D and V, husband and wife, respectively, had each been drink…

D and V, husband and wife, respectively, had each been drinking heavily throughout the day. During the course of a drunken and increasingly heated argument, V told D that she had been cheating on him with his friend, and that she had done so in part, because D was “a worthless, no-good, stinking drunk, just like your (D’s) father.” In fact, D’ s father had been a violent drunk, who had physically abused and then abandoned his family. In addition, D was, in fact, an alcoholic. Enraged, D picked up a fireplace tool and slammed in into V’s head, killing her. D is charged with murder, and seeks to mitigate his crime to manslaughter, based on the heat of passion doct1ine. Applying common law principles, which of the following statements is least accurate?