misdemeanor-manslaughter rule (California) · Go Syfert
← California issues

misdemeanor-manslaughter rule in California

13 California opinions name it 2 courts 1972–2025 2 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (27)

CaseFollowedCited
People v. McManisgreen
calctapp · 1972 · cited in 4 California opinions naming this issue, 1975–2025
2 sentences

2025(Oct. 2024) CALCRIM No. 580, p. 331; see People v. McManis (1972) 26 Cal.App.3d 608, 614 [“instruction defining misdemeanor within the context of a misdemeanor- manslaughter instruction must be given sua sponte”].) Here, instead of directing the jury to an underlying predicate offense committed with criminal negligence, the version of CALCRIM No. 580 given by the court incorrectly directed the jury to murder which requires either express or implied malice.

2025(Oct. 2024) CALCRIM No. 580, p. 331; see People v. McManis (1972) 26 Cal.App.3d 608, 614 [“instruction defining misdemeanor within the context of a misdemeanor- manslaughter instruction must be given sua sponte”].) Here, instead of directing the jury to an underlying predicate offense committed with criminal negligence, the version of CALCRIM No. 580 given by the court incorrectly directed the jury to murder which requires either express or implied malice.

24
People v. Faillagreen
cal · 1966 · cited in 2 California opinions naming this issue, 1972–2000
2 sentences

2000(People v. Failla [(1966)] 64 Cal.2d 560, 564 [ 51 Cal.Rptr. 103 , 414 P.2d 39 ] [citations].) Failure to do so may allow the trier of fact to engage *673 in unguided speculation as to what conduct is sufficient to constitute a misdemeanor inherently dangerous to human life.” (McManis, supra, 26 Cal.App.3d at p. 614 .) Interestingly, this court’s decision in People v. Failla, supra, 64 Cal.2d 560 (Failla), upon which the McManis court relied with little substantive analysis, had nothing to do with homicide or manslaughter.

2000(People v. Failla [(1966)] 64 Cal.2d 560, 564 [ 51 Cal.Rptr. 103 , 414 P.2d 39 ] [citations].) Failure to do so may allow the trier of fact to engage *673 in unguided speculation as to what conduct is sufficient to constitute a misdemeanor inherently dangerous to human life.” (McManis, supra, 26 Cal.App.3d at p. 614 .) Interestingly, this court’s decision in People v. Failla, supra, 64 Cal.2d 560 (Failla), upon which the McManis court relied with little substantive analysis, had nothing to do with homicide or manslaughter.

22
People v. Wrightgreen
calctapp · 1976 · cited in 2 California opinions naming this issue, 1982–1986
2 sentences

1986(See People v. Wright (1976) 60 Cal.App.3d 6, 11, fn. 5 [ 131 Cal.Rptr. 311 ] for a discussion of the need to rewrite the involuntary manslaughter statute.) It should be apparent from the structure of the argument outlined above, unless we find insufficient evidence to convict defendant of a violation of Penal Code section 417, subdivision (a)(2), that we never reach defendant’s bid for extension of the misdemeanor manslaughter doctrine.

1986(See People v. Wright (1976) 60 Cal.App.3d 6, 11, fn. 5 [ 131 Cal.Rptr. 311 ] for a discussion of the need to rewrite the involuntary manslaughter statute.) It should be apparent from the structure of the argument outlined above, unless we find insufficient evidence to convict defendant of a violation of Penal Code section 417, subdivision (a)(2), that we never reach defendant’s bid for extension of the misdemeanor manslaughter doctrine.

22
People v. Stuartgreen
cal · 1956 · cited in 2 California opinions naming this issue, 2000–2008
2 sentences

2008(See, e.g., People v. Stuart (1956) 47 Cal.2d 167, 174 [ 302 P.2d 5 ] [preparing, compounding, or selling an adulterated or misbranded drug]; People v. Southack (1952) 39 Cal.2d 578, 584 [ 248 P.2d 12 ] [brandishing a firearm]; People v. Ramirez (1979) 91 Cal.App.3d 132, 139-140 [ 153 Cal.Rptr. 789 ] [carrying a loaded firearm in a public place]; People v. Villalobos (1962) 208 Cal.App.2d 321, 326 [ 25 Cal.Rptr. 111 ] [child endangerment].) Therefore, it cannot be said a violation of section 192 would necessarily or commonly result in a violation of section 245.

