The difference between other homicide offenses and involuntary manslaughter depends on whether the person was aware of the risk to life that his or her actions created and consciously disregarded that risk. An unlawful killing caused by a willful act done with full knowledge and awareness that the person is endangering the life of another, and done in conscious disregard of that risk, is voluntary manslaughter or murder. An unlawful killing resulting from a willful act committed without intent to kill and without conscious disregard of the risk to human life is involuntary manslaughter.

The defendant committed involuntary manslaughter if:

1.      The defendant (committed a crime that posed a high risk of death or great bodily injury because of the way in which it was committed/ [or] committed a lawful act, but acted with criminal negligence);

AND

2.      The defendant’s acts unlawfully caused the death of another person.

[The People allege that the defendant committed the following crime[s]:             <insert misdemeanor[s]/infraction[s])/
noninherently dangerous (felony/felonies)>.

Instruction[s] ______________  tell[s] you what the People must prove

in order to prove that the defendant committed  <insert misdemeanor[s]/infraction[s])/ noninherently dangerous (felony/felonies)>.]

[The People [also] allege that the defendant committed the following lawful act[s] with criminal negligence: ___________________________________________
<insert act[s] alleged>.]