Friday, July 10, 2026
Page 3
Court of Appeal:
Claim That Racism Accusation Provoked Killing Is Rejected
Opinion Says Defendant’s Assertion That Victim Yelling at Accused’s Companion Over Use of Racial Epithet Did Not Transform Shooting Into ‘Heat of Passion’ Crime
By a MetNews Staff Writer
Div. Four of this district’s Court of Appeal has rejected a convicted murderer’s assertion that a Los Angeles Superior Court judge prejudicially erred in not instructing the jury on voluntary manslaughter based on a heat-of-passion theory due to evidence that the victim aggressively yelled at the defendant’s companion for using a racial slur before the fatal shots were fired.
Presiding Justice Helen Zukin authored Wednesday’s unpublished opinion, joined in by Justices Audra Mori and Armen Tamzarian, saying:
“Defendant’s sole contention on appeal is that the trial court prejudicially erred by failing to instruct the jury on the lesser included offense of voluntary manslaughter based on heat of passion. He argues that [the victim’s] ‘suddenly “aggressive” behavior’ and his ‘unwarranted raised-voice accusation of racism’ provoked the killing. We disagree.”
Appealing his conviction was Ronald Maldonado, who was found guilty of second-degree murder in April 2024. During the trial before Los Angeles Superior Court Judge Laura L. Laesecke, prosecutors accused the defendant of fatally shooting the then-24-year-old Larry Jefferson outside of a Long Beach liquor store on March 29, 2022.
Fatal Shooting
Just before the fatal shooting, Jefferson entered the shop at 12:41 a.m. and asked the cashier to call the police because of some unidentified danger outside. Ronald Maldonado entered the store with his friends, Julian Maldonado and Myrna Palay, shortly after Jefferson and directed the victim to leave the store.
When Jefferson, who was Black, refused, Julian Maldonado allegedly referred to him by way of a racial slur and said that “nobody’s out there.” According to witnesses, Jefferson “got aggressive” and yelled at Julian Maldonado, saying that he was not allowed to “say that.”
Ronald Maldonado then punched Jefferson, chased him out of the store, and shot him twice, once while the two men were, according to witnesses, “squar[ing] off” to fight in the middle of the street and again after the victim fell to the ground. Jefferson later died as a result of a gunshot wound to the head.
On May 8, 2024, Laesecke sentenced him to 25 years to life in prison.
Mandatory Instruction
Acknowledging that a trial court must instruct on any lesser-included offenses for which the evidence offers substantial support even in the absence of a request to do so, Zukin pointed out that manslaughter is one such crime when a defendant has been charged with murder.
She noted that “one type of voluntary manslaughter” is a killing that occurs in a “heat of passion” such that a suspect’s reason was eclipsed by a provocation that is of the kind that would cause an ordinary person to act rashly.
Saying that “[v]oluntary manslaughter on a heat of passion theory has both subjective and objective components,” she turned to Ronald Maldonado’s contention that Jefferson’s accusation of racism provoked him to shoot and said:
“Jefferson’s behavior would not provoke an ordinary, reasonable person to act in that manner….Jefferson’s ‘aggressive’ behavior was only in response to Julian’s racial epithet directed at him. Moreover, Jefferson merely yelled a statement of disapproval for being called a [racial slur]. Contrary to defendant’s contention, Jefferson did not escalate the encounter to a quarrel. Rather, defendant did so by punching Jefferson and then chasing him out of the liquor store.”
The jurist added:
“In addition, there was no evidence that defendant was under the influence of a strong heat of passion based on Jefferson’s alleged provocation….Defendant did not testify at trial, and there was otherwise no evidence to show he exhibited anger, fury, or other intense emotion before shooting Jefferson.”
Saying “we conclude that there was insufficient evidence to support instructing the jury on voluntary manslaughter on a heat of passion theory,” she declared that his judgment of conviction “is affirmed.”
The case is People v. Maldonado, B339095.
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