State v. Adams

In State v. Adams, 155 Ariz. 117, 745 P.2d 175 (App. 1987), this court held that attempted reckless manslaughter and attempted negligent homicide are not cognizable offenses. Id. at 120, 745 P.2d at 178. The Court reasoned that the word "planned" in the attempt statute, A.R.S. 13-1001(A) (2001), "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. 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.