rule. The “unlawful act” course of conduct embodies the “misdemeanor-manslaughter rule” under which a criminal defendant is guilty of a felony for killing a human being while in the commission of a misdemeanor. Wayne R. LaFave & Austin W. Scott, Substantive Criminal Law § 7.13(a), at 288 (1986) 83, 784 (1971) (concluding that violations of the motor vehicle code are not necessarily the unlawful act contemplated in misdemeanor-manslaughter, and that to sustain a conviction “it must be established that such violation in itself, or together with the surrounding circumstances, ‘evidence a disregard of human life or an indifference to consequences’ ” (quoting Commonwealth v. Holman, 160 Pa.Super. 211, 50 A.2d 720, 721 (1947))); Holder v. State, 152 Tenn. 390, 277 S.W. 900 (1925) (<HOLDING>); State v. Beayon, 158 Vt. 133, 605 A.2d 527,
holding that a minormisdemeanor such as the failure to stop at a stop sign could not be a predicate offence for misdemeanormanslaughter because it did not show the necessary intent or recklessness holding that the only showing of intent required for a vcea claim is the intent to do the act involved holding that the misdemeanormanslaughter rule requires a showing of intent or the commission of an act in such a maimer as to make the killing of deceased a natural or probable result of such conduct holding intent to intimidate or threaten may be proved by circumstantial evidence such as ones conduct or statements holding that such conduct or the causing of the result must have been the persons conscious objective