California Appellate and Supreme Court Decisions Referencing Penal Code 745 (Published in 2024)

People v. Hardin (2024)

Citation: People v. Hardin (2024) 15 Cal.5th 838 (Docket: S277487)

This case originated from Los Angeles County. The California Supreme Court addressed whether a state law that provides parole hearings for most young adult offenders (those under 26) but excludes those sentenced to life without parole (LWOP) violates the Fourteenth Amendment’s equal protection guarantee. The defendant was sentenced to LWOP for a murder he committed at age 25.

The Supreme Court reversed the Court of Appeal, holding that the legislature acted rationally. The court reasoned that the legislature could balance the recognized capacity for growth in young adults against the extreme seriousness of their crimes. The California Racial Justice Act (Penal Code § 745) was referenced in the court’s opinion in the context of arguments made by amici curiae (friends of the court) regarding the broader landscape of sentencing reforms.

People v. Hodge (2024)

Citation: People v. Hodge (2024) (Docket: B337339)

The defendant, whose 2012 conviction from Los Angeles County was final, filed a motion in the superior court seeking relief under the California Racial Justice Act (Penal Code § 745). The trial court denied the motion. The defendant appealed.

The California Court of Appeal, Second Appellate District, dismissed the appeal, holding that the trial court’s order was non-appealable. The court clarified a critical procedural point: for defendants whose convictions are final, the exclusive remedy to raise a Racial Justice Act claim is a petition for a writ of habeas corpus, not a motion filed in the trial court.

People v. SanMiguel (2024)

Citation: People v. SanMiguel (2024) (Docket: B328160)

The defendant, Joel SanMiguel, was convicted by a jury in Ventura County of willful, deliberate, and premeditated attempted murder and assault with a deadly weapon. The jury also found true allegations that he personally inflicted great bodily injury.

The California Court of Appeal, Second Appellate District, Division Six, affirmed the judgment. In the published portion of its opinion, the court referenced the California Racial Justice Act (Penal Code § 745) while discussing the constitutionality of the Act’s automatic reversal provision, citing a dissenting opinion from a previous case.

Mosby v. Superior Court (2024)

Citation: Mosby v. Superior Court (2024) (Docket: E080924M)

The petitioner, Michael Earl Mosby III, was charged in Riverside County with a drive-by shooting, and the District Attorney sought the death penalty. Mosby filed a motion under the California Racial Justice Act (CRJA), claiming the decision to seek the death penalty was based on race, in violation of Penal Code § 745.

The trial court denied the motion, ruling that Mosby had failed to make a prima facie showing of racial discrimination. The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the denial and granted the petition. The appellate court found that Mosby had indeed produced sufficient evidence to establish a prima facie case of a CRJA violation and was therefore entitled to an evidentiary hearing in the superior court.

People v. Lashon (2024)

Citation: People v. Lashon (2024) 98 Cal.App.5th 804

This case is a key appellate decision interpreting the procedural aspects of the California Racial Justice Act (Penal Code § 745). The decision is frequently cited for its analysis of how RJA claims must be preserved in the trial court. It specifically addresses the requirement that a defendant must make an objection or motion in the trial court to be able to raise the claim on direct appeal.

People v. Stubblefield (2024)

Citation: People v. Stubblefield (2024) (Docket: H048598)

In this case from the Sixth Appellate District, the defendant contended that the prosecutor’s statements during closing arguments violated the California Racial Justice Act (RJA, Penal Code § 745). The closing arguments took place in July 2020, shortly after the murder of George Floyd. The defendant argued the prosecution improperly appealed to racial bias by identifying the defendant’s race and tapping into a backlash against the protests. The Court of Appeal analyzed the RJA claim in its published opinion.