Does a defendant have any evidence supporting his claim that a prosecutor committed error by arguing that the default finding was second degree murder?

Defendant asserts the prosecutor committed error by arguing that "the failure of proof of criminal negligence foreclosed an involuntary manslaughter conviction, and that the default finding was second degree murder." Defendant does not include any citation to the record to support that assertion. When defendants do not provide adequate citations to the record, the court is not obligated to search the record and thus can deem challenges waived. (People v. Smith (2015) 61 Cal.4th 18, 48.)

Defendant nevertheless goes on to argue that the prosecutor's argument was a misstatement of the law because "a finding of criminal negligence was a necessary element of implied malice." Defendant does not support that assertion with any citation to relevant legal authority. However, he argues this misstatement of the law resulted in the prosecutor diminishing the People's burden of proof and "implying" it was defendant's "burden to prove involuntary manslaughter." We are not required to address an issue raised without citation to relevant authority. (People v. Hardy (1992) 2 Cal.4th 86, 150.)

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Defendant also maintains that trial counsel rendered ineffective assistance in "ratifying" the prosecutor's erroneous argument regarding involuntary manslaughter. He does not support that theory with any actual argument. We will not examine perfunctory claims or make arguments for parties. (People v. Oates (2004) 32 Cal.4th 1048, 1068, fn. 10.)