with whom FABE, Justice, joins, concurring.
I agree with the result the court reaches, but write separately to discuss my concern about how our slayer statute, AS 18.12.8038, applies to negligent homicide.1
Many states have equivalent statutes, but most prevent inheritance only i#f the heir intentionally causes the decedent's death.2 Only about ten states by statute or common law forbid someone who unintentionally causes the death of another from inheriting the decedent's estate,3 and most of these states disinherit only for reckless conduct and not for negligent homicide.4 Other than Alaska, no more than four states and the District of Columbia appear to disinherit if the wrongful conduct that causes the death is merely negligent in some degree.5
*713Our statute is unusual because it potentially applies to a class of events that are predictably more likely to occur (because they involve negligence). It is also unusual because the wrongful conduct that puts family members at risk may be relatively mainstream, akin to what much of the populace commonly does. This is especially so if it involves common activities (such as driving motor vehicles) that often violate the standard of care specified by statute or regulation.6 As a result, our statute potentially applies both broadly and frequently. There is a potential for harsh results not necessarily contemplated by the drafters.
There is also a risk that the state's interests advanced by the statute are too marginal to justify interference with the testamentary expectations of the victim of negligence. But Blodgett has not challenged the statute's constitutionality. I therefore assume here that the state has sufficient interest in deterrence and public safety to bar inheritance even for negligent homicide. There is nonetheless a potential for injustice if the statute is applied harshly in a particular case.
Our statute since 1989 has contained an exception for "manifest injustice." 7 The legislature, concerned about the possible injustice of applying the slayer statute to unintentional homicides, in that year adopted an escape clause that permits a court to avoid forfeiture if it "makes special findings of fact and conclusions of law" that manifest injustice would result.8
But because the statute necessarily applies to negligent homicide, trial courts might mistakenly assume that cireumstances involving mainstream conduct well within the statute (such as negligent homicide arising out of operation of a vehicle) cannot provide a basis for finding manifest injustice. A court might likewise think cireumstances bearing on the conduct itself cannot be relevant to a manifest injustice inquiry. In my view, such a cramped interpretation of the manifest injustice standard could result in substantial unfairness in many cases. Indeed, the very frequency with which negligently operated vehicles cause death might lead some trial courts to think the cireumstances of how a vehicle was operated can never demonstrate manifest injustice. At the least, a court might apply a presumption against finding manifest injustice.
The statute does not explain what cireum-stances might justify a finding of manifest injustice. It would seem that a litigant trying to avoid disinheritance under the slayer statute should be permitted to present any arguably relevant evidence. This would include evidence relevant to the gravity of the negligent conduct or to the beneficiary's relationship with the decedent. Foreign jurisdictions whose slayer statutes also contain escape clauses permit consideration of a broad range of cireumstances. The English Forfeiture Act states: "The court shall not make an order under this section modifying the effect of the forfeiture rule in any case unless it is satisfied that, having regard to the conduct of the offender and of the deceased and to such other cireumstances as appear to the court to be material, the justice of the case requires the effect of the rule to be so modified in that case."9 One of the leading English cases considering what cireumstances might be relevant has explained:
The court is entitled to take into account a whole range of cireumstances relevant to the discretion, quite apart from the conduct of the offender and the deceased: the relationship between them; the degree of moral culpability for what has happened; the nature and gravity of the offense; the *714intentions of the deceased; the size of the estate and the value of the property in dispute; the financial position of the offender; and the moral claims and wishes of those who would be entitled to take the property on the application of the forfeiture rule.[10]
It would also seem that if a beneficiary requests findings on cireumstances that are arguably relevant to manifest injustice, the trial court should make findings as to each relevant cireumstance and explain which circumstances the court concludes are irrelevant. But Blodgett does not claim here that the trial court's findings were inadequate. Although the trial court addressed only one cireumstance-the financial effect of disinheritance on Blodgett-there was no request for findings as to any other cireumstance and there is no claim on appeal that the superior court's findings were deficient.
I therefore agree to affirm.
. Per AS 11.41.130 "(al person commits the crime of criminally negligent homicide if, with criminal negligence, the person causes the death of another person." Per AS 11.81.900(a)(4) a person acts with criminal negligence "when the person fails to perceive a substantial and unjustifiable risk ... of such a nature and degree that the failure to perceive it constitutes a gross deviation from the standard of care that a reasonable person would observe in the situation."
. See Op. at 706.
. Jeffrey G. Sherman, Mercy Killing and the Right to Inherit, 61 U. Cm. L.Rev. 803, 848 n. 213 (1993).
