Wipfel v. State

Summary

The court affirmed Wipfel’s convictions, holding that the trial court did not legally err by failing to give an unrequested involuntary-manslaughter instruction. The court clarified that the substantive rule barring error based solely on failure to give an unrequested lesser-offense instruction remains valid, while plain-error review governs the appellate review of unpreserved instructional claims. Because no written request was made, Wipfel could not establish the legal error required for plain-error relief.