I think that simply the introduction of an outsider into a marriage, as in Postman, makes it noir if it leads to the death of a spouse. Domestic violence in and of itself does not make it noir.
Example:
If a woman kills her husband with a frying in the heat of rage, it's not noir.
If she kills her husband with a frying pan in the heat of rage and then calls her lover to help her make it look like an accident, that's noir.
If she hires a hitman to kill her husaband, that's noir.
If she talks her lover into killing her husband, that's definitely noir.
If they plot it and execute it together, that's the stuff of great noir.
Jeff
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