Aaron David Rico v. Eric Mejia, Warden, et al.

CourtDistrict Court, S.D. California
DecidedMarch 20, 2026
Docket3:22-cv-00701
StatusUnknown

This text of Aaron David Rico v. Eric Mejia, Warden, et al. (Aaron David Rico v. Eric Mejia, Warden, et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aaron David Rico v. Eric Mejia, Warden, et al., (S.D. Cal. 2026).

Opinion

1 NOT FOR PUBLICATION 2

3 UNITED STATES DISTRICT COURT 4 SOUTHERN DISTRICT OF CALIFORNIA 5 Aaron David RICO, Case No.: 22-cv-0701-AGS-LR 6 Petitioner, ORDER ACCEPTING REPORT AND RECOMMENDATION (ECF 17) AND 7 v. DENYING HABEAS PETITION 8 Eric MEJIA, Warden, et al., (ECF 1) 9 Respondents. 10 11 In this petition for a writ of habeas corpus, a state prisoner seeks relief from his 12 various state convictions. 13 BACKGROUND 14 After a state-court trial, petitioner Aaron Rico was convicted of 25 crimes stemming 15 from multiple robberies and burglaries, and two crimes relating to a sexual assault that took 16 place during one of those robberies. People v. Rico, No. D074546, 2020 WL 6790154, 17 at *1 (Cal. Ct. App. Nov. 19, 2020). The specific counts were “conspiracy to commit first 18 degree burglary,” “conspiracy to commit first degree burglary and robbery,” “first degree 19 robbery in concert,” “first degree burglary,” “forcible sexual penetration,” and “assault 20 with intent to commit forcible sexual penetration during a first degree burglary.” Id. The 21 California Court of Appeal affirmed those convictions, id. at *6, *11, and the state Supreme 22 Court declined further review (ECF 11-56, at 2). Rico now requests federal habeas relief. 23 The state appellate court’s recitation of the facts—which is “presumed to be correct” 24 absent “clear and convincing evidence” to the contrary, see 28 U.S.C. § 2254(e)(1)— 25 “briefly summarize[s] the nature of [Rico’s] crimes”: “In early 2016, a series of home 26 burglaries and robberies occurred on six days in San Diego County.” Rico, 2020 WL 27 6790154, at *2. “The victims stated that the suspects were of different races, something the 28 police considered unique.” Id. The suspects “typically used zip ties, shoelaces, and scarves 1 to tie up the residents” before taking “jewelry, money, personal electronics and gaming 2 systems.” Id. 3 “Crime scene evidence ultimately led” to Rico’s arrest and the arrest of six 4 “cohorts”: Stephen Gomez, Robin Shawver, Aaron Rico V (“Rico V”), Victor Harvey, 5 Jordan Wilson, and Thomas Smith. Id. Everyone “pleaded guilty to various charges,” 6 except for Rico and Smith who were “tried before a single jury.” Id. “During closing 7 arguments, Rico’s counsel essentially conceded his client’s guilt for aiding and abetting 8 the crimes, claiming that Rico acted as a lookout for all of the charged offenses.” Id. 9 “Counsel argued however, that Rico did not aid and abet the sexual assault because the 10 assault was not foreseeable.” Id. “The jury rejected these arguments” and convicted Rico 11 of “all charges, including the incident involving the sexual assault.” Id. 12 In this habeas petition, Rico advances two arguments: (1) “The State failed to 13 disclose” exculpatory evidence, violating Rico’s rights, and (2) the evidence was 14 “insufficient” to sustain his convictions on two robbery counts. (ECF 1-2, at 5, 23.) The 15 magistrate judge recommended rejecting both claims. (See ECF 17.) Rico objected (see 16 ECF 21), so this Court considers the matter “de novo,” see 28 U.S.C. § 636(b)(1). 