Id. (emphasis added). Thus, the dicta in this footnote, contrary to the holding expressed in the main body of the opinion, provided that a person may be convicted of attempted murder if evidence showed that he or she acted knowingly or intentionally. Based on this footnote in Vigil, the trial court and the court of appeals denied Casey's challenges to the jury instructions concerning attempted murder. 3. Other Utah Cases Concerning Attempted Murder 283 In other cases in which we have discussed the level of culpability necessary to convict a defendant of attempted murder, we have consistently required intentional conduct. A month before we decided Maestas, we held that an attempted manslaughter conviction requires intentional conduct. See State v. Howell, 649 P.2d 91 (Utah 1982) (<HOLDING>). In that case, we reasoned "that one cannot be
holding that one can be convicted of attempted manslaughter under the subsections of section 765205 that require intentional conduct but not under the subsection that only requires the mens rea of recklessness holding that those crimes with a mens rea of negligence or recklessness do not trigger the enhanced penalties mandated by the acca holding that a mens rea of unlawfully in the indictment was sufficient because the indictment referenced the applicable statute which required a reckless mens rea holding that neither recklessness nor gross negligence is a sufficient mens rea to establish that a conviction is for a crime of violence under section 16 holding that under california law section 28002 requires a reckless mens rea