With no explanation, chose the best option from "A", "B", "C" or "D". and have chosen to abandon the misdemeanor-manslaughter rule. See, e.g., State v. Pray, 378 A.2d 1322, 1323 (Me.1977) (acknowledging that criminal negligence had been required for misdemeanor-manslaughter rule, but choosing to abolish the entire doctrine in Maine); Commonwealth v. Catalina, 407 Mass. 779, 556 N.E.2d 973, 978 (1990) (noting the strong trend away from the misdemeanor-manslaughter rule and holding “that unlawful-act manslaughter should be abandoned in Massachusetts except for appropriate cases which are based on the principle that a battery that causes death is manslaughter”). Other jurisdictions require that the predicate misdemeanor for misdemeanor manslaughter be either inherently dangerous or malum in se. See, e.g., Comber v. United States, 584 A.2d 26, 50 (D.C.1990) (<HOLDING>); Schlossman v. State, 105 Md.App. 277, 659

A: holding that begay rejected that circuits earlier approach under which an offense presented a serious potential risk of physical injury to another if the offense conduct had the potential for serious physical injury to another
B: recognizing inherent power of courts of appeals
C: holding that under the misdemeanormanslaughter rule the category of misdemeanors dangerous in and of themselves encompasses misdemeanors which bear an inherent danger of physical injury
D: holding method of merchandising and nature of article causing injury more important than length of time dangerous article has been in area in which injury occurs
C.