Attempted Reckless Manslaughter In Arizona

In State v. Adams, 155 Ariz. 117, 745 P.2d 175 (App. 1987), the Court held that attempted reckless manslaughter and attempted negligent homicide are not cognizable offenses in Arizona. The court reasoned that the word "planned" in the same subsection of our attempt statute "clearly anticipates an intentional act or step by a defendant which is 'planned,' that is, designed or intended to culminate or end in the commission" of the offense. Id. at 120, 745 P.2d at 178. The court also agreed with the reasoning of cases from other jurisdictions that there is "no such criminal offense as an attempt to achieve an unintended result." Id.