This defense was first used by U. S. Congressman Daniel Sickles of New York in 1859 after he had killed his wife's lover, Philip Barton Key, but was most used during the 1940s and 1950s.

This defense was first used by U. S. Congressman Daniel Sickles of New York in 1859 after he had killed his wife's lover, Philip Barton Key, but was most used during the 1940s and 1950s.

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