2000We recognize, as did the Court of Appeal below, that a line of early California intermediate appellate court decisions, many predating Stuart , held that “where a person, in committing an assault and battery . . . unintentionally causes the death of his victim, the crime is [involuntary] manslaughter. [Citations.]” (People v. McManis (1954) 122 Cal.App.2d 891, 898 [ 266 P.2d 134 ]; see also People v. Morgan (1969) 275 Cal.App.2d 603, 608 [ 79 Cal.Rptr. 911 ]; People v. Tophia (1959) 167 Cal.App.2d 39, 47-48 [ 334 P.2d 133 ]; People v. Le Grant (1946) 76 Cal.App.2d 148, 152 [ 172 P.2d 554 ]; Pe

12
People v. Phillipsgreen
cal · 1966 · cited in 2 California opinions naming this issue, 1983–1989
2 sentences

1989Code, § 192, par. 2), we reach the same conclusion as to the first degree felony-murder rule only by piling inference on inference; and the second degree felony-murder rule remains, as it has been since 1872, a judge-made doctrine without any express basis in the Penal Code (see People v. Phillips (1966) . . . 64 Cal.2d 574, 582 [ 51 Cal.Rptr. 225 , 414 P.2d 353 ], and cases cited).

1989Code, § 192, par. 2), we reach the same conclusion as to the first degree felony-murder rule only by piling inference on inference; and the second degree felony-murder rule remains, as it has been since 1872, a judge-made doctrine without any express basis in the Penal Code (see People v. Phillips (1966) . . . 64 Cal.2d 574, 582 [ 51 Cal.Rptr. 225 , 414 P.2d 353 ], and cases cited).

12
People v. Ramirezgreen
calctapp · 1979 · cited in 1 California opinions naming this issue, 2008–2008
2 sentences

2008(See, e.g., People v. Stuart (1956) 47 Cal.2d 167, 174 [ 302 P.2d 5 ] [preparing, compounding, or selling an adulterated or misbranded drug]; People v. Southack (1952) 39 Cal.2d 578, 584 [ 248 P.2d 12 ] [brandishing a firearm]; People v. Ramirez (1979) 91 Cal.App.3d 132, 139-140 [ 153 Cal.Rptr. 789 ] [carrying a loaded firearm in a public place]; People v. Villalobos (1962) 208 Cal.App.2d 321, 326 [ 25 Cal.Rptr. 111 ] [child endangerment].) Therefore, it cannot be said a violation of section 192 would necessarily or commonly result in a violation of section 245.

2008(See, e.g., People v. Stuart (1956) 47 Cal.2d 167, 174 [ 302 P.2d 5 ] [preparing, compounding, or selling an adulterated or misbranded drug]; People v. Southack (1952) 39 Cal.2d 578, 584 [ 248 P.2d 12 ] [brandishing a firearm]; People v. Ramirez (1979) 91 Cal.App.3d 132, 139-140 [ 153 Cal.Rptr. 789 ] [carrying a loaded firearm in a public place]; People v. Villalobos (1962) 208 Cal.App.2d 321, 326 [ 25 Cal.Rptr. 111 ] [child endangerment].) Therefore, it cannot be said a violation of section 192 would necessarily or commonly result in a violation of section 245.

11
People v. Garciagreen
calctapp · 2008 · cited in 1 California opinions naming this issue, 2008–2008
2 sentences

2008The misdemeanor manslaughter clause of section 192 applies whenever the victim’s death results from a misdemeanor that is “dangerous to human life under the circumstances of its commission.” (People v. Garcia (2008) 162 Cal.App.4th 18, 27 [ 74 Cal.Rptr.3d 912 ].) While aggravated assault would qualify as a predicate misdemeanor, it is only one of many that may support a conviction under section 192.

2008The misdemeanor manslaughter clause of section 192 applies whenever the victim’s death results from a misdemeanor that is “dangerous to human life under the circumstances of its commission.” (People v. Garcia (2008) 162 Cal.App.4th 18, 27 [ 74 Cal.Rptr.3d 912 ].) While aggravated assault would qualify as a predicate misdemeanor, it is only one of many that may support a conviction under section 192.

11
People v. Southackgreen
cal · 1952 · cited in 1 California opinions naming this issue, 2008–2008
2 sentences

2008(See, e.g., People v. Stuart (1956) 47 Cal.2d 167, 174 [ 302 P.2d 5 ] [preparing, compounding, or selling an adulterated or misbranded drug]; People v. Southack (1952) 39 Cal.2d 578, 584 [ 248 P.2d 12 ] [brandishing a firearm]; People v. Ramirez (1979) 91 Cal.App.3d 132, 139-140 [ 153 Cal.Rptr. 789 ] [carrying a loaded firearm in a public place]; People v. Villalobos (1962) 208 Cal.App.2d 321, 326 [ 25 Cal.Rptr. 111 ] [child endangerment].) Therefore, it cannot be said a violation of section 192 would necessarily or commonly result in a violation of section 245.

