 12, Title 3 (10), (12); 1857, ch. 64, arts. 174, 176; 1871, §§ 2637, 2639; 1880, §§ 2885, 2887; 1892, §§ 1158, 1160; 1906, §§ 1236, 1238; Hemingway's 1917, §§ 966, 968; 1930, §§ 994, 996; 1942, §§ 2224, 2226.


Notes of Decisions
Cited in 255 cases (26 in the last 5 years), 1974–2026 · leading case: Nolan v. State, 61 So. 3d 887 (Miss. 2011).
Nolan v. State, 61 So. 3d 887 (Miss. 2011). · cites it 44× “” Miss. Code Ann. § 97-3-35 (Rev.2006). ¶ 26.”
Timothy Nelson Evans v. State of Mississippi, 226 So. 3d 1 (Miss. 2017). · cites it 8× “” Miss. Code Ann. § 97-3-35 (Rev. 2014). “Heat of passion” has been defined as: [a] state of violent and uncontrollable rage engendered by a blow or certain other provocation given, which will reduce a homicide from the grade of murder to that of manslaughter.”
Cook v. State, 467 So. 2d 203 (Miss. 1985). · cites it 16× “The type of manslaughter most commonly prosecuted is that committed in the heat of passion and defined more specifically in Miss. Code Ann. § 97-3-35 (1972) as follows: The killing of a human being, without malice, in the heat of passion, but in a cruel or unusual manner, or by…”
Thomas Glynn Flynt v. State of Mississippi, 183 So. 3d 1 (Miss. 2015). · cites it 12× “” Miss. Code Ann. § 97-3-35 (Rev. 2014) (emphasis added).”
Batiste v. State, 121 So. 3d 808 (Miss. 2013). · cites it 6× “See Miss.Code Ann. § 97-3-35 (Rev.2006). The trial court refused the instruction, finding it lacked evidentiary support.”
Jackson v. State, 684 So. 2d 1213 (Miss. 1996). · cites it 7× “For over half a century, this Court has approved circuit courts granting heat of *1228 passion manslaughter instructions to the State in a homicide prosecution which is either murder or justifiable homicide committed in lawful self defense, and there is no element whatever of a…”
Zack Cozar v. State of Mississippi, 226 So. 3d 574 (Miss. 2017). · cites it 10× “Code 97-5-39(2) and 97-3-19(e) and (f) to that of MANSLAUGHTER in violation of Miss. Code 97-3-35 ... the referenced charge ■is hereby reduced .”
McCune v. State, 989 So. 2d 310 (Miss. 2008). · cites it 8× “" Miss.Code Ann. § 97-3-35 (Rev.2006) (emphasis added).”
Grace Ann McCarty v. State of Mississippi, 247 So. 3d 260 (Miss. Ct. App. 2017). · cites it 6× “Mississippi Code Annotated section 97-3-35 (Rev. 2014) states that “[t]he killing of a human being, without malice, in the heat of passion, but in a cruel and unusual manner, or by the use of a dangerous weapon, without authority of law, and not in necessary self- defense, shall…”
Phillips v. State, 794 So. 2d 1034 (Miss. 2001). · cites it 6× “Manslaughter committed in the heat of passion is defined in Miss.Code Ann. § 97-3-35 as, "the killing of a human being, without malice, in the heat of passion, but in a cruel or unusual manner, or by the use of a dangerous weapon, without authority of law, and not in necessary…”
Mease v. State, 539 So. 2d 1324 (Miss. 1989). · cites it 4× “The manslaughter instructions sought by the defense seem directed to unlawful act manslaughter under Section 97-3-31 and heat of passion manslaughter under Section 97-3-35. Where the principal defense theory was manslaughter and where five separate manslaughter instructions were…”
David Thomas v. State of Mississippi, 249 So. 3d 331 (Miss. 2018). · cites it 4× “” Miss. Code Ann. § 97-3-35 (Rev. 2014). 23 ¶56.”
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