In People v. Wells (1996) 12 Cal.4th 979, 911 P.2d 1374, the court addressed the meaning of an inherently dangerous act. Defendant was convicted of gross vehicular manslaughter (Pen. Code, 192, subd. (c)(1)). The evidence established defendant had been speeding on a curving, hilly road when his out-of-control car struck another vehicle, injuring the driver and killing a passenger. ( People v. Wells, supra, 12 Cal.4th at pp. 982-983.) At trial, the court instructed the jury on various Vehicle Code violations, including speeding (see Veh. Code, 22349), and defined an "unlawful act" as one that is inherently dangerous to human life or safety. The trial court then said that each of the alleged Vehicle Code violations was inherently dangerous. The appellate court reversed because it found that speeding was not inherently dangerous and therefore could not constitute the "unlawful act" element of the offense. ( People v. Wells, supra, 12 Cal.4th at pp. 982-984.) Wells examined Penal Code section 192, subdivision (c)(1), which defines one of the three kinds of vehicular manslaughter described in section 192 as "driving a vehicle in the commission of an unlawful act, not amounting to felony, and with gross negligence; or driving a vehicle in the commission of a lawful act which might produce death, in an unlawful manner, and with gross negligence." The court was asked to decide "if the 'unlawful act' to which the statute refers must be an offense that is inherently dangerous to human life or safety, and if so, whether exceeding the maximum speed limit constitutes such an unlawful act." ( People v. Wells, supra, 12 Cal.4th at p. 981.) Wells reversed the appellate court, and resolved the issue of whether an unlawful act on which a charge of involuntary manslaughter is predicated must be inherently dangerous, that is, dangerous in the abstract, or dangerous under the circumstances of its commission. "The offense which constitutes the 'unlawful act' need not be an inherently dangerous misdemeanor or infraction. Rather, to be an 'unlawful act' within the meaning of section 192(c)(1), the offense must be dangerous under the circumstances of its commission. An unlawful act committed with gross negligence would necessarily be so." (People v. Wells, supra, 12 Cal.4th at p. 982.)