2008(See, e.g., People v. Stuart (1956) 47 Cal.2d 167, 174 [ 302 P.2d 5 ] [preparing, compounding, or selling an adulterated or misbranded drug]; People v. Southack (1952) 39 Cal.2d 578, 584 [ 248 P.2d 12 ] [brandishing a firearm]; People v. Ramirez (1979) 91 Cal.App.3d 132, 139-140 [ 153 Cal.Rptr. 789 ] [carrying a loaded firearm in a public place]; People v. Villalobos (1962) 208 Cal.App.2d 321, 326 [ 25 Cal.Rptr. 111 ] [child endangerment].) Therefore, it cannot be said a violation of section 192 would necessarily or commonly result in a violation of section 245.

11
People v. Villalobosgreen
calctapp · 1962 · cited in 1 California opinions naming this issue, 2008–2008
2 sentences

2008(See, e.g., People v. Stuart (1956) 47 Cal.2d 167, 174 [ 302 P.2d 5 ] [preparing, compounding, or selling an adulterated or misbranded drug]; People v. Southack (1952) 39 Cal.2d 578, 584 [ 248 P.2d 12 ] [brandishing a firearm]; People v. Ramirez (1979) 91 Cal.App.3d 132, 139-140 [ 153 Cal.Rptr. 789 ] [carrying a loaded firearm in a public place]; People v. Villalobos (1962) 208 Cal.App.2d 321, 326 [ 25 Cal.Rptr. 111 ] [child endangerment].) Therefore, it cannot be said a violation of section 192 would necessarily or commonly result in a violation of section 245.

2008(See, e.g., People v. Stuart (1956) 47 Cal.2d 167, 174 [ 302 P.2d 5 ] [preparing, compounding, or selling an adulterated or misbranded drug]; People v. Southack (1952) 39 Cal.2d 578, 584 [ 248 P.2d 12 ] [brandishing a firearm]; People v. Ramirez (1979) 91 Cal.App.3d 132, 139-140 [ 153 Cal.Rptr. 789 ] [carrying a loaded firearm in a public place]; People v. Villalobos (1962) 208 Cal.App.2d 321, 326 [ 25 Cal.Rptr. 111 ] [child endangerment].) Therefore, it cannot be said a violation of section 192 would necessarily or commonly result in a violation of section 245.

11
People v. Le Grantgreen
calctapp · 1946 · cited in 1 California opinions naming this issue, 2000–2000
2 sentences

2000We recognize, as did the Court of Appeal below, that a line of early California intermediate appellate court decisions, many predating Stuart , held that “where a person, in committing an assault and battery . . . unintentionally causes the death of his victim, the crime is [involuntary] manslaughter. [Citations.]” (People v. McManis (1954) 122 Cal.App.2d 891, 898 [ 266 P.2d 134 ]; see also People v. Morgan (1969) 275 Cal.App.2d 603, 608 [ 79 Cal.Rptr. 911 ]; People v. Tophia (1959) 167 Cal.App.2d 39, 47-48 [ 334 P.2d 133 ]; People v. Le Grant (1946) 76 Cal.App.2d 148, 152 [ 172 P.2d 554 ]; Pe

2000We recognize, as did the Court of Appeal below, that a line of early California intermediate appellate court decisions, many predating Stuart , held that “where a person, in committing an assault and battery . . . unintentionally causes the death of his victim, the crime is [involuntary] manslaughter. [Citations.]” (People v. McManis (1954) 122 Cal.App.2d 891, 898 [ 266 P.2d 134 ]; see also People v. Morgan (1969) 275 Cal.App.2d 603, 608 [ 79 Cal.Rptr. 911 ]; People v. Tophia (1959) 167 Cal.App.2d 39, 47-48 [ 334 P.2d 133 ]; People v. Le Grant (1946) 76 Cal.App.2d 148, 152 [ 172 P.2d 554 ]; Pe

11
People v. McManisgreen
calctapp · 1954 · cited in 1 California opinions naming this issue, 2000–2000
2 sentences

2000We recognize, as did the Court of Appeal below, that a line of early California intermediate appellate court decisions, many predating Stuart , held that “where a person, in committing an assault and battery . . . unintentionally causes the death of his victim, the crime is [involuntary] manslaughter. [Citations.]” (People v. McManis (1954) 122 Cal.App.2d 891, 898 [ 266 P.2d 134 ]; see also People v. Morgan (1969) 275 Cal.App.2d 603, 608 [ 79 Cal.Rptr. 911 ]; People v. Tophia (1959) 167 Cal.App.2d 39, 47-48 [ 334 P.2d 133 ]; People v. Le Grant (1946) 76 Cal.App.2d 148, 152 [ 172 P.2d 554 ]; Pe

