It was not immediately clear whether Burda had an attorney.
Day, 76, had been missing for nearly a year before police announced they had found his body in June, two months after discovering his remains in his southern Oregon home.
Day was reported missing in July 2018 by his husband, who suffers from memory loss, after he failed to visit him at the hospital for several weeks.
Later that month, officers conducted a search of the home after receiving reports of “bad smell” coming from the area.
Nearly a year later, in April, Phoenix police officers found Day’s body inside the home with the help of a cadaver dog. It was not immediately clear why the remains weren’t found in the home until April. Police haven’t said where the body was located in the house.
Day was one of the first cast members of “The Mickey Mouse Club,” the 1950s television variety show aimed at children.