LETTER TO HONORABLE JUDGE RICHARD M. KING
Re: In re Chazz Jackson, Case No. M-21903
Dear Judge King,
We write to you not as lawyers, but as members of the community who have followed this case with unwavering attention. We have read the briefs, reviewed the certified transcripts, and witnessed the proceedings. We write to urge you to not only vacate Mr. Jackson's conviction, but to dismiss the case with prejudice—the only remedy that matches the magnitude of what occurred in this prosecution.
We offer these reasons for your consideration:
1. THE BIAS WAS NOT ISOLATED—IT WAS INSTITUTIONAL
This case does not involve a single errant remark. It involves racial bias at every level of the prosecution.
Judge Steven D. Bromberg, the presiding judge, told the jury pool: "you see one gentleman, an African-American, he's black, and you probably figured he's the defendant." The judge himself instructed prospective jurors that Blackness equals criminality.
Lt. Craig Friesen of the Anaheim Police Department, head of the Orange County Human Trafficking Task Force, testified as an expert that "pimps are generally black." He then doubled down, stating that "most people we arrested were Black," using his own racially disproportionate arrests as "proof" of Black criminality. He further testified that different types of pimping correlate to different races—a racial profiling framework presented as expert opinion.
DA Brad Schoenleben repeatedly elicited the "no black men" rule throughout trial, introduced exhibits