2000We recognize, as did the Court of Appeal below, that a line of early California intermediate appellate court decisions, many predating Stuart , held that “where a person, in committing an assault and battery . . . unintentionally causes the death of his victim, the crime is [involuntary] manslaughter. [Citations.]” (People v. McManis (1954) 122 Cal.App.2d 891, 898 [ 266 P.2d 134 ]; see also People v. Morgan (1969) 275 Cal.App.2d 603, 608 [ 79 Cal.Rptr. 911 ]; People v. Tophia (1959) 167 Cal.App.2d 39, 47-48 [ 334 P.2d 133 ]; People v. Le Grant (1946) 76 Cal.App.2d 148, 152 [ 172 P.2d 554 ]; Pe

11
People v. Tophiagreen
calctapp · 1959 · cited in 1 California opinions naming this issue, 2000–2000
2 sentences

2000We recognize, as did the Court of Appeal below, that a line of early California intermediate appellate court decisions, many predating Stuart , held that “where a person, in committing an assault and battery . . . unintentionally causes the death of his victim, the crime is [involuntary] manslaughter. [Citations.]” (People v. McManis (1954) 122 Cal.App.2d 891, 898 [ 266 P.2d 134 ]; see also People v. Morgan (1969) 275 Cal.App.2d 603, 608 [ 79 Cal.Rptr. 911 ]; People v. Tophia (1959) 167 Cal.App.2d 39, 47-48 [ 334 P.2d 133 ]; People v. Le Grant (1946) 76 Cal.App.2d 148, 152 [ 172 P.2d 554 ]; Pe

2000We recognize, as did the Court of Appeal below, that a line of early California intermediate appellate court decisions, many predating Stuart , held that “where a person, in committing an assault and battery . . . unintentionally causes the death of his victim, the crime is [involuntary] manslaughter. [Citations.]” (People v. McManis (1954) 122 Cal.App.2d 891, 898 [ 266 P.2d 134 ]; see also People v. Morgan (1969) 275 Cal.App.2d 603, 608 [ 79 Cal.Rptr. 911 ]; People v. Tophia (1959) 167 Cal.App.2d 39, 47-48 [ 334 P.2d 133 ]; People v. Le Grant (1946) 76 Cal.App.2d 148, 152 [ 172 P.2d 554 ]; Pe

11
People v. Morgangreen
calctapp · 1969 · cited in 1 California opinions naming this issue, 2000–2000
2 sentences

2000We recognize, as did the Court of Appeal below, that a line of early California intermediate appellate court decisions, many predating Stuart , held that “where a person, in committing an assault and battery . . . unintentionally causes the death of his victim, the crime is [involuntary] manslaughter. [Citations.]” (People v. McManis (1954) 122 Cal.App.2d 891, 898 [ 266 P.2d 134 ]; see also People v. Morgan (1969) 275 Cal.App.2d 603, 608 [ 79 Cal.Rptr. 911 ]; People v. Tophia (1959) 167 Cal.App.2d 39, 47-48 [ 334 P.2d 133 ]; People v. Le Grant (1946) 76 Cal.App.2d 148, 152 [ 172 P.2d 554 ]; Pe

2000We recognize, as did the Court of Appeal below, that a line of early California intermediate appellate court decisions, many predating Stuart , held that “where a person, in committing an assault and battery . . . unintentionally causes the death of his victim, the crime is [involuntary] manslaughter. [Citations.]” (People v. McManis (1954) 122 Cal.App.2d 891, 898 [ 266 P.2d 134 ]; see also People v. Morgan (1969) 275 Cal.App.2d 603, 608 [ 79 Cal.Rptr. 911 ]; People v. Tophia (1959) 167 Cal.App.2d 39, 47-48 [ 334 P.2d 133 ]; People v. Le Grant (1946) 76 Cal.App.2d 148, 152 [ 172 P.2d 554 ]; Pe

