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490 Pa. 187

415 A.2d 403

Commonwealth v. Williams

Supreme Court of Pennsylvania

Decided June 10, 1980

Supreme Court of Pennsylvania · decided 1980-06-10

Key passage — most relied on by later courts

“§ 2501. Criminal Homicide (a) Offense defined. — A person is guilty of criminal homicide if he intentionally, knowingly, recklessly or negligently causes the death of another human being. (b) Classification. — Criminal homicide shall be classified as murder, voluntary manslaughter, or involuntary manslaughter.”

quoted by 1 later decision, including Commonwealth v. Pfaff

Relies on Commonwealth v. Garcia

Good law ✅— No negative treatment on recordhow we know

Decided 1980-06-10

How this case has been cited

Cited by 70 later decisions — most recently January 2019 · most notably Commonwealth v. Zettlemoyer (1982), Commonwealth v. Frey (1984)

67 state decisions

4201980199020002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

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ROBERTS, Justice,

¶1dissenting.

¶2For all the reasons set forth in Commonwealth v. Garcia, 474 Pa. 449, 378 A.2d 1199 (1977) (plurality opinion) (Roberts, J., joined by O’Brien & Manderino, JJ.), I would reject the holding of the majority that under the Crimes Code an accused is entitled to an instruction on involuntary manslaughter only where the evidence supports that verdict. Section 2501(a) of the Crimes Code, 18 Pa.C.S. § 2501(a), defines “criminal homicide” as follows:

“Offense defined. — A person is guilty of criminal homicide if he intentionally, knowingly, recklessly or negligently causes the death of another human being.”

¶3As the Reporter’s Comment to Section 2501 points out, “[section 2501] defines the unified offense of ‘criminal homicide,’ which includes murder, voluntary manslaughter or involuntary manslaughter.” Toll, Pennsylvania Crimes Code Annotated 307 (1974). Thus I remain convinced that “[t]he state of mind which suffices to establish the commission of involuntary manslaughter constitutes a lesser kind of culpability than the malice which is an essential element to murder.” Id., 474 Pa. at 464, 378 A.2d at 1207. So too, I adhere to the view that *194Id.,474 Pa. at 465, 378 A.2d at 1207-1208. Accordingly, as in Garcia, I would hold that under the Crimes Code “in every murder prosecution a defendant is entitled, upon request, to a jury instruction on involuntary manslaughter.” Id.,474 Pa. at 469, 378 A.2d at 1210. Because the trial court failed to grant appellant’s timely request for an involuntary manslaughter instruction, this Court should reverse judgment of sentence on the murder conviction and remand for a new trial.

*193“involuntary manslaughter, which is defined as a killing committed in a reckless or grossly negligent manner, [18 Pa. C.S.] § 2504, also may be committed when a killing is committed intentionally or knowingly. Under the Crimes Code the categories of murder and voluntary manslaughter on the one hand, and involuntary manslaughter on the other, are not mutually exclusive categories. Because an intentional or knowing killing also establishes a negligent killing, all criminal homicides necessarily include involun-. tary manslaughter as a constituent offense.”
*194O’BRIEN, J., joins in this dissenting opinion.
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