In re Nale Estate, 290 Mich. App. 704

Respondent was convicted of voluntary manslaughter in the death of her husband in 2007 and sentenced to 34 to 180 months.
Petitioner Julia Cook, successor personal representative, petitioned probate court to forfeit and revoke respondent’s benefits under MCL 700.2803.
Probate court held that respondent forfeited all benefits because of felonious and intentional killing.
Respondent argued manslaughter is not an 'intentional killing' under MCL 700.2803 and thus she could receive estate benefits.
This Court reviews the legal interpretation of MCL 700.2803 de novo; factual posture is on the record.
Statutory text and common-law slayer rule are used to determine whether voluntary manslaughter falls within 'feloniously and intentionally' killing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does MCL 700.2803 apply to voluntary manslaughter?	Cook argues manslaughter is not 'intentional killing'.	Nale contends statute covers intentional killings, including manslaughter.	Yes; statute applies to voluntary manslaughter.
Is voluntary manslaughter an 'intentional killing' for purposes of the slayer rule?	Manslaughter lacks intent to kill.	Voluntary manslaughter is an intentional killing under common law.	Voluntary manslaughter is an intentional killing, triggering forfeiture.

Garwols v Bankers Trust Co, 251 Mich 420 (1930) (slayer rule extends to manslaughter)
People v Mendoza, 468 Mich 527 (2003) (defines voluntary manslaughter; intentional killing context)
People v Townes, 391 Mich 578 (1974) (voluntary manslaughter elements; provocation)
People v Pouncey, 437 Mich 382 (1991) (voluntary vs involuntary manslaughter elements)
People v Delaughter, 124 Mich App 356 (1983) (essential element of intent to kill or cause serious harm)
People v Hess, 214 Mich App 33 (1995) (comparison of murder and voluntary manslaughter regarding 'intentional')
Budwit v Herr, 339 Mich 265 (1954) (early articulation of slayer rule and common-law approach)