This is the property of the Daily Journal Corporation and fully protected by copyright. It is made available only to Daily Journal subscribers for personal or collaborative purposes and may not be distributed, reproduced, modified, stored or transferred without written permission. Please click "Reprint" to order presentation-ready copies to distribute to clients or use in commercial marketing materials or for permission to post on a website. and copyright (showing year of publication) at the bottom.
Subscribe to the Daily Journal for access to Daily Appellate Reports, Verdicts, Judicial Profiles and more...

Criminal

Sep. 25, 2026

A concurrence in the spotlight: In re Haney and the Racial Justice Act after Hazlett

The 1st District Court of Appeal's unusual partial publication in In re Haney highlights the continuing debate over whether racially discriminatory peremptory challenges should be actionable under California's Racial Justice Act and signals a potential invitation for legislative action.

Laurel Garcia

Higgs Fletcher & Mack LLP

See more...

A concurrence in the spotlight: <i>In re Haney</i> and the Racial Justice Act after <i>Hazlett</i>
Shutterstock

When a Court of Appeal panel publishes only the introduction to its opinion and leaves the rest unpublished, practitioners take notice. That is what the 1st District Court of Appeal did in In re Haney, a Racial Justice Act habeas matter decided Sept. 16, 2026. (In re Haney, No. A170412, 2026 WL 2731165 (Cal. Ct. App. Sept. 16, 2026).)

The court certified only its introduction for publication, expressly to frame a separate con...

To continue reading, please subscribe.
For only $95 a month (the price of 2 article purchases)
Receive unlimited article access and full access to our archives,
Daily Appellate Report, award winning columns, and our
Verdicts and Settlements.
Or
$895, but save $100 when you subscribe today… Just $795 for the first year!

Or access this article for $45
(Purchase provides 7-day access to this article. Printing, posting or downloading is not allowed.)

Already a subscriber?

Enewsletter Sign-up