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

Wash. Rev. Code § 9A.32.070 (2026)

Manslaughter in the second degree

✓ current as of May 2026
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(1) A person is guilty of manslaughter in the second degree when, with criminal negligence, he or she causes the death of another person.
(2) Manslaughter in the second degree is a class B felony.
[ 2011 c 336 s 358; 1997 c 365 s 6; 1975 1st ex.s. c 260 s 9A.32.070.]
Notes of Decisions
Cited in 88 cases (12 in the last 5 years), 1978–2025 · leading case: State v. Numrich, 480 P.3d 376 (Wash. 2021).
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State v. Numrich, 480 P.3d 376 (Wash. 2021). · cites it 7× “Procedural history On January 5, 2018, the State initially charged Numrich with manslaughter in the second degree (RCW 9A.32.070) (count 1) and violation of labor safety regulation with 4 No.”
State v. Gamble, 114 P.3d 646 (Wash. 2005). · cites it 4× “RCW 9A.32.070, .050(b). ¶ 41 Discriminatory treatment is not the purpose of our criminal code, yet, inexplicably, permitting either manslaughter or felony murder to be charged for the very same act creates and condones a double standard.”
State v. Gamble, 154 Wash. 2d 457 (Wash. 2005). · cites it 4× “RCW 9A.32.070, .050(1)(b). Chambers, J. ¶41 Discriminatory treatment is not the purpose of our criminal code, yet, inexplicably, permitting either manslaughter or felony murder to be charged for the very same act creates and condones a double standard.”
State v. Sublett, 292 P.3d 715 (Wash. 2012). · cites it 2× “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. Aten, 927 P.2d 210 (Wash. 1996). · cites it 3× “See RCW 9A.32.070, "A person is guilty of manslaughter in the second degree when, with criminal negligence, [that person] causes the death of another person.”
United States v. Gomez-Leon, 545 F.3d 777 (9th Cir. 2008). · cites it 2× “2d 286, 291 (1990)); Wash. Rev.Code § 9A.32.070 (offense called "manslaughter in the second degree" but requires criminal negligence).”
State v. McCullum, 656 P.2d 1064 (Wash. 1983). · cites it 2× “060; RCW 9A.32.070. The Legislature also placed the homicide justification of self-defense under the provisions of RCW 9A.”
State v. Smith, 610 P.2d 869 (Wash. 1980). · cites it 2× “All of the following offenses, each far more serious than possessing over 40 grams of marijuana, are class C felonies and subject a guilty person to 5 years in the state penitentiary or a maximum fine of $5,000 or both: second-degree manslaughter, when, with criminal negligence,…”
State v. Tamalini, 953 P.2d 450 (Wash. 1998). · cites it 2× “On the other hand, a person commits first degree manslaughter when he or she recklessly causes death or intentionally and unlawfully kills an unborn child by inflicting injury on the mother.”
State v. Gamble, 225 P.3d 973 (Wash. 2010). “RCW 9A.32.070. A person acts with criminal negligence "when he or she fails to be aware of a substantial risk that a wrongful act may occur and his or her failure to be aware of such substantial risk constitutes a gross deviation from the standard of care that a reasonable…”
State v. Gamble, 168 Wash. 2d 161 (Wash. 2010). “RCW 9A.32.070. A person acts with criminal negligence “when he or she fails to be aware of a substantial risk that a wrongful act may occur and his or her failure to be aware of such substantial risk constitutes a gross deviation from the standard of care that a reasonable…”
State v. Norman, 808 P.2d 1159 (Wash. Ct. App. 1991). · cites it 2× “060, and with criminal negligence causing the death of another, RCW 9A.32.070. Mr. Norman's argument the penal statute violates his free exercise of religion is one that has been addressed and dismissed by numerous courts across the land.”
Show all 88 citing cases →
— Wash. Rev. Code § 9A.32.070(1) — 44 cases
State v. Gamble, 114 P.3d 646 (Wash. 2005). “RCW 9A.32.070, .050(b). ¶ 41 Discriminatory treatment is not the purpose of our criminal code, yet, inexplicably, permitting either manslaughter or felony murder to be charged for the very same act creates and condones a double standard.”
State v. Gamble, 154 Wash. 2d 457 (Wash. 2005). “RCW 9A.32.070, .050(1)(b). Chambers, J. ¶41 Discriminatory treatment is not the purpose of our criminal code, yet, inexplicably, permitting either manslaughter or felony murder to be charged for the very same act creates and condones a double standard.”
State v. Aten, 927 P.2d 210 (Wash. 1996). “See RCW 9A.32.070, "A person is guilty of manslaughter in the second degree when, with criminal negligence, [that person] causes the death of another person.”
State v. Sublett, 292 P.3d 715 (Wash. 2012). “A person who is an accomplice in the commission of a crime is guilty of that crime whether present at the scene or not.”
Bowman v. State, 172 P.3d 681 (Wash. 2007).
— Wash. Rev. Code § 9A.32.070(2) — 3 cases
State v. Davis, 846 P.2d 527 (Wash. 1993).
State Of Washington v. Kevin Lee Garrison (Wash. Ct. App. 2015).
State Of Washington v. Kevin Lee Garrison (Wash. Ct. App. 2015).
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