People v. Laster CA4/1

California Court of Appeal·Decided September 9, 2026·No. D085438·Unpublished

Opinion

Filed 9/9/26 P. v. Laster CA4/1

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

THE PEOPLE, D085438

Plaintiff and Respondent, (San Diego Super. Ct.

v. No. SCE414351)

RICKEY TYRONE LASTER,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of San Diego County, Selena D. Epley, Judge. Affirmed.

Sheila O’Connor, under appointment by the Court of Appeal, for Defendant and Appellant.

Rob Bonta, Attorney General, Charles C. Ragland, Chief Assistant Attorney General, Arlene Sevidal, Assistant Attorney General, Collette C. Cavalier and Nora S. Weyl, Deputy Attorneys General, for Plaintiff and Respondent.

Rickey Tyrone Laster was convicted by a jury of premeditated murder following a shootout at a gas station. The victim started a fistfight that ended when Laster was knocked to the ground. A few seconds later, the victim shot at Laster, who had retreated to his car where he had stashed his own gun. After an initial exchange of gunfire caused the victim to stumble backwards and fall down, Laster shot him multiple times at close range.

Laster, who does not dispute that he killed the victim, challenges his conviction on three grounds. First, he claims there was not enough time to premeditate the killing, nor was there sufficient evidence that he shot the victim in anything other than a spontaneous response. But premeditation can occur in mere seconds, and several aspects of the killing indicate that Laster exhibited this state of mind. Second, he asserts that the trial court erroneously admitted evidence of his affiliation with a motorcycle club at the time of the killing; however, this ruling was carefully circumscribed and not so irrational that it constitutes an abuse of discretion. Finally, Laster’s third allegation of error—that the prosecutor committed misconduct in misrepresenting the law during his closing argument—has been forfeited. Finding no reversible error, we affirm the judgment.

FACTUAL AND PROCEDURAL BACKGROUND1 A jury convicted Laster of one count of first degree murder (Pen. Code, § 187, subd. (a)) and found true that he personally discharged a firearm to proximately cause Joseph Curtis’s death (id., § 12022.53, subd. (d)) during

1 In accordance with the standard of review that applies to a claim of insufficient evidence, we recite the facts of the offense in the light most favorable to the judgment. (People v. Morales (2020) 10 Cal.5th 76, 88 (Morales).)

a shootout at a San Diego area gas station in August 2022. He was sentenced

to a total term of 50 years to life plus two years.2 The killing occurred around 9:40 a.m. at a gas station. A few minutes earlier, Laster arrived at the gas station with Iliana F., a woman he was on a first date with. Laster was driving Iliana’s Mitsubishi SUV. Iliana had arranged to meet Curtis at the gas station so she could return his debit card that she had borrowed.

Shortly after Laster and Iliana arrived, the two men got into an argument that, as captured by a gas station security video, escalated when Curtis punched Laster twice in the face. The scuffle continued off camera and ended with Laster being knocked to the ground. Laster made his way back to the Mitsubishi where, unbeknownst to Iliana, he had stashed a handgun loaded with ten rounds. The video shows Curtis walking toward Laster as he sat in the SUV, pulling his gun, and shooting a round in the defendant’s direction.

Laster also fired at Curtis, which caused the victim to stumble

backwards out of the camera’s field of view.3 Approximately two seconds later, Laster disappeared off camera with his gun pointed in Curtis’s direction. Eleven seconds after he disappeared from the camera’s view— and less than a minute after he was punched—Laster was captured by the security camera walking back to the SUV and driving away. The physical

2 Laster was also convicted of one count of witness intimidation (Pen. Code, § 136.1, subd. (b)(1)), which is not at issue in this appeal. 3 The camera was pointed toward a bank of gas pumps. Curtis’s car was in front of gas pumps; the Mitsubishi was behind them. Because the view into the Mitsubishi was obscured, the camera footage does not reveal who fired first.

evidence established that Curtis fired only one round before his gun jammed, and that Laster fired all ten of his rounds in a downward direction toward the victim.

Several bystanders heard or saw at least some of the gunfight. Five witnesses said that Laster fired his rounds in two distinct bursts. Three witnesses recalled Laster shooting Curtis between four and seven times while approaching him after he stumbled. Two of these three witnesses stated that Curtis was shot multiple times from just a few feet away and that he did not appear to be holding a gun at that time. And one of these two witnesses told the jury that Curtis reached his arm up toward Laster before he was shot.

Curtis suffered nonfatal gunshot wounds to left knee and big toe and a fatal wound to his chest. The angle of the fatal shot was consistent with both (1) the position of Curtis’s torso when he fired at Laster as captured in the security video and (2) by being shot from above while sitting or kneeling on the ground. A forensic pathologist testified that the kill shot would have incapacitated Curtis within seconds, rendering him unable to walk or to reach up with his arm.

DISCUSSION

A. Sufficiency of the Evidence

1. Additional Background

Laster’s first date with Iliana came after he had tried for a month to meet her in person. In the early morning hours before the killing, the two spent time at the clubhouse of the 4 Horsemen motorcycle club, where Laster was a prospective member. Despite having only “low-level” responsibilities for the club, he told Iliana he would soon be its president. He frequently shared on social media images of himself in his black leather motorcycle vest

that had the club patch sewn on its back (his “cut”). He also sent Iliana one of these pictures before they met in person. The pair left the clubhouse around 7:00 a.m. because they had to drop Iliana’s daughter off at school and then return the debit card to Curtis.

For his part in the shootout, Laster claimed he acted in self-defense.

After being knocked down, Laster said he heard Curtis, whom he had never met, tell Iliana, “ ‘He looked at me crazy. I’ll fucking kill this guy. I’ll kill this [motherfucker].’ ” Laster told the jury that he wanted to drive away in the Mitsubishi, but Curtis was walking toward him with his gun drawn and was repeating his threats. According to Laster, Curtis fired first and he responded by shooting all his rounds blindly from behind the open driverside door of the SUV. He then ran over to where Curtis had fallen, saw the gun next to him, and drove off.

2. There was sufficient evidence of premeditation.

Laster does not dispute that he killed Curtis, but challenges the sufficiency of the evidence to establish premeditation. He claims there was not enough time for him to plan the killing, and that the eyewitnesses’ testimony was not reliable because portions of it contradicted facts otherwise conclusively established. Accordingly, he contends that the killing was necessarily a “rash, hasty response to being punched and chased with a gun” that lacks the characteristics of premeditation and deliberation. For these reasons, he requests that we either vacate his conviction or reduce it to voluntary manslaughter.

“ ‘When considering a challenge to the sufficiency of the evidence to support a conviction, we review the entire record in the light most favorable to the judgment to determine whether it contains substantial evidence—

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