People v. Haddock (2026): RJA Evidence and Discovery

forensic toxicology working group members September 23, 2026 Law Updates, Racial Justice Act

People v. Haddock (2026) is an important California Racial Justice Act decision because it addresses two recurring procedural questions: what a court may do when deciding whether a defendant has made a prima facie showing under Penal Code section 745, and what is required to obtain discovery of evidence relevant to a potential RJA violation.

The Fourth District Court of Appeal, Division One, conditionally reversed and remanded after concluding that the trial court applied improper legal standards to the defendants’ renewed RJA motions and discovery requests. The opinion was filed May 4, 2026 and certified for publication on May 28, 2026.

What happened in People v. Haddock?

Donte Jerome Haddock and Anthony Constantin Frank were convicted in a gang-related murder prosecution. After earlier appellate proceedings and remand, they sought relief under California’s Racial Justice Act. Their claims included the prosecution’s presentation of a rap-song introduction containing racially charged language and violent imagery.

The defendants also requested RJA discovery. The trial court denied the renewed motions and discovery requests. On appeal, the Court of Appeal held that the trial court had used improper standards and directed further proceedings.

The prima facie stage is not a mini-trial

A central feature of Haddock is the distinction between a prima facie showing and ultimate proof. At the prima facie stage, the question is whether the factual allegations, if true, demonstrate a substantial likelihood of an RJA violation. The court should not convert that threshold inquiry into a full credibility determination or require the defendant to prove the merits before receiving the hearing contemplated by the statute.

That distinction matters in practice. Evidence relevant to racial bias may be incomplete, disputed, or embedded in a larger trial record. A threshold showing is designed to determine whether the claim should proceed, not to resolve every factual conflict against the moving party.

Racially charged material presented to the jury can matter under section 745

The RJA reaches more than explicitly racist statements personally authored by a prosecutor. Penal Code section 745 addresses racially discriminatory language and conduct that exhibits bias or animus. Haddock explains that a prosecutor may implicate the statute by presenting racially incendiary or racially coded material to a jury, even when the prosecutor did not create the underlying words.

The opinion is particularly significant where the prosecution uses music, images, gang evidence, nicknames, social-media content, or other expressive material carrying racial meaning. The analytical question is not simply who originally created the material. The court must consider how the material was used in the proceeding and whether its presentation fits the RJA’s statutory framework.

The RJA does not require a prejudice analysis at the prima facie stage

The Court of Appeal also rejected the use of a conventional prejudice analysis as a substitute for the RJA’s own threshold. California enacted section 745 to create a statutory remedy for racial bias in criminal proceedings. A court therefore should apply the standards the Legislature supplied rather than importing a different harmless-error or prejudice test into the prima facie inquiry.

This is an important distinction for practitioners because an RJA motion can fail if the briefing is forced into the wrong doctrinal framework. The threshold question is whether the allegations satisfy the statute’s prima facie standard, not whether the movant has already proved that the result of the trial would have been different.

Statistical evidence may support discovery

Haddock is also important on discovery. The Court of Appeal rejected a standard that effectively required additional case-specific proof before statistical evidence could justify RJA discovery. Statistical evidence can itself provide the factual foundation for a discovery request when it is relevant to a potential violation.

That does not mean every request must be granted without limitation. Penal Code section 745(d) still requires a motion identifying the type of records or information sought, and courts may address relevance, burden, privacy, availability, and appropriate protective measures. But the discovery standard should not be transformed into a requirement that defendants prove the underlying discriminatory practice before they can obtain the records needed to investigate it.

Why Haddock matters for California RJA litigation

The practical lesson is that RJA litigation has distinct stages with distinct burdens. A defendant seeking discovery need not prove the final claim. A defendant making a prima facie showing need not win credibility disputes that belong at a later evidentiary hearing. And material introduced by the prosecution may be scrutinized for racial meaning even when it originated with a third party.

For lawyers developing an RJA record, that means the motion should identify the precise language, image, evidence, argument, or practice alleged to be discriminatory; explain why it fits section 745; preserve the complete context in which it was presented; and separately articulate why requested discovery is relevant to a potential violation.

Evidence to preserve

When an RJA claim involves racially charged trial material, counsel should preserve more than the reporter’s transcript. Depending on the facts, useful material may include admitted exhibits, audio and video actually played for the jury, demonstratives, prosecution slide decks, motions in limine, limiting instructions, sidebars, exhibit logs, electronic courtroom playback records, and any version history showing what the jury did or did not hear.

Haddock itself illustrates why that matters: disputes about what was presented can become central to the threshold analysis. A complete evidentiary record reduces the risk that the claim turns on reconstruction years later.

Relationship to other 2026 RJA decisions

Haddock fits within a broader 2026 line of cases clarifying procedure under the Racial Justice Act. In re Pride addresses appointed counsel and the good-cause standard for discovery. In re Haney addresses discovery in preparation for an RJA habeas petition. People v. Williams addresses prima facie evidence, statistics, and comparator analysis. Together, these decisions make it increasingly important to identify the procedural stage before arguing the applicable evidentiary burden.

Practice points from Haddock

Separate the discovery standard, prima facie standard, evidentiary-hearing burden, and ultimate merits burden.
Do not allow credibility weighing to replace the prima facie inquiry.
Identify how racially charged third-party material was actually used by the prosecution.
Preserve the exact media, exhibit, or presentation shown to the jury.
Use statistical evidence to support a targeted discovery theory when appropriate.
Describe requested records with enough specificity to show their connection to a potential section 745 violation.

Bottom line

People v. Haddock reinforces that California’s Racial Justice Act must be analyzed under its own statutory standards. Courts should not demand ultimate proof at the discovery or prima facie stages, and prosecutors’ use of racially incendiary or coded material can fall within the Act even when the underlying words were created by someone else.

For current RJA authorities, procedural guides, and statutory developments, see the California Racial Justice Act Resources page.

Sources

This article discusses published legal authority for educational purposes and is not a substitute for advice regarding a particular case.

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