Racial Justice Act (RJA)

Name: People v. Jimenez
Case #: H049356
Court: CA Court of Appeal
District 6 DCA
Opinion Date: 10/06/2026

The Court of Appeal holds that appellant failed to make a prima facie showing under the RJA that the prosecution more frequently sought special-circumstance murder convictions against people who share appellant’s race or ethnicity than against members of another group “who have engaged in similar conduct and are similarly situated.” (PC 745.) The Court concludes appellant’s statistical report does not satisfy PC 745(a)(3)’s second criterion: it conflated the general population with the population that has engaged in similar conduct and is similarly situated and conflated the occurrences of a more serious charge with the frequency of that charging decision.

The full…

View Full Summary
Name: In re Haney
Case #: A170412
Court: CA Court of Appeal
District 1 DCA
Division: 4
Opinion Date: 09/16/2026

The Court of Appeal published only the introductory portion of the opinion to give context to a separate concurrence regarding RJA claims based on peremptory challenges. While the defendant's habeas petition was pending in the Court of Appeal, the Supreme Court decided People v. Hazlett (2026) __ Cal.5th __ (S126387), which required the denial with prejudice of the portion of the defendant's RJA claim based on the racially discriminatory use of peremptory challenges. 

Justice Streeter wrote a concurring opinion, noting he was required to concur, but expressing agreement with Justice Evans' dissent in Hazlett, and adding historical context to give further…

View Full Summary
Name: People v. Williams
Case #: E087071
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 09/17/2026

Defendant failed to meet his prima facie burden establishing "a substantial likelihood" that a violation of the RJA occurred (PC 745(c) & (h)(2)). Defendant presented evidence that (1) a juror stated during voir dire that he “grew up with racism”; (2) a prosecutor made public statements described as hateful toward African Americans; and (3) Black defendants in San Bernadino County received sentencing enhancements more frequently than White defendants. The Court found the juror’s testimony that he had overcome the racial bias demonstrated this was not evidence of bias toward defendant; the prosecutor had only appeared twice to continue the matter,…

View Full Summary
Name: People v. Hazlett
Case #: S126387
Court: CA Supreme Court
Opinion Date: 08/27/2026

The California Supreme Court holds that excusing the sole remaining Black prospective juror with a peremptory challenge did not establish a prima facie case of discrimination under Batson/Wheeler, given a race-neutral reason in the juror’s equivocal views on the death penalty. The Court concludes that the Racial Justice Act (RJA) does not apply to the basis for peremptory challenges. It further holds there was no other prejudicial RJA violation and affirms the judgment. Justice Evans (joined by Liu) would find a prima facie Batson/Wheeler violation and believes the RJA applies to peremptory challenges; Justice Liu (joined by Evans) would find…

View Full Summary
Name: In re Pride
Case #: E085951
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 08/28/2026

Trial court erred in finding Pride had not met the RJA's minimal pleading requirement for appointment of counsel. To be entitled to counsel, petitioners must only allege facts that would establish a violation of the RJA. (PC 745.) Pride satisfied this minimal requirement when he alleged that his trial counsel had a discussion with the prosecutor regarding the importance of Pride's conviction to avoid future incidents of racial unrest.

Pride demonstrated a plausible justification for RJA discovery. Further, at the discovery stage, the alleged discussion was sufficient to demonstrate a plausible justification that a RJA violation has occurred.  The court of…

View Full Summary
Name: People v. Barrera
Case #: S103358
Court: CA Supreme Court
Opinion Date: 06/01/2026

The California Supreme Court affirms appellant’s convictions for two first degree murders of his children and the death sentence. Evidence was sufficient for torture murder and premeditated murder and for torture-murder special circumstances based on prolonged physical abuse, starvation, and failure to seek care. Any confrontation clause/Sanchez error was harmless. Any error for failing to give a second degree felony murder by torture instruction was harmless. Any Griffin error was harmless. The Court rejects multiple Racial Justice Act (RJA) claims, finding that any RJA violations were harmless. [Editor's Note: Justice Liu concurred in the judgment, including the majority's determination that any violations of…

View Full Summary
Name: People v. Chhuon and Pan
Case #: S105403
Court: CA Supreme Court
Opinion Date: 06/01/2026

Defendant Pan’s convictions and death sentence reversed where trial counsel conceded guilt on second degree murder despite Pan’s expressed desire to maintain complete innocence (McCoy error). The Court rejected defendant Chhuon’s RJA error claims based on prosecution references to his family being Cambodian immigrants and Buddhists, his targeting of Asian victims, and his being a “predator”, either finding no error or finding beyond a reasonable doubt that the violation did not contribute to the judgment.

Other holdings: 1) murder charges from separate counties properly joined; 2) no error in deeming witness unavailable (EC 1291) after reasonable prosecution efforts to locate; 3) numerous…

View Full Summary
Name: People v. Bankston
Case #: S044739
Court: CA Supreme Court
Opinion Date: 06/01/2026

Death judgment reversed because the DA’s comparison of defendant to a Bengal tiger constituted a prejudicial violation of the RJA. The RJA was not violated when an expert testified about tendencies among racially or ethnically organized gangs, nor when the DA commented on defendant’s dress and demeanor. However, as the AG conceded, the comparison of the defendant to a Bengal tiger, along with references to the defendant using “thug” as an epithet, were an implicit appeal to racial bias, violating the RJA. For judgments entered before the RJA’s effective date, whether by petition or direct appeal, the error requires reversal…

View Full Summary
Name: People v. Demolle
Case #: S159120
Court: CA Supreme Court
Opinion Date: 06/01/2026

Potential RJA violation during the penalty phase of a capital case – referring to defendant as a wolf – was harmless beyond a reasonable doubt. After defendant was found guilty of murdering and raping an 11-year-old, the prosecutor’s reference to defendant as a “predator” and a “wolf in sheep’s clothing” did not violate the RJA. Additionally, where the judgment was entered before the effective date of the RJA, the harmless beyond a reasonable doubt standard applies to RJA claims asserting racially discriminatory language. Assuming without deciding that more references to defendant as a “wolf” violated the RJA, any error was…

View Full Summary
Name: People v. Haddock
Case #: D084537, D084538
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 05/28/2026

The Court of Appeal upholds the admission of rap lyrics at trial, rejecting claims under EC 352 and People v. Aguirre (2025) 18 Cal.5th 629. The court further holds that the trial court applied the wrong legal standards in denying appellants' Racial Justice Act (RJA) motion and requests for discovery. The court finds that appellants made a prima facie showing that the jury may have heard a racially charged rap-song introduction containing violent imagery and racially discriminatory language, violating the RJA. It also confirms that statistical evidence alone may justify RJA discovery without additional case-specific proof of discrimination.

The full opinion is…

View Full Summary