17 DISCUSSION 18 “An application for a writ of habeas corpus . . . shall not be granted . . . unless the 19 adjudication of the claim resulted in a decision that was contrary to, or involved an 20 unreasonable application of, clearly established Federal law.” 28 U.S.C. § 2254(d). “The 21 ‘contrary to’ and ‘unreasonable application’ clauses of § 2254(d)(1) have independent 22 meaning.” Cook v. Kernan, 948 F.3d 952, 965 (9th Cir. 2020). “A state court’s decision is 23 ‘contrary to’ clearly established federal law if it applies a rule that contradicts the governing 24 law set forth in Supreme Court cases,” while a decision is “an ‘unreasonable application’ 25 of clearly established federal law if it correctly identifies the governing legal rule but 26 applies it unreasonably to the facts of a particular prisoner’s case.” Id. (cleaned up). In this 27 case, the Court examines the California Court of Appeal’s opinion, as it is “the state’s last 28 reasoned decision.” See Avila v. Galaza, 297 F.3d 911, 918 (9th Cir. 2002). 1 A. Brady Violation 2 Rico argued on appeal that his sexual assault-related convictions should be reversed 3 based on a violation of Brady v. Maryland, 373 U.S. 83 (1963), which imposes a duty on 4 the government to disclose “evidence favorable to an accused . . . where the evidence is 5 material either to guilt or to punishment, irrespective of the good faith or bad faith of the 6 prosecution.” Brady, 373 U.S. at 87; see Rico, 2020 WL 6790154, at *2–*6. The Court of 7 Appeal rejected this claim, Rico, 2020 WL 6790154, at *6, and Rico now says that this 8 ruling was both contrary to, and an unreasonable application of, clearly established law. 9 1. Contrary to Clearly Established Federal Law 10 “To establish a Brady violation, a defendant must show that: (1) the evidence at issue 11 is favorable to the accused, either because it is exculpatory or because it is impeaching; 12 (2) the evidence was suppressed by the government, regardless of whether the suppression 13 was willful or inadvertent; and (3) the evidence is material to the guilt or innocence of the 14 defendant.” United States v. Sedaghaty, 728 F.3d 885, 899 (9th Cir. 2013). The California 15 Court of Appeal found, and no one disputes, that the first two elements are satisfied. See 16 Rico, 2020 WL 6790154, at *4 (“[T]he prosecutor conceded that the first and second 17 elements of a Brady violation occurred . . . .”); (see also ECF 10-1; ECF 24). So only the 18 materiality prong is at issue. 19 Rico argues briefly that, when it comes to materiality, the Court of Appeal applied a 20 “sufficiency of the evidence” test that runs counter to Supreme Court precedent. (ECF 1-2, 21 at 18; ECF 21, at 2 (“[B]oth federal and state courts have specifically held that the test for 22 materiality under Brady ‘is not a sufficiency of the evidence test.’” (quoting Kyles v. 23 Whitley, 514 U.S. 419, 434 (1995)).) Rico correctly recites the law, but incorrectly 24 interprets the appellate court’s actions. It did not apply the wrong standard. 25 According to the Supreme Court, “evidence is material [for Brady purposes] if there 26 is a reasonable probability that, had the evidence been disclosed to the defense, the result 27 of the proceeding would have been different.” Strickler v. Greene, 527 U.S. 263, 280 28 (1999) (cleaned up). And a “‘reasonable probability’ of a different result is one in which 1 the suppressed evidence undermines confidence in the outcome of the trial.” Turner v. 2 United States, 582 U.S. 313, 324 (2017) (cleaned up). This is the exact language employed 3 by the California Court of Appeal. See Rico, 2020 WL 6790154, at *4 (holding that Rico 4 must show that “the nondisclosure was so serious that there is a reasonable probability that 5 the suppressed evidence would have produced a different verdict” (quoting People v. 6 Salazar, 112 P.3d 14, 21 (Cal. 2005)); id. (defining a “reasonable probability” as a 7 “probability sufficient to undermine confidence in the outcome” (cleaned up) (quoting 8 Salazar, 112 P.3d at 25)).

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Bluebook (online)
Aaron David Rico v. Eric Mejia, Warden, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/aaron-david-rico-v-eric-mejia-warden-et-al-casd-2026.