Wash. Rev. Code » Title 9A · Chapter 9A.32
Revised Code of Washington

Wash. Rev. Code § 9A.32.060 (2026)

Manslaughter in the first degree

✓ current as of May 2026
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(1) A person is guilty of manslaughter in the first degree when:
(a) He or she recklessly causes the death of another person; or
(b) He or she intentionally and unlawfully kills an unborn quick child by inflicting any injury upon the mother of such child.
(2) Manslaughter in the first degree is a class A felony.
[ 2011 c 336 s 357; 1997 c 365 s 5; 1975 1st ex.s. c 260 s 9A.32.060.]
Notes of Decisions
Cited in 147 cases (11 in the last 5 years), 1978–2026 · leading case: State v. Gamble, 114 P.3d 646 (Wash. 2005).
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State v. Gamble, 114 P.3d 646 (Wash. 2005). · cites it 5× “The State must prove all essential elements of the above two offenses in order to achieve a guilty verdict for second degree felony murder.”
State v. Gamble, 154 Wash. 2d 457 (Wash. 2005). · cites it 5× “The State must prove all essential elements of the above two offenses in order to achieve a guilty verdict for second degree felony murder.”
In Re the Pers. Restraint of Montoya, 744 P.2d 340 (Wash. 1987). · cites it 3× “On July 20, 1983, the prosecuting attorney filed an amended information which charged Montoya with first degree manslaughter under RCW 9A.32.060(l)(a) and stated that the maximum penalty was 10 years and/ or $20,000.”
State v. Berlin, 947 P.2d 700 (Wash. 1997). · cites it 2× “RCW 9A.32.060(l)(a). The elements of manslaughter in the second degree are that the defendant, with criminal negligence, causes the death of another person.”
State v. Dennison, 801 P.2d 193 (Wash. 1990). · cites it 2× “Dennison's assumption that second degree murder and first and second degree manslaughter are lesser included offenses of felony murder is incorrect.”
State v. Acosta, 683 P.2d 1069 (Wash. 1984). · cites it 2× “Similarly, in Hanton , we held that evidence of self-defense negated the element of "recklessness" in the first degree manslaughter statute, RCW 9A.32.060(1)(a). There we focused upon the requirement of wrongful action in the definition of recklessness.”
State v. Gamble, 118 Wash. App. 332 (Wash. Ct. App. 2003). · cites it 3× “See RCW 9A.32.060(l)(a). *335 Gamble and others beat Carroll to death at a party in Vancouver, Washington, on March 26, 1999.”
State v. Sublett, 292 P.3d 715 (Wash. 2012). “However, more than mere presence and knowledge of the criminal activity of another must be shown to establish that a person is an accomplice. A person who is an accomplice in the commission of a crime is guilty of that crime whether present at the scene or not.”
State v. Shipp, 610 P.2d 1322 (Wash. 1980). · cites it 2× “For example, under this redefinition, it would be possible to convict every negligent driver who causes injury, in a situation where the ordinary person would have known that injury would result, of second-degree assault, because RCW 9A.36.020(1)(b) makes it a class B felony,…”
In Re Burchfield, 46 P.3d 840 (Wash. Ct. App. 2002). · cites it 3× “011 reads: (1) A person is guilty of assault in the first degree if he or she, with intent to inflict great bodily harm: (a) Assaults another with a firearm or any deadly weapon or by any force or means likely to produce great bodily harm or death; or (b) Administers, exposes,…”
State v. Pascal, 736 P.2d 1065 (Wash. 1987). · cites it 2× “RCW 9A.32.060. Reckless conduct involves knowingly disregarding a substantial risk that a wrongful act may occur where such disregard is a gross deviation from conduct that a reasonable person would exercise in the same situation.”
In re the Pers. Restraint of Breedlove, 979 P.2d 417 (Wash. 1999). · cites it 2× “021 (setting maximum sentences); former RCW 9A.32.060 (first degree manslaughter); 2 RCW 9A.”
Show all 147 citing cases →
— Wash. Rev. Code § 9A.32.060(1) — 8 cases
State v. Davis, 827 P.2d 298 (Wash. Ct. App. 1992).
State v. Gilmer, 981 P.2d 902 (Wash. Ct. App. 1999).
State v. Berlin, 911 P.2d 414 (Wash. Ct. App. 1996).
State v. Gamble, 155 P.3d 962 (Wash. Ct. App. 2007).
State v. Gamble, 137 Wash. App. 892 (Wash. Ct. App. 2007).
— Wash. Rev. Code § 9A.32.060(1)(a) — 58 cases
State v. Gamble, 114 P.3d 646 (Wash. 2005). “The State must prove all essential elements of the above two offenses in order to achieve a guilty verdict for second degree felony murder.”
State v. Gamble, 154 Wash. 2d 457 (Wash. 2005). “The State must prove all essential elements of the above two offenses in order to achieve a guilty verdict for second degree felony murder.”
State v. Gamble, 225 P.3d 973 (Wash. 2010).
State v. Gamble, 168 Wash. 2d 161 (Wash. 2010).
State v. Creekmore, 783 P.2d 1068 (Wash. Ct. App. 1990).
— Wash. Rev. Code § 9A.32.060(1)(b) — 2 cases
State v. Lamy, 969 A.2d 451 (N.H. 2009).
Baum v. Burrington, 79 P.3d 456 (Wash. Ct. App. 2003).
— Wash. Rev. Code § 9A.32.060(1975) — 1 case
In re Pers. Restraint of Canha (Wash. 2017).
— Wash. Rev. Code § 9A.32.060(2) — 4 cases
In re the Pers. Restraint of Breedlove, 979 P.2d 417 (Wash. 1999). “021 (setting maximum sentences); former RCW 9A.32.060 (first degree manslaughter); 2 RCW 9A.”
In Re Breedlove, 979 P.2d 417 (Wash. 1999).
State Of Washington v. Skylar Nemetz (Wash. Ct. App. 2018).
State Of Washington V. Ivan Lopez Gutierrez (Wash. Ct. App. 2025).
— Wash. Rev. Code § 9A.32.060(l)(a) — 26 cases
In Re the Pers. Restraint of Montoya, 744 P.2d 340 (Wash. 1987). “On July 20, 1983, the prosecuting attorney filed an amended information which charged Montoya with first degree manslaughter under RCW 9A.32.060(l)(a) and stated that the maximum penalty was 10 years and/ or $20,000.”
State v. Berlin, 947 P.2d 700 (Wash. 1997). “RCW 9A.32.060(l)(a). The elements of manslaughter in the second degree are that the defendant, with criminal negligence, causes the death of another person.”
State v. Gamble, 118 Wash. App. 332 (Wash. Ct. App. 2003). “See RCW 9A.32.060(l)(a). *335 Gamble and others beat Carroll to death at a party in Vancouver, Washington, on March 26, 1999.”
State v. Hanton, 614 P.2d 1280 (Wash. 1980).
State v. Hughes, 118 Wash. App. 713 (Wash. Ct. App. 2003).
— Wash. Rev. Code § 9A.32.060(l)(b) — 3 cases
Ankrom v. State, 152 So. 3d 397 (Ala. 2013).
State v. Dunn, 916 P.2d 952 (Wash. Ct. App. 1996).
Baum v. Burrington, 79 P.3d 456 (Wash. Ct. App. 2003).
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