People v. Bean CA2/5, B334652

Defendant David Bean, an Eight-Trey gang member, and Jenelle Williams, a Rollin' 60's gang associate, were charged in connection with four murders committed with the same firearm over two weeks in Summer 2016 in Los Angeles.
Bean was convicted in 2023 of murders of Shawn Pryor (felony murder), Tiffany Doxy (aiding and abetting), and Kenyada Thornton (second degree malice murder), plus related firearm and assault charges. He was acquitted of the Marcus Wilkerson murder.
The evidence included surveillance video, eyewitness testimony, forensic ballistics, DNA, and jail phone calls showing coordination and cover-up efforts.
Bean appealed his convictions, arguing insufficiency of the evidence for each murder charge, citing alleged lack of proof of key elements, especially intent and lack of justification/self-defense.
The court also addressed and struck an unauthorized (imposed-but-stayed) 10-year sentencing enhancement for Bean’s prior convictions, but affirmed the judgment in all other respects.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for Pryor felony murder	Substantial evidence shows attempted theft by pretense—Bean and Williams used counterfeit money and a ruse.	No robbery or attempted theft shown; only a failed drug buy and subsequent defense of Williams.	Conviction affirmed; evidence supports felony-murder theory.
Sufficiency of evidence for Doxy (witness) murder	Bean aided and abetted Williams in execution-style murder to silence a witness; circumstantial evidence supports shared intent.	No direct evidence of aiding and abetting; Bean was mere bystander, and presence/car ownership insufficient.	Conviction affirmed; reasonable inferences support aiding and abetting.
Sufficiency of evidence for Thornton murder	Ballistics and testimony show Bean shot first without justification; flight and cover-up evidence supports malice.	Bean acted in self-defense after being threatened and shot at by Thornton.	Conviction affirmed; jury could find no legal justification; self-defense properly rejected.
Imposed but stayed prior sentencing enhancement	No statutory authority for imposing-but-staying enhancement; should be stricken.		Enhancement stricken; sentence otherwise affirmed.

Jackson v. Virginia, 443 U.S. 307 (1979) (sets forth standard for appellate review of sufficiency of evidence in criminal convictions)
People v. Knoller, 41 Cal.4th 139 (Cal. 2007) (defines malice for murder)
People v. Abilez, 41 Cal.4th 472 (Cal. 2007) (articulates standard for reviewing facts in the light most favorable to the judgment)
People v. Maciel, 57 Cal.4th 482 (Cal. 2013) (appellate courts must accept jury's credibility determinations barring physical impossibility or inherent improbability)
People v. Farley, 46 Cal.4th 1053 (Cal. 2009) (explains felony murder rule)
People v. Penunuri, 5 Cal.5th 126 (Cal. 2018) (appellate review limited to substantial evidence not weighing evidence anew)