People v. Burnett CA4/3

CourtCalifornia Court of Appeal
DecidedNovember 20, 2025
DocketG064455
StatusUnpublished

This text of People v. Burnett CA4/3 (People v. Burnett CA4/3) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Burnett CA4/3, (Cal. Ct. App. 2025).

Opinion

Filed 11/20/25 P. v. Burnett CA4/3

NOT TO BE PUBLISHED IN OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

THE PEOPLE,

Plaintiff and Respondent, G064455

v. (Super. Ct. No. 23NF1740)

EFFRUM MALAND BURNETT, OPINION

Defendant and Appellant.

Appeal from a judgment of the Superior Court of Orange County, Sheila F. Hanson, Judge. Affirmed. Robert L.S. Angres, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney General, Charles C. Ragland, Assistant Attorney General, Eric V. Tran and Steve Oetting, Deputy Attorneys General, for Plaintiff and Respondent. * * * This appeal stems from Effrum Maland Burnett’s conviction for second degree murder following a jury trial. The trial court instructed the jury on first degree murder, second degree murder, and voluntary manslaughter. Burnett contends the trial court erred in not instructing the jury on the lesser included offense of involuntary manslaughter. We disagree. The evidence demonstrated that on the day of the incident, Burnett and Toye Jones, the victim, engaged in two fights outside of a sober living home. Jones stopped the first fight but then the two continued fighting down the street. During that second fight, Burnett took out a knife and stabbed Jones five times, including one fatal wound through the heart and another stab wound to the groin that would also have been fatal without immediate medical attention. There was no evidence in the record from which the jury could conclude that Burnett did not subjectively believe his stabbing of Jones would result in anything other than Jones’s death. The trial court, therefore, did not err by failing to instruct on involuntary manslaughter and we affirm the judgment. FACTS In July 2023, Burnett and a female companion drove to a sober living facility in Anaheim where Jones was living. A witness testified that the female told Burnett that Jones had recently drugged her, held her against her will, and sexually assaulted her. When Burnett arrived, a resident inside the house told Jones the female was making allegations about him; Jones then ran outside. Once outside, Jones yelled at the female and hit her. Burnett intervened and then Jones and Burnett started fighting. Jones

2 stopped the fight and said, “‘Not in front of my house. Go down the street.’” Jones went into the house briefly but then followed behind Burnett who was already walking down the street. A video introduced at trial shows “Burnett’s right hand remained in his pocket as he was walking.” The witness testified as the two walked, Jones charged Burnett and punched him while Burnett was not looking. Burnett then proceeded to hit Jones five or six times in an uppercut fashion; the motion appeared as if he was using a knife. After about 15 or 20 seconds, Jones backed away, said he was done, and started walking back to the sober living home. Burnett watched Jones walk away holding his left arm against his side with his right arm. Video surveillance from the area showed Burnett walking with a knife in his right hand. The witness said Burnett ran to the car; he climbed into the backseat and said, “‘He hit me good,’ and ‘Get out of here. Drive, drive, drive.’” By the time police arrived, Jones was nonresponsive and lying in a large pool of blood. He was pronounced dead a short while later. An autopsy was conducted, and it was determined Jones suffered five stab wounds. One was to his jaw which was not life threatening because the knife had hit his mandible bone. There was a stab wound to Jones’s left armpit which had the potential to be life threatening, but was not in this case because the knife did not reach into the chest cavity. The third stab wound was to the left chest area and went into Jones’s heart. This wound was life threatening. There was a fourth stab wound to Jones’s left abdomen which was not life threatening and another to his right groin area. The stab to the groin area could have caused Jones to bleed out if he did not receive immediate medical attention. The cause of death was sharp force injuries to Jones’s face, torso, and right groin.

3 In an information, Burnett was charged with one count of murder (Pen. Code, § 187, subd. (a); count 1) and an allegation that he personally used a deadly weapon in the commission of that murder (id., § 12022, subd. (b)(1)). It was further alleged that Burnett had two prior strike convictions (id., §§ 667, subds. (d) & (e)(2)(A), 1170.12, subds. (b) & (c)(2)(A)) and a prior serious felony (id., § 667, subd. (a)(1)). Burnett’s case proceeded to a jury trial in which the trial court instructed the jury, as relevant here, on the elements of first degree murder, second degree murder, and voluntary manslaughter. Following deliberation, the jury returned a guilty verdict on second degree murder and a true finding as to the personal use of a deadly weapon allegation. Burnett admitted the prior strike and prior serious felony convictions. The court sentenced Burnett to an indeterminate term of 45 years to life, plus a determinate term of one year to be served consecutively to the indeterminate term. DISCUSSION

Burnett’s sole contention on appeal is that the trial court erred in not instructing the jury on the lesser included offense of involuntary manslaughter. A trial court has a sua sponte duty to do so, but only if substantial evidence warrants the instruction. (People v. Simon (2016) 1 Cal.5th 98, 132 (Simon).) Here, as we explain, there was no such evidence and the trial court correctly did not instruct on the offense. “Murder is the unlawful killing of a human being, or a fetus, with malice aforethought.” (Pen. Code, § 187, subd. (a).) “[M]alice may be express or implied. [¶] [It] is express when there is manifested a deliberate intention to unlawfully take away the life of a fellow creature.” (Id., § 188, subd. (a)(1).) It is implied “when no considerable provocation appears, or when the

4 circumstances attending the killing show an abandoned and malignant heart.” (Id., subd. (a)(2).) “Manslaughter is the unlawful killing of a human being without malice.” (Pen. Code, § 192.) “Voluntary manslaughter is ‘the unlawful killing of a human being without malice’ ‘upon a sudden quarrel or heat of passion.’” (People v. Thomas (2012) 53 Cal.4th 771, 813 (Thomas).) Involuntary manslaughter is a killing committed without malice and without an “aware[ness] of the risk to life that [the defendant’s] actions created and [a] conscious[] disregard[of that] risk.” (People v. Odell (2023) 92 Cal.App.5th 307, 321.) Involuntary manslaughter is a lesser included offense of murder. (Thomas, supra, 53 Cal.4th at p. 813.) “A trial court has a sua sponte duty to instruct the jury on a lesser included uncharged offense if there is substantial evidence that would absolve the defendant from guilt of the greater, but not the lesser, offense. [Citation.] Substantial evidence is evidence from which a jury could conclude beyond a reasonable doubt that the lesser offense was committed. [Citations.] Speculative, minimal, or insubstantial evidence is insufficient to require an instruction on a lesser included offense.” (Simon, supra, 1 Cal.5th at p. 132.) We review de novo a trial court’s decision not to instruct on a lesser included offense. (Id. at p.

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Related

People v. Thomas
269 P.3d 1109 (California Supreme Court, 2012)
People v. Kraft
5 P.3d 68 (California Supreme Court, 2000)
People v. Beatrice Bros.
236 Cal. App. 4th 24 (California Court of Appeal, 2015)
People v. Simon
375 P.3d 1 (California Supreme Court, 2016)

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Bluebook (online)
People v. Burnett CA4/3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-burnett-ca43-calctapp-2025.