11
Williams v. Stategreen
alactapp · 1936 · cited in 1 California opinions naming this issue, 2000–2000
1 sentence

2000As LaFave and Scott point out, early cases relying on the so-called malum in se/malum prohibitum distinction in fashioning an automatic misdemeanor-manslaughter rule for cases in which the predicate unlawful act *676 resulting in a killing was malum in se (i.e., a misdemeanor committed with general criminal intent) were indeed widespread. (2 LaFave & Scott, Substantive Criminal Law (1986) Crimes Against the Person, § 7.13(d), p. 296 (LaFave & Scott); see, e.g., Broxton v. State (1936) 27 Ala.App. 298 [ 171 So. 390 ]; State v. Boag (1936) 154 Or. 354 [ 59 P.2d 396 ]; State v. Horton (1905) 139

11
Broxton v. Stategreen
· 1936 · cited in 1 California opinions naming this issue, 2000–2000
1 sentence

2000As LaFave and Scott point out, early cases relying on the so-called malum in se/malum prohibitum distinction in fashioning an automatic misdemeanor-manslaughter rule for cases in which the predicate unlawful act *676 resulting in a killing was malum in se (i.e., a misdemeanor committed with general criminal intent) were indeed widespread. (2 LaFave & Scott, Substantive Criminal Law (1986) Crimes Against the Person, § 7.13(d), p. 296 (LaFave & Scott); see, e.g., Broxton v. State (1936) 27 Ala.App. 298 [ 171 So. 390 ]; State v. Boag (1936) 154 Or. 354 [ 59 P.2d 396 ]; State v. Horton (1905) 139

11
People v. Millergreen
calctapp · 1931 · cited in 1 California opinions naming this issue, 2000–2000
2 sentences

2000We recognize, as did the Court of Appeal below, that a line of early California intermediate appellate court decisions, many predating Stuart , held that “where a person, in committing an assault and battery . . . unintentionally causes the death of his victim, the crime is [involuntary] manslaughter. [Citations.]” (People v. McManis (1954) 122 Cal.App.2d 891, 898 [ 266 P.2d 134 ]; see also People v. Morgan (1969) 275 Cal.App.2d 603, 608 [ 79 Cal.Rptr. 911 ]; People v. Tophia (1959) 167 Cal.App.2d 39, 47-48 [ 334 P.2d 133 ]; People v. Le Grant (1946) 76 Cal.App.2d 148, 152 [ 172 P.2d 554 ]; Pe

2000We recognize, as did the Court of Appeal below, that a line of early California intermediate appellate court decisions, many predating Stuart , held that “where a person, in committing an assault and battery . . . unintentionally causes the death of his victim, the crime is [involuntary] manslaughter. [Citations.]” (People v. McManis (1954) 122 Cal.App.2d 891, 898 [ 266 P.2d 134 ]; see also People v. Morgan (1969) 275 Cal.App.2d 603, 608 [ 79 Cal.Rptr. 911 ]; People v. Tophia (1959) 167 Cal.App.2d 39, 47-48 [ 334 P.2d 133 ]; People v. Le Grant (1946) 76 Cal.App.2d 148, 152 [ 172 P.2d 554 ]; Pe

11
People v. Samarjiangreen
calctapp · 1966 · cited in 1 California opinions naming this issue, 1992–1992
2 sentences

1992(People v. Banks (1959) 53 Cal.2d 370, 380-383 [ 1 Cal.Rptr. 669 , 348 P.2d 102 ]; People v. Bozigian (1969) 270 Cal.App.2d 373, 379 [ 75 Cal.Rptr. 876 ]; People v. Samarjian (1966) 240 Cal.App.2d 13, 23 [ 49 Cal.Rptr. 180 ].) There was no basis for a misdemeanor-manslaughter instruction. 9.

1992(People v. Banks (1959) 53 Cal.2d 370, 380-383 [ 1 Cal.Rptr. 669 , 348 P.2d 102 ]; People v. Bozigian (1969) 270 Cal.App.2d 373, 379 [ 75 Cal.Rptr. 876 ]; People v. Samarjian (1966) 240 Cal.App.2d 13, 23 [ 49 Cal.Rptr. 180 ].) There was no basis for a misdemeanor-manslaughter instruction. 9.

11
People v. Bozigiangreen
calctapp · 1969 · cited in 1 California opinions naming this issue, 1992–1992
2 sentences

1992(People v. Banks (1959) 53 Cal.2d 370, 380-383 [ 1 Cal.Rptr. 669 , 348 P.2d 102 ]; People v. Bozigian (1969) 270 Cal.App.2d 373, 379 [ 75 Cal.Rptr. 876 ]; People v. Samarjian (1966) 240 Cal.App.2d 13, 23 [ 49 Cal.Rptr. 180 ].) There was no basis for a misdemeanor-manslaughter instruction. 9.

