JONATHAN EUGENE BOWERS v. STATE OF MARYLAND
Court of Special Appeals, Wright, Filed March 30, 2016,
Involuntary Manslaughter – Rule of Lenity – The maximum penalty for involuntary manslaughter is ten years. This is not ambiguous despite there being a second, optional maximum penalty

The opinion provides a history of manslaughter and its lack of distinction at common law (as between voluntary and involuntary).

There is also a discussion of obiter dictum that is somewhat romantic in nature, as that concept tends to be a bit more “fluid” depending on the opinion of the court authoring the opinion.