Manslaughter
Manslaughter: an unlawful killing without malice aforethought.
Voluntary Manslaughter
- An intentional killing, but mitigated from murder.
- Classic mitigation: heat of passion + adequate provocation + before cooling time + provocation came from the victim.
- See Massachusetts v. Hinds, 927 N.E.2d 1009 (Mass. 2010) (provocation must come from the victim).
- Imperfect self-defense (killing on unreasonable but honest belief in necessity) also reduces murder to voluntary manslaughter in many jurisdictions.
Involuntary Manslaughter
- An unintentional killing.
- CL Majority (criminally negligent homicide):
- ∆ should have known of a substantial and unjustifiable risk.
- Gross deviation from the standard of care—so gross that public-law punishment is warranted.
- MPC § 210.3 / § 210.4:
- Recklessness (manslaughter), OR
- What would otherwise be murder, but committed under extreme mental or emotional disturbance for which there is reasonable explanation.
Did ∆ KNOW About the Risk? (mens rea ladder)
- "I know this could kill someone... and I don't care." → Extreme Recklessness / Depraved Heart Murder (Second Degree Murder).
- "I know there's a risk, but I underestimate it." → Recklessness (MPC manslaughter; few CL jurxs.).
- "I didn't realize the big risk, but I should have." → Criminal Negligence (involuntary manslaughter).
Compared with Depraved-Heart Murder
- Both are unintentional.
- Depraved heart: extreme recklessness, malice imputed.
- Involuntary manslaughter: criminal negligence OR ordinary recklessness.
Cases:
- Massachusetts v. Hinds, 927 N.E.2d 1009 (Mass. 2010) — voluntary manslaughter; provocation requirement.
- Noakes v. Virginia — IM via gross negligence (cardboard crib cover).
- State v. Powell — IM via intentional violation of safety ordinance (loose dogs).
- People v. McCoy — IM via gross negligence (speeding).