People v. Little CA3

Filed 5/21/25 P. v. Little CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published,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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA THIRD APPELLATE DISTRICT (Amador) ----

THE PEOPLE, C099148

Plaintiff and Respondent, (Super. Ct. No. 22CR31624)

v.

STEVEN WARD LITTLE,

Defendant and Appellant.

After a jury found defendant Steven Ward Little guilty of assaulting his wife (Doe) and making criminal threats to her, the trial court sentenced him to state prison for an aggregate term of 21 years 10 months. On appeal, Little contends the trial court prejudicially erred in failing to instruct the jury on the requirement of unanimity regarding the charge of making criminal threats. We conclude that any such error was harmless beyond a reasonable doubt. We also agree with the parties that the trial court

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made an arithmetical error in calculating one of Little’s subordinate terms. Accordingly, we will affirm Little’s conviction for making criminal threats and remand the matter for the trial court clerk to correct the abstract of judgment. BACKGROUND Doe met Little when she was 26 years old and he was 50. They married less than one month later. Little assaulted Doe multiple times after they married. The first time, Little “choked [Doe] out” until she lost consciousness. Little also repeatedly threatened Doe. On one occasion, when Doe said she wanted a divorce, he told her, “[Y]ou can’t leave, I’m going to kill you.” On another, he said he would “get a tool and sodom[ize]” her. He also told Doe he would kill her family if she involved them in the couple’s disputes. In July 2022, an information charged Little with three counts of assault by means likely to produce great bodily injury (Pen. Code, § 245, subd. (a)(4); counts I, II, & III),1 one count of injuring a spouse (§ 273.5, subd. (a); count IV), and one count of making criminal threats (§ 422, subd. (a); count V).2 Among other additional allegations in the information, the prosecutor alleged that in connection with counts I and II Little inflicted great bodily injury within the meaning of section 12022.7, subdivision (e). After the close of evidence at trial, the prosecutor reminded the jurors that they “heard evidence that there were multiple instances of” criminal threats by Little: