If you were negligent in causing that car accident or dropping your weapon, and someone died, you could be charged with involuntary manslaughter. A spontaneous bludgeoning, resulting in death, could end with the perpetrator being charged with the more serious crime of voluntary manslaughter. Second - degree murder, a close cousin to voluntary manslaughter, had the element of malice aforethought, and possibly recklessness, but not the additional one of premeditation, or lying in wait, as it was often called. Decker sipped his beer as he went through the legal requirements of intentionally ending the life of another. The last one was the worst of all, in his estimation. First-degree murder almost always required the specific elements of willfulness, premeditation, and malice aforethought.