People v. Hill CA2/1, B342345

Kalen Ahmad Hill, a member of the West Boulevard Crips, was convicted of multiple offenses, including the first-degree murder of Harrison Kristol (a rival gang member), second-degree murder of Laroyice McFarland (a bystander), and several related assault and fleeing charges.
The incident began after an argument in a supermarket parking lot, escalated when Hill fired multiple gunshots at Kristol's vehicle while driving at high speed, killing Kristol.
Kristol's vehicle, out of control from the shooting, struck and killed bystander McFarland.
Hill then led police on a dangerous high-speed chase, injuring a bicyclist before escaping; he was later arrested and made incriminating statements in jail.
At trial, Hill attempted an alibi defense, but the timeline offered by his witness was disproved.
On appeal, Hill challenged only the jury instructions for McFarland's death, arguing the trial judge should have instructed on involuntary manslaughter as a lesser included offense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court should have instructed on	No, evidence supports	Yes, substantial evidence of lesser offense requiring	No duty to instruct; court
involuntary manslaughter for McFarland's death (Count 4)	only murder convictions	involuntary manslaughter instruction on Count 4	properly omitted instruction

People v. Manriquez, 37 Cal.4th 547 (Cal. 2005) (sets standard for when trial courts must instruct on lesser included offenses)
People v. Cruz, 44 Cal.4th 636 (Cal. 2008) (defines 'substantial evidence' for lesser included offense instructions)
People v. Chun, 45 Cal.4th 1172 (Cal. 2009) (explains implied malice in murder cases)
People v. Taylor, 32 Cal.4th 863 (Cal. 2004) (clarifies implied malice applies even if defendant unaware of specific victim)