Error and/or relief
(GARY NOTE: There were three nearly identical petitions filed on the same day out of the same Court of Appeal in different cases. Each summary, therefore, is identical, and the three cases are summarized here in this single summary.)
In this writ proceeding, the petitioner challenges the summary denial of his request for discovery under the California Racial Justice Act of 2020 (RJA). He made the request in conjunction with a petition for a writ of habeas corpus, but the trial court ruled RJA discovery is not permitted in that context unless the petitioner first makes a prima facie showing for habeas relief. Because he did not make such a showing, the court summarily denied his discovery request without addressing its merits. While his challenge to that ruling was pending in this court, the Legislature amended the RJA effective January 1, 2026. Designed to expand access to RJA discovery, AB 1071 allows defendants to seek such discovery when they file a petition for writ of habeas corpus, or in preparation of filing such a petition. Because AB 1071 does not condition access to RJA discovery on a prima facie showing for habeas relief, we grant his petition for a writ of mandate. We direct the trial court to vacate its order summarily denying his request for discovery and remand for the court to consider the merits of that request.
First Holding:
Under amendments effective January 1, 2026, the RJA allows defendants to seek discovery when they file a petition for writ of habeas corpus, or in preparation of filing such a petition. Because the amendment does not condition access to RJA discovery on a prima facie showing for habeas relief, the trial court must consider the merits of the discovery request.
Authority:
AB 1071
PEN 745
Second Holding:
The RJA was enacted in 2020 with a stated aim to eliminate racial bias from California’s criminal justice system and to ensure that race plays no role at all in seeking or obtaining convictions or in sentencing. To that end, the RJA prohibits the state from seeking or obtaining a criminal conviction, or seeking, obtaining, or imposing a sentence, on the basis of race, ethnicity, or national origin.
Authority:
People v. Wilson (2024) 16 Cal.5th 874, 944–945
Third Holding:
Under the RJA, an incarcerated defendant whose judgment is final may bring a claim for relief under the Act by filing a petition for writ of habeas corpus. The defendant may also file a motion requesting disclosure of all evidence relevant to a potential violation of the RJA in the possession or control of the state. Upon a showing of good cause, the court shall order the records to be released.
Authority:
PEN 745
