California, United States of America
The following excerpt is from People v. Reyes, G059720 (Cal. App. 2021):
However, because involuntary manslaughter is not a lesser included offense of voluntary manslaughter (see, People v. Orr (1994) 22 Cal.App.4th 780, 784-785), the parties were unable to agree on appropriate instructions. Noting that no published case had viewed involuntary manslaughter as a lesser included offense of voluntary manslaughter, the trial court indicated it was not inclined to instruct the jury as though it were.
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