and have chosen to abandon the misdemeanor-manslaughter rule. See, e.g., State v. Pray, 378 A.2d 1322, 1323 (Me.1977) (acknowledging that criminal negligence had been required for misdemeanor-manslaughter rule, but choosing to abolish the entire doctrine in Maine); Commonwealth v. Catalina, 407 Mass. 779, 556 N.E.2d 973, 978 (1990) (noting the strong trend away from the misdemeanor-manslaughter rule and holding “that unlawful-act manslaughter should be abandoned in Massachusetts except for appropriate cases which are based on the principle that a battery that causes death is manslaughter”). Other jurisdictions require that the predicate misdemeanor for misdemeanor manslaughter be either inherently dangerous or malum in se. See, e.g., Comber v. United States, 584 A.2d 26, 50 (D.C.1990) (<HOLDING>); Schlossman v. State, 105 Md.App. 277, 659
holding that begay rejected that circuits earlier approach under which an offense presented a serious potential risk of physical injury to another if the offense conduct had the potential for serious physical injury to another holding method of merchandising and nature of article causing injury more important than length of time dangerous article has been in area in which injury occurs holding that under the misdemeanormanslaughter rule the category of misdemeanors dangerous in and of themselves encompasses misdemeanors which bear an inherent danger of physical injury recognizing inherent power of courts of appeals holding that the malum in se commonlaw misdemeanor of intentional battery was a sufficient predicate offense even though not inherently dangerous to support a misdemeanormanslaughter conviction