What is the legal test for a reduction of murder to voluntary manslaughter?

^9. We rely on cases involving the reduction of murder to voluntary manslaughter for the applicable legal principles. For our purposes, there is no meaningful difference between the completed crime and an attempt, although we recognize attempted voluntary manslaughter, unlike voluntary manslaughter, requires an intent to kill. (Compare People v. Lasko (2000) 23 Cal.4th 101, 108 with People v. Montes (2003) 112 Cal.App.4th 1543, 1546-1547.) Because of this requirement, defendant's suggestion the injuries inflicted in this case support the inference he lacked the intent to kill and so were more consistent with attempted voluntary manslaughter than attempted murder, is based on a legally erroneous premise.

^10. There is no additional requirement that an ordinary person of average disposition "would act rashly in a particular manner, namely, by killing." (People v. Beltran (2013) 56 Cal.4th 935, 942.)