Keith (D) was charged with involuntary manslaughter after the car he was driving collided with another vehicle, killing the driver. D was indicted and argued that the indictment failed to allege two key elements of the offense charged and only alleged that he operated his auto without due caution and circumspection; and this alleged only negligence and not the criminal negligence required by the statute and the fact that D had knowledge of the circumstances that would alert a reasonable person to the perils of his conduct. That motion was denied. D appealed his conviction.