1992(People v. Banks (1959) 53 Cal.2d 370, 380-383 [ 1 Cal.Rptr. 669 , 348 P.2d 102 ]; People v. Bozigian (1969) 270 Cal.App.2d 373, 379 [ 75 Cal.Rptr. 876 ]; People v. Samarjian (1966) 240 Cal.App.2d 13, 23 [ 49 Cal.Rptr. 180 ].) There was no basis for a misdemeanor-manslaughter instruction. 9.

11
People v. Banksgreen
cal · 1959 · cited in 1 California opinions naming this issue, 1992–1992
2 sentences

1992(People v. Banks (1959) 53 Cal.2d 370, 380-383 [ 1 Cal.Rptr. 669 , 348 P.2d 102 ]; People v. Bozigian (1969) 270 Cal.App.2d 373, 379 [ 75 Cal.Rptr. 876 ]; People v. Samarjian (1966) 240 Cal.App.2d 13, 23 [ 49 Cal.Rptr. 180 ].) There was no basis for a misdemeanor-manslaughter instruction. 9.

1992(People v. Banks (1959) 53 Cal.2d 370, 380-383 [ 1 Cal.Rptr. 669 , 348 P.2d 102 ]; People v. Bozigian (1969) 270 Cal.App.2d 373, 379 [ 75 Cal.Rptr. 876 ]; People v. Samarjian (1966) 240 Cal.App.2d 13, 23 [ 49 Cal.Rptr. 180 ].) There was no basis for a misdemeanor-manslaughter instruction. 9.

11
People v. Burroughsgreen
cal · 1984 · cited in 1 California opinions naming this issue, 1986–1986
2 sentences

1986(See People v. Burroughs (1984) 35 Cal.3d 824, 835 [ 201 Cal.Rptr. 319 , 678 P.2d 894 ]; and People v. Morales (1975) 49 Cal.App.3d 134 [ 122 Cal.Rptr. 157 ].) Defendant argues, by analogy to this “felony manslaughter” doctrine, that the misdemeanor manslaughter doctrine should be extended to noninherently dangerous misdemeanors committed without due caution and circumspection, and that he should have been given the benefit of such an extension in the instructions to the jury.

1986(See People v. Burroughs (1984) 35 Cal.3d 824, 835 [ 201 Cal.Rptr. 319 , 678 P.2d 894 ]; and People v. Morales (1975) 49 Cal.App.3d 134 [ 122 Cal.Rptr. 157 ].) Defendant argues, by analogy to this “felony manslaughter” doctrine, that the misdemeanor manslaughter doctrine should be extended to noninherently dangerous misdemeanors committed without due caution and circumspection, and that he should have been given the benefit of such an extension in the instructions to the jury.

11
People v. Buttsgreen
calctapp · 1965 · cited in 1 California opinions naming this issue, 1984–1984
11
People v. Satchellgreen
cal · 1971 · cited in 1 California opinions naming this issue, 1984–1984
11
People v. Schadergreen
cal · 1965 · cited in 1 California opinions naming this issue, 1984–1984
11
People v. Kerrickgreen
calctapp · 1927 · cited in 1 California opinions naming this issue, 1984–1984
11
Auto Equity Sales, Inc. v. Superior Courtgreen
cal · 1962 · cited in 1 California opinions naming this issue, 1982–1982
11
People v. Escarcegagreen
calctapp · 1969 · cited in 1 California opinions naming this issue, 1972–1972
11
People v. Lilliockgreen
calctapp · 1968 · cited in 1 California opinions naming this issue, 1972–1972
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (11)

CaseCitedYears
People v. Blair green
cal · 2005
1 sentence

2014(See People v. Rogers, supra, 39 Cal.4th at pp. 866–867; People v. Blair (2005) 36 Cal.4th 686 , 744–745.) Nonetheless, when, as occurred here, a defendant’s trial counsel cites one or more specific statutes as the basis for a misdemeanor manslaughter instruction, and the trial judge concludes that the cited statutes are not a proper basis for the instruction, we do not believe the judge is required to comb the Penal Code in search of an alternative statutory basis for the instruction. 19 Second, “where involuntary manslaughter is predicated on an unlawful act constituting a misdemeanor, it mu

12014–2014
People v. Morse green
calctapp · 1992
1 sentence

2014In support of this contention, respondent cites People v. Morse (1992) 2 Cal.App.4th 620, 647 , which held that a wobbler is a felony for all purposes unless and until it is validly reduced to a misdemeanor.

