A legal distinction between intentional and unintentional homicide was introduced in Athenian law in 409 BC, when the legal code of Draco indicated that intentional homicide ("hekousios phonos" or "phonos ek pronoias") was punishable by death. The language is ambiguous as to unintentional homicide ("akousios phonos"), but it may have been punishable by exile. However, academic David D Phillips says that these categories "do not correspond to the common-law categories of murder and manslaughter either in their original significance or in their present definitions", because under Athenian law intentional homicide would include both murder and voluntary manslaughter.