Error and/or relief
The trial court erred in denying the defendant’s pre-sentence motion for discovery under the Racial Justice Act (RJA).
First Holding:
Good cause for RJA discovery requires only a plausible factual foundation, based on specific facts, that a violation of the Racial Justice Act could or might have occurred. Good cause for RJA discovery is a minimal plausible justification standard less onerous than the prima facie showing of an RJA violation under section 745(c) that should not be difficult to meet. The statistical and academic materials presented with the defendant’s motion satisfied the minimally stringent requirements for discovery, entitling him to further evidentiary development of his RJA claim.
Authority:
Young v. Superior Court (2022) 79 Cal.App.5th 138
Second Holding:
The trial court must exercise its discretion to decide the appropriate scope of disclosure by weighing the following: whether the material requested is adequately described; the material’s relative availability to the responding entity and the defendant; the request’s timeliness; the risk of causing unreasonable delay or imposing an undue burden on the responding entity; and the risk of violating third-party confidentiality, privacy rights, or protected governmental interests.
Authority:
Young v. Superior Court (2022) 79 Cal.App.5th 138, 168
City of Alhambra v. Superior Court (1988) 205 Cal.App.3d 1118, 1134