March 23, 2026
Court of Appeal, Second Appellate District, Division Seven
The Rule of People v. Tzul is that a handwritten statement found at a crime scene expressing the defendant's rage and belief about what victims were doing has significant probative value for provocation defense that cannot be substantially outweighed by prejudice concerns under Evidence Code section 352, under circumstances where the statement is the only evidence of provocation and is central to the defense theory.