Reported / Citable
Background
Demondre Williams was convicted of first degree murder and firearm possession after admitting that he shot a man in a San Bernardino apartment-complex parking lot. Years later, during resentencing proceedings prompted by the elimination of a prior-prison-term enhancement, Williams sought relief under the California Racial Justice Act (CRJA). The CRJA permits relief when race, ethnicity, or national origin improperly affected a criminal prosecution or sentence.
Williams argued that racial bias infected his case and that Black defendants in San Bernardino County received sentence enhancements at a higher rate than white defendants. The superior court denied the motion without an evidentiary hearing, concluding that he had not made the required prima facie showing—enough specific facts that, if true, would support a statutory violation. Appointed appellate counsel filed a no-issue brief, and Williams submitted his own arguments.
The Court’s Holding
The Fourth District affirmed. A defendant seeking a CRJA hearing must allege facts showing more than a mere possibility of discriminatory treatment. Williams relied principally on a single countywide statistic stating that Black defendants received enhancements in 64 percent of prison admissions, compared with 42 percent for white defendants. The court could not locate that figure in his exhibits and, even assuming it was accurate, found it too general to connect the disparity to Williams’s prosecution.
The statistic grouped together materially different enhancements, including firearm, gang, prior-record, and Three Strikes enhancements. Some categories had already been removed from Williams’s sentence and others never applied. He also offered no examples of similarly situated nonminority defendants who engaged in comparable conduct but received lesser charges or punishment. Unlike cases supported by controlled statistical studies and comparable prosecutions, his submission did not account for relevant case-specific variables. The trial court therefore was not required to order a hearing.
Key Takeaways
- A CRJA movant must present specific facts supporting a reasonable inference of a statutory violation; a generalized disparity does not automatically earn an evidentiary hearing.
- Statistical evidence is stronger when it controls for relevant variables and addresses the particular charging decision, enhancement, or sentence challenged.
- Evidence about comparable defendants should show that they were similarly situated and engaged in similar conduct, not merely that outcomes differed across broad racial groups.
- Practitioners should tie every cited dataset to the enhancements and procedural posture actually remaining in the client’s case.
Why It Matters
The opinion gives criminal practitioners a practical pleading guide for CRJA motions. Countywide statistics can be important, but counsel must explain what the numbers measure, isolate the challenged decision, and connect the comparison group to the defendant’s circumstances. Raw percentages spanning unrelated enhancements risk being treated as too broad to justify discovery or a hearing.
For prosecutors and trial courts, the decision confirms that the prima facie threshold has substance while leaving room for well-designed studies and concrete comparator evidence. The case does not reject statistical proof; it explains why the proof offered here lacked the specificity shown in successful CRJA cases.