12014–2014
People v. Tufunga green
cal · 1999
1 sentence

2014(People v. Tufunga (1999) 21 Cal.4th 935, 944 .) At trial, appellant requested a misdemeanor manslaughter instruction on the theory that the homicide occurred in the course of a violation of former section 12025, subsection (a)(3), which has since been recodified as section 25400, subsection (a)(3).14 Former section 12025, subdivision (a)(3) made it a crime to “[c]ause[] to be carried concealed within any vehicle in which [the defendant] is an occupant any pistol, revolver, or other firearm capable of being concealed upon the person.” Appellant’s theory at trial, which he reiterates on appeal,

12014–2014
People v. Rogers green
cal · 2006
2 sentences

2014As to his first contention, appellant quotes People v. Rogers (2006) 39 Cal.4th 826 for the proposition that “[a]n instruction on involuntary manslaughter is required whenever there is substantial evidence indicating the defendant did not actually form the intent to kill.” (Id. at p. 884.) Appellant has taken this quotation out of context, however.

2014(See People v. Rogers, supra, 39 Cal.4th at pp. 866–867; People v. Blair (2005) 36 Cal.4th 686 , 744–745.) Nonetheless, when, as occurred here, a defendant’s trial counsel cites one or more specific statutes as the basis for a misdemeanor manslaughter instruction, and the trial judge concludes that the cited statutes are not a proper basis for the instruction, we do not believe the judge is required to comb the Penal Code in search of an alternative statutory basis for the instruction. 19 Second, “where involuntary manslaughter is predicated on an unlawful act constituting a misdemeanor, it mu

12014–2014
People v. Cox green
cal · 2000
2 sentences

2014The court further held that “where involuntary manslaughter is predicated on an unlawful act constituting a misdemeanor, it must still be shown that such misdemeanor was dangerous to human life or safety under the circumstances of its commission.” (People v. Cox, supra, 23 Cal.4th at p. 675 .) Accordingly, the Court disapproved earlier cases adopting “a misdemeanor-manslaughter rule that automatically establishes the offense of involuntary manslaughter whenever a killing results from the commission of any misdemeanor . . . .” (Ibid.) Thus, People v. Cox is flatly inconsistent with appellant’s

2014(See People v. Rogers, supra, 39 Cal.4th at pp. 866–867; People v. Blair (2005) 36 Cal.4th 686 , 744–745.) Nonetheless, when, as occurred here, a defendant’s trial counsel cites one or more specific statutes as the basis for a misdemeanor manslaughter instruction, and the trial judge concludes that the cited statutes are not a proper basis for the instruction, we do not believe the judge is required to comb the Penal Code in search of an alternative statutory basis for the instruction. 19 Second, “where involuntary manslaughter is predicated on an unlawful act constituting a misdemeanor, it mu

12014–2014
State v. Puryear green
arizctapp · 1979
2 sentences

2000As LaFave and Scott point out, early cases relying on the so-called malum in se/malum prohibitum distinction in fashioning an automatic misdemeanor-manslaughter rule for cases in which the predicate unlawful act *676 resulting in a killing was malum in se (i.e., a misdemeanor committed with general criminal intent) were indeed widespread. (2 LaFave & Scott, Substantive Criminal Law (1986) Crimes Against the Person, § 7.13(d), p. 296 (LaFave & Scott); see, e.g., Broxton v. State (1936) 27 Ala.App. 298 [ 171 So. 390 ]; State v. Boag (1936) 154 Or. 354 [ 59 P.2d 396 ]; State v. Horton (1905) 139

2000As LaFave and Scott point out, early cases relying on the so-called malum in se/malum prohibitum distinction in fashioning an automatic misdemeanor-manslaughter rule for cases in which the predicate unlawful act *676 resulting in a killing was malum in se (i.e., a misdemeanor committed with general criminal intent) were indeed widespread. (2 LaFave & Scott, Substantive Criminal Law (1986) Crimes Against the Person, § 7.13(d), p. 296 (LaFave & Scott); see, e.g., Broxton v. State (1936) 27 Ala.App. 298 [ 171 So. 390 ]; State v. Boag (1936) 154 Or. 354 [ 59 P.2d 396 ]; State v. Horton (1905) 139

12000–2000
State v. Horton. green
· 1905
2 sentences

2000As LaFave and Scott point out, early cases relying on the so-called malum in se/malum prohibitum distinction in fashioning an automatic misdemeanor-manslaughter rule for cases in which the predicate unlawful act *676 resulting in a killing was malum in se (i.e., a misdemeanor committed with general criminal intent) were indeed widespread. (2 LaFave & Scott, Substantive Criminal Law (1986) Crimes Against the Person, § 7.13(d), p. 296 (LaFave & Scott); see, e.g., Broxton v. State (1936) 27 Ala.App. 298 [ 171 So. 390 ]; State v. Boag (1936) 154 Or. 354 [ 59 P.2d 396 ]; State v. Horton (1905) 139

2000As LaFave and Scott point out, early cases relying on the so-called malum in se/malum prohibitum distinction in fashioning an automatic misdemeanor-manslaughter rule for cases in which the predicate unlawful act *676 resulting in a killing was malum in se (i.e., a misdemeanor committed with general criminal intent) were indeed widespread. (2 LaFave & Scott, Substantive Criminal Law (1986) Crimes Against the Person, § 7.13(d), p. 296 (LaFave & Scott); see, e.g., Broxton v. State (1936) 27 Ala.App. 298 [ 171 So. 390 ]; State v. Boag (1936) 154 Or. 354 [ 59 P.2d 396 ]; State v. Horton (1905) 139

12000–2000
People v. Wells green
cal · 1996
1 sentence

2000We recognize, as did the Court of Appeal below, that a line of early California intermediate appellate court decisions, many predating Stuart , held that “where a person, in committing an assault and battery . . . unintentionally causes the death of his victim, the crime is [involuntary] manslaughter. [Citations.]” (People v. McManis (1954) 122 Cal.App.2d 891, 898 [ 266 P.2d 134 ]; see also People v. Morgan (1969) 275 Cal.App.2d 603, 608 [ 79 Cal.Rptr. 911 ]; People v. Tophia (1959) 167 Cal.App.2d 39, 47-48 [ 334 P.2d 133 ]; People v. Le Grant (1946) 76 Cal.App.2d 148, 152 [ 172 P.2d 554 ]; Pe

12000–2000
State v. Boag green
or · 1936
2 sentences

2000As LaFave and Scott point out, early cases relying on the so-called malum in se/malum prohibitum distinction in fashioning an automatic misdemeanor-manslaughter rule for cases in which the predicate unlawful act *676 resulting in a killing was malum in se (i.e., a misdemeanor committed with general criminal intent) were indeed widespread. (2 LaFave & Scott, Substantive Criminal Law (1986) Crimes Against the Person, § 7.13(d), p. 296 (LaFave & Scott); see, e.g., Broxton v. State (1936) 27 Ala.App. 298 [ 171 So. 390 ]; State v. Boag (1936) 154 Or. 354 [ 59 P.2d 396 ]; State v. Horton (1905) 139

2000As LaFave and Scott point out, early cases relying on the so-called malum in se/malum prohibitum distinction in fashioning an automatic misdemeanor-manslaughter rule for cases in which the predicate unlawful act *676 resulting in a killing was malum in se (i.e., a misdemeanor committed with general criminal intent) were indeed widespread. (2 LaFave & Scott, Substantive Criminal Law (1986) Crimes Against the Person, § 7.13(d), p. 296 (LaFave & Scott); see, e.g., Broxton v. State (1936) 27 Ala.App. 298 [ 171 So. 390 ]; State v. Boag (1936) 154 Or. 354 [ 59 P.2d 396 ]; State v. Horton (1905) 139

12000–2000
People v. Morales green
calctapp · 1975
2 sentences

1986(See People v. Burroughs (1984) 35 Cal.3d 824, 835 [ 201 Cal.Rptr. 319 , 678 P.2d 894 ]; and People v. Morales (1975) 49 Cal.App.3d 134 [ 122 Cal.Rptr. 157 ].) Defendant argues, by analogy to this “felony manslaughter” doctrine, that the misdemeanor manslaughter doctrine should be extended to noninherently dangerous misdemeanors committed without due caution and circumspection, and that he should have been given the benefit of such an extension in the instructions to the jury.

1986(See People v. Burroughs (1984) 35 Cal.3d 824, 835 [ 201 Cal.Rptr. 319 , 678 P.2d 894 ]; and People v. Morales (1975) 49 Cal.App.3d 134 [ 122 Cal.Rptr. 157 ].) Defendant argues, by analogy to this “felony manslaughter” doctrine, that the misdemeanor manslaughter doctrine should be extended to noninherently dangerous misdemeanors committed without due caution and circumspection, and that he should have been given the benefit of such an extension in the instructions to the jury.

11986–1986
People v. Williams green
cal · 1975
11982–1982

Statutes the citing opinions construe

CA § Cal. Penal Code § 192 (8) CA § Cal. Penal Code § 187 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 13 (1972–2025) OK 6 (1973–2024) MI 4 (1994–2004) AK 3 (1980–2018) NM 2 (1996–2009) DC 2 (1990–1999)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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