People v. Superior Court (Small) CA4/2

CourtCalifornia Court of Appeal
DecidedFebruary 10, 2026
DocketE086768
StatusUnpublished

This text of People v. Superior Court (Small) CA4/2 (People v. Superior Court (Small) CA4/2) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Superior Court (Small) CA4/2, (Cal. Ct. App. 2026).

Opinion

Filed 2/10/26 P. v. Superior Court (Small) CA4/2

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION TWO

THE PEOPLE,

Petitioner, E086768

v. (Super.Ct.No. SWF021505)

THE SUPERIOR COURT OF OPINION RIVERSIDE COUNTY,

Respondent;

JAMES LEON SMALL,

Real Party in Interest.

ORIGINAL PROCEEDINGS; petition for writ of mandate. John M. Monterosso,

Judge. Petition denied.

Michael Hestrin, District Attorney, Matthew Murray and Kent M. Walters, Deputy

District Attorneys, for Petitioner.

No appearance for Respondent.

1 Steven L. Harmon, Public Defender and Joseph J. Martinez, Deputy Public

Defender, for Real Party in Interest.

The discovery provision of the California Racial Justice Act of 2020 (RJA)

(Stats.2020, ch. 317, § 1) requires a trial court to order “all evidence relevant to a

potential violation of subdivision (a) in the possession or control of the state” released to

a criminal defendant “[u]pon a showing of good cause.” (Pen. Code, § 745, subd. (d)

(section 745(d)); unlabeled statutory references are to this code.)

In 2023, the trial court recalled the sentence of James Leon Small under section

1172.75. While Small was awaiting resentencing, he moved for disclosure of

information from the Riverside County District Attorney, alleging a potential violation of

subdivision (a)(3) of section 745 (section 745(a)(3)), that is, racial disparity in seeking or

obtaining convictions or imposing sentences in Riverside County for the offenses of

which Small was convicted. The trial court granted the motion and ordered the district

attorney to disclose responsive information for the five-year period in which Small was

charged, convicted, and sentenced.

The district attorney subsequently moved for reconsideration. The trial court

denied the motion in part and granted it in part. The court rejected the district attorney’s

invitation to reconsider its finding that Small had established good cause for disclosure,

but the court limited the amount of information that the district attorney had to provide.

2 The district attorney filed a petition for writ of mandate, challenging the trial

court’s finding of good cause under section 745(d) and its failure to compel the public

defender’s office to search its own records before ordering disclosure from the district

attorney. We deny the petition.

BACKGROUND

I. The conviction

Small is African American.1 In June 2007, a felony complaint was filed against

him in Riverside County. In March 2010, a jury convicted him of numerous sexual

offenses committed against his former girlfriend’s daughter, including one count of rape

of a child under age 14 (§ 269, subd. (a)(1)), one count of forcible lewd and lascivious

conduct against a minor under age 14 (§ 288, subd. (b)(1)), and a total of eight counts of

lewd and lascivious conduct against a child under age 14 or 16 (id., subds. (a), (c)(1)).

(People v. Small (June 30, 2011, E050735) [nonpub. opn.].) Small admitted that he

served one prior prison term under former section 667.5, subdivision (b). (People v.

Small, E050735.) In April 2010, the trial court sentenced Small to an aggregate term of

39 years four months in state prison, which included a one-year term for the prior prison

term enhancement. We affirmed the judgment in an unpublished opinion. (People v.

Small, E050735.)

1 Small’s motion does not contain any information identifying his race, so we take judicial notice of the record from Small’s direct appeal on our own motion. (Evid. Code, §§ 452, subd. (d), 459, subd. (d).) We provided the parties the requisite notice under Evidence Code section 459, subdivision (d), in a tentative opinion, and they did not oppose judicial notice of those materials.

3 II. Initial resentencing proceedings

In 2023, the trial court recalled Small’s sentence under section 1172.75 and struck

the one-year prior prison term enhancement, thereby reducing his aggregate sentence to

38 years four months in state prison. The court scheduled a future hearing to conduct a

full resentencing.

III. RJA discovery motion

Small filed a motion for disclosure of information under the RJA. (§ 745(d).) He

was represented by an attorney from the public defender’s office. Small argued that the

requested records were relevant to prove a violation of section 745(a)(3). The motion

sought the following categories of information from the district attorney’s office for the

years 2003 through 2010: (1) lists of everyone arrested for violating section 269 or

section 288 and everyone charged with violating those provisions, along with each

person’s age, gender, race, ethnicity, and national origin; (2) any offers made by the

prosecution to any person charged with violating section 269 or section 288; (3) any

written material in the district attorney’s office reflecting the reasons for the charging

decision and the disposition for each offense; and (4) “[a]ny reason stated or provided by

any member of the Riverside County District Attorney’s Office or policy relied upon in

making the decision to charge James Small.” Small also sought copies of any associated

police reports and rap sheets.

4 The following exhibits were attached to the motion: (1) a printout from the

website www.indexmundi.com stating that the African Americans were between 6 and

7.5 percent of Riverside County’s population from 2000 to 2009; (2) a printout from the

United States Census Bureau’s website providing “Quick Facts” about Riverside County,

showing African Americans to be 7.6 percent of the population at some unspecified

time2; (3) two pages of a 2021 report from the Judicial Council of California (the Judicial

Council), stating that in 2020 African Americans were 5.5 percent of California’s

population but were 18.9 percent of California’s felony defendants; and (4) several copies

of reports printed from a website called the Racial Justice Act Tool, which is maintained

by an organization called the Paper Prisons Initiative. The exhibits were attached to the

motion without any accompanying declaration.

The Paper Prisons Initiative describes itself as “a multi-disciplinary research

initiative focused on documenting and narrowing the ‘second chance gap’ between

eligibility for relief from the criminal justice system and its delivery due to hurdles in

access to relevant information and data.” Its website “provides summary data

representing the raw numbers, rates per population, and disparity gaps by race of adults in

the California criminal justice system using data provided by the California Department

of Justice as well as by the Census Department.”

2 Some of the statistics in the “Quick Facts” are accompanied by dates, but there is no date accompanying the data concerning the racial composition of the county’s population. In his motion, Small asserted that the United States Census Bureau statistics were taken from July 1, 2023.

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People v. Superior Court (Small) CA4/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-superior-court-small-ca42-calctapp-2026.