People v. Berryman CA4/1

A model's reading — qwen3.8-27b, prompt v1, 2026-10-13T03:52Z · confidence high

The trial court denied Berryman's post-judgment motion for relief under the Racial Justice Act (RJA). The Court of Appeal dismissed the appeal for lack of jurisdiction, holding that a custodial defendant must seek RJA relief via a habeas corpus petition, not a motion, and that the trial court lacked subject matter jurisdiction to rule on the motion.

Ruling reviewed	Standard	The court	The model
Denial of post-judgment motion for relief under the Racial Justice Act (Pen. Code, § 745) “The trial court therefore lacked jurisdiction to act on the motion that he filed, and the court’s order denying that motion is not appealable.”	unclear	error	agree with court agree with court

Authorities

• relied: People v. Hodge (2024) 107 Cal.App.5th 985 — A custodial defendant may seek review under the Racial Justice Act only in a petition for writ of habeas corpus; a trial court lacks jurisdiction to act on a motion for relief, and the resulting order is not appealable.
• relied: In re E.M. (2014) 228 Cal.App.4th 828 — Any judgment or order rendered by a court lacking subject matter jurisdiction is void.
• relied: People v. Serrano (2024) 106 Cal.App.5th 276 — Petitioners or appointed counsel may request discovery for the purpose of developing RJA claims and/or filing an amended petition.
• relied: In re Montgomery (2024) 104 Cal.App.5th 1062 — Petitioners or appointed counsel may request discovery for the purpose of developing RJA claims and/or filing an amended petition.
• relied: Young v. Superior Court (2022) 79 Cal.App.5th 138 — Petitioners or appointed counsel may request discovery for the purpose of developing RJA claims and/or filing an amended petition.

The appellate opinion: sound — The opinion correctly applies People v. Hodge to establish that the trial court lacked subject matter jurisdiction to rule on a motion for RJA relief filed by a custodial defendant, rendering the order void and non-appealable. It properly declines to convert the appeal into a habeas petition, noting that the procedural requirements for RJA habeas (such as appointment of counsel and discovery) are better suited to the superior court.

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A model's reading — claude-fable-5-1, prompt v1, 2026-10-13T04:29Z · confidence low

The Imperial County Superior Court denied Warren Berryman's pro per post-judgment motion for relief under the Racial Justice Act (Pen. Code, § 745) while he was in custody serving a life sentence for first degree murder. The Court of Appeal, following People v. Hodge, held that an in-custody defendant may raise RJA claims only by habeas petition, that the trial court lacked jurisdiction to rule on the motion, and that the denial order is not appealable; it declined to treat the appeal as a habeas petition and dismissed without prejudice to a properly filed RJA habeas petition in superior court.

Ruling reviewed	Standard	The court	The model
Trial court's adjudication of Berryman's post-judgment RJA motion on the merits (denial of the motion) while he was in custody “The trial court therefore lacked jurisdiction to act on the motion that he filed, and the court’s order denying that motion is not appealable.”	unclear	error (procedure)	agree with court The opinion does not state a standard, but appealability and subject-matter jurisdiction are legal questions reviewed independently. Relying on Hodge, the court treated the trial court's ruling as void for want of jurisdiction because an in-custody defendant must proceed by habeas corpus under section 1473, subdivision (e); the court expressly noted the order was void under In re E.M. so that the same claims may be reasserted. The reasoning tracks Hodge's reading of the statutory scheme, and the opinion gives no basis to find a contrary binding authority.
Merits of the trial court's denial of the RJA claims “We express no view on the merits of Berryman’s RJA claims.”	unclear	not reached	agree with court Because the appeal was dismissed for lack of appellate jurisdiction, the court did not and could not reach the merits; dismissal without prejudice preserves the claims for a properly filed habeas petition, which is the correct course when the underlying order is void.

Authorities

• relied: People v. Hodge (2024) 107 Cal.App.5th 985 — An in-custody defendant may seek RJA relief only by petition for writ of habeas corpus; a trial court lacks jurisdiction to act on a post-judgment RJA motion, the denial order is not appealable, and an order denying a habeas petition is likewise not appealable.
• relied: In re E.M. (2014) 228 Cal.App.4th 828 — Any judgment or order rendered by a court lacking subject matter jurisdiction is void.
• relied: People v. Serrano (2024) 106 Cal.App.5th 276 — A petitioner or appointed counsel may seek discovery to develop RJA claims and amend a habeas petition with additional evidence, proceedings best conducted in superior court.
• relied: In re Montgomery (2024) 104 Cal.App.5th 1062 — Discovery is available to develop RJA habeas claims (review granted Dec. 11, 2024, S287339).
• relied: Young v. Superior Court (2022) 79 Cal.App.5th 138 — Standards governing RJA discovery requests and the showing of good cause for disclosure of evidence relevant to a potential RJA violation.

The appellate opinion: sound with gaps — The dismissal follows directly from Hodge's holding that in-custody defendants must proceed by habeas and that denial orders on RJA motions are not appealable, and the court sensibly explained why it would not convert a pro per motion into an appellate habeas petition given the counsel, amendment, and discovery rights available in superior court. The gap is that the court simply adopted Hodge without engaging the parties' appealability arguments or the text of section 745 itself, which matters because Hodge was then a very recent decision on an unsettled question.

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