. See Coro.Rev.Star §§ 15-11-803 & 18-3-04 (extending slayer statute to killers who recklessly cause death of others); Der Cong Ann. tit 12 § 2322 & tit. 11 § 632 (extending slayer statute to killers who recklessly cause the death of another); In re Wells' Will, 76 Misc.2d 458, 350 N.Y.S.2d 114, 119 (N.Y.Sur.1973) (noting that "[tJhere is a tremendous difference between one who is criminally negligent but nevertheless guilty of unintentional manslaughter from one guilty of manslaughter in the second degree for recklessly causing the death of another"); 84 Orta. St Anmm. § 231 & 21 Oxta. St. Ann. § 711 (extending slayer statute to involuntary manslaughter); Or.RevSmt § 112.455 (extending slayer statute to those who kill with "felonious intent," which would appear to cover reckless, but not negligent, homicide); In re Klein's Estate, 474 Pa. 416, 378 A.2d 1182, 1186 (1977) (holding that involuntary manslaughter bars inheritance when the culpability is reckless, but not if negligent); McClure v. McClure, 184 W.Va. 649, 403 S.E.2d 197, 200 n. 6 (1991) (holding that despite statute declaring anyone who feloniously kills another could not inherit, nonetheless "'death resulting from negligence or gross negligence will not bar recovery under a slayer statute").
. The District of Columbia slayer statute covers homicide resulting from grossly negligent conduct. See Turner v. Travelers Ins. Co., 487 A.2d 614, 615 (D.C.1985) (explaining that the slayer statute covers "unintentional killing derived from reckless or grossly negligent conduct").
Louisiana's slayer statute covers all criminal homicide. In re Hamilton, 446 So.2d 463, 465 (La.App.1984) (holding that slayer statute "was intended to include situations such as that presented by this case, where a beneficiary does not intentionally and feloniously cause the death of the insured but is nonetheless held criminally responsible for that death").
North Carolina's common law slayer rule prohibits inheritance after any wrongful homicide. Quick v. United Benefit Life Ins. Co., 287 N.C. 47, 213 S.E.2d 563, 567 (1975); Matter of Estate of Cox, 97 N.C.App. 312, 388 S.E.2d 199, 201 (1990). The continued application of this common law rule has been criticized in light of a slayer statute barring only intentional killers from inheriting. N.C. Grn.Stmar § 314-3; see also generally Julie Waller Hampton, The Need for a New Slayer Statute in North Carolina, 24 CamPerLt L. Rev. 295 (2002).
Kentucky Revised Statute § 381.280 bars inheritance from those convicted of any felonious homicide. "Reckless homicide" is a felony. KRS § 507.050. Kentucky defines "reckless" as "a gross deviation from the standard of conduct that a reasonable person would observe." KRS § 501.020. Reckless homicide in Kentucky is therefore equivalent to criminal negligence in Alaska under AS 11.81.900(a)(4).
Kansas Statute § 59-513 states that "[nlo person convicted of feloniously killing, or procuring the killing of, another person shall inherit." Involuntary homicide under Kansas law extends to '"'killing of a human being" committed recklessly, during a misdemeanor, or "during the commission of a lawful act in an unlawful manner." KS ST § 59-513. This arguably could extend to grossly negligent conduct, especially as KS ST § 21-3201 explains that "[the terms 'gross negligence,' 'culpable negligence, 'wanton negligence' and 'wantonness' are included within the term 'recklessness' as used in this code." A federal district court has held that Kansas's slayer statute does not apply to negligent homicide, and there appear to be no state cases interpreting the scope of the statute or applying it to negligent homicide. Rosenberger v. Nw. Mut. Life Ins. Co., 176 F.Supp. 379, 382-83 (D.Kan.1959) (explaining that "the intent of the legislature in enacting the statute must have been to give effect *713to the common-law rule"). The Kansas slayer statute is essentially unchanged since Rosenber-ger.
. A driver who breaches a standard of care set by traffic statutes and regulations is negligent. See, eg., Ardinger v. Hummell, 982 P.2d 727, 734 (Alaska 1999) (explaining that one "who indisputably violates a statute must be found to be negligent"). If there is a gross deviation from the standard of care that a reasonable person would observe the conduct could rise to the level of criminal negligence. See Comeau v. State, 758 P.2d 108, 114 (Alaska App.1988) (noting that driving while impaired by alcohol could constitute criminal negligence).
. AS 13.12.803(k); see also Op. at 705-706.
. See Op. at 705-706 (discussing legislative history).
. Forfeiture Act, 1982, c. 2 § 1 (Eng.).
. Dunbar v. Plant, [1998] Ch. 412, 427-28 (appeal taken from Chancery Division) (U.K.) (holding that survivor of husband-wife suicide pact could inherit her husband's estate).