LOS ANGELES — A California Court of Appeal has granted relief to a petitioner after ruling that a trial judge applied “the wrong legal standard” in denying his request for appointed counsel under the California Racial Justice Act.
In its opinion in In re Tommie Lawson Lynex, the court addressed a habeas petition arising from Los Angeles County. Although filed as a petition for writ of habeas corpus, the court stated that the petition was “construed as a petition for writ of mandate” and ultimately granted the petition.
The Court of Appeal explained in its opinion that Tommie Lawson Lynex was convicted in 2000 of first-degree murder and received “50 years to life in prison.”
In 2020, the RJA was enacted, “which authorizes prisoners to seek habeas relief on the ground the state sought or obtained their convictions or sentences based on race, ethnicity, or national origin.”
In 2025, Lynex, under the RJA, “filed a petition for writ of habeas corpus.” Within his petition was a chart showing “the District Attorney charged far more Black defendants with murder and the firearm allegation than White defendants during that three-year period.”
The trial court denied Lynex’s petition, finding that “Lynex’s Racial Justice Act claims were successive and thus procedurally barred.” The court also found that Lynex failed to show any tangible proof that the police’s destruction of property, as well as the police’s identification procedures, were affected by racial bias.
The court also insisted that Lynex must “make a prima facie showing that he is entitled to relief,” and, since he had failed to do so, was “not entitled to appointment of counsel.”
The appellate court rejected the trial court’s reasoning.
The Court of Appeal wrote, “The District Attorney acknowledges the trial court ‘applied the wrong legal standard.’” The opinion explained that the statute requires appointment of counsel if “the petition pleads a plausible allegation of a violation.” The Legislature further clarified that the standard “does not require a prima facie showing” and “should be construed as a minimal pleading requirement,” according to the opinion.
The Court of Appeal explained that appointment of counsel is separate from the higher showing required later in proceedings, noting courts must assess “the adequacy of the factual allegations in the habeas corpus petition, not an assessment of the overall sufficiency of the prima facie showing.”
“The policy of ‘liberality in permitting amendment is the rule,’” the court wrote, adding that amendment procedures are “exceptionally important in the context of Racial Justice Act claims.”
On procedural barriers, the appellate court held that petitioners are not required to “address and explain potential procedural bars” at the initial stage when seeking counsel.
The court further explained that a “petition raising a claim of this nature for the first time … shall not be deemed a successive or abusive petition.” Calling the lower court’s reasoning legally flawed, the opinion states that “an abuse of discretion arises if the trial court based its decision … on an incorrect legal standard.”
The appellate panel ultimately ordered the lower court to vacate its prior ruling and “conduct further proceedings consistent with this opinion.”
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