Santa Ana : Bolsa Murder Conviction Overturned on Appeal

The 4th District Court of Appeal Tuesday reversed the murder conviction of a man accused of killing a 16-year-old boy after an argument over firewood at Bolsa Chica State Beach four years ago.

Juan G. Guzman, now 24, of Los Angeles was convicted of second-degree murder in the stabbing death of Paul Martino of Huntington Beach in a parking lot near the beach.

Guzman said he had stabbed someone as a reflex action after members of his group and Martino’s group had gotten into a dispute that was broken up by police.

The Guzman group had at first offered some of its firewood to the Martino group. But later, when some of the Martino group took more of the Guzman group’s firewood, it led to an argument.

The appellate court found that Superior Court Judge James Cook did not give jurors a clear enough definition of “implied malice,” a condition of second-degree murder. Guzman’s attorney had argued for a verdict of involuntary manslaughter. The appellate court noted that one juror asked the judge for a definition of malice “in layman’s terms,” indicating the jury’s confusion.

Presiding Justice John K. Trotter described the instruction on implied malice read to the jury as “Byzantine” and added that “it is impossible to say that the instructional error was harmless beyond a reasonable doubt.”