People v. Van Ronk
California Court of Appeal, Third District
217 Cal.Rptr. 581 (1985)
During a dispute over an undelivered marijuana purchase and a woman refusing to leave with him, Van Ronk (defendant) told James Gravelle "I should kill you," then shot him three times, also firing at two other people present without hitting them. Convicted of attempted voluntary manslaughter after claiming self-defense at trial, Van Ronk argued on appeal that attempted voluntary manslaughter is a legally impossible crime because manslaughter's heat-of-passion mitigation cannot logically be "planned" or attempted.
Whether, in California, a charge of attempted voluntary manslaughter requires that the defendant possessed a specific intent to kill, even though death did not result.