Commonwealth v. Adjutant

Following a jury trial, Rhonda Adjutant, a woman employed by an escort service, was found guilty of voluntary manslaughter for killing Stephen Whiting, a client of the service. In this appeal, Adjutant argues that evidence of Whiting’s violent reputation and past conduct, even though unknown to her at the time of the killing, should have been admitted at her trial because it was relevant to her claim that Whiting was the *650“first aggressor” in the altercation that resulted in his death, and that she acted in self-defense.

After surveying the state of the law in jurisdictions throughout the…