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defendantappealhearingtrialmotionprobationcredibility
defendantappealhearingtrialmotionprobationcredibility

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Finley v. Superior Court, 95 Cal.App.5th 12, 312 Cal.Rptr.3d 907, 23 Cal. Daily Op. Serv. 8800, 2023 Daily Journal D.A.R. 9104

Facts

Demond Finley, a Black man, was stopped by Officer Terrell Gunn in a high-crime area of San Francisco after a license plate check revealed discrepancies. Despite providing proof of ownership, Officer Gunn searched Finley's vehicle due to his federal probation status, discovering a loaded handgun. Finley subsequently filed a motion claiming racial bias under the Racial Justice Act, which the trial court denied, leading to his petition for writ of mandate.

Demond Finley, a Black man, was stopped by Officer Terrell Gunn in a high-crime area of San Francisco after a license plate check revealed discrepancies. Despite providing proof of ownership, Officer Gunn searched Finley's vehicle due to his federal probation status, discovering a loaded handgun.

Issue

Did the trial court err in denying Finley's motion for a prima facie violation of the Racial Justice Act by applying an incorrect standard of review?

Did the trial court err in denying Finley's motion for a prima facie violation of the Racial Justice Act by applying an incorrect standard of review?

Rule

The court must accept the truth of the defendant's allegations, including expert evidence and statistics, unless the allegations are conclusory, unsupported, or contradicted by the court's own records.

The court must accept the truth of the defendant's allegations, including expert evidence and statistics, unless the allegations are conclusory, unsupported, or contradicted by the court's own records.

Analysis

The Court of Appeal found that the trial court improperly weighed evidence and made credibility determinations instead of focusing on whether Finley's allegations, if true, established a substantial likelihood of a Racial Justice Act violation. The court emphasized that the trial court should have accepted Finley's proffered facts and expert opinions at the prima facie stage without considering conflicting evidence.

The Court of Appeal found that the trial court improperly weighed evidence and made credibility determinations instead of focusing on whether Finley's allegations, if true, established a substantial likelihood of a Racial Justice Act violation.

Conclusion

The Court of Appeal granted Finley's petition for writ of mandate, directing the trial court to vacate its previous order and hold a new hearing to determine if Finley established a prima facie violation of the Racial Justice Act.

The Court of Appeal granted Finley's petition for writ of mandate, directing the trial court to vacate its previous order and hold a new hearing to determine if Finley established a prima facie violation of the Racial Justice Act.

Who won?

Demond Finley prevailed in the case because the Court of Appeal found that the trial court applied the wrong legal standard in evaluating his motion under the Racial Justice Act.

Demond Finley prevailed in the case because the Court of Appeal found that the trial court applied the wrong legal standard in evaluating his motion under the Racial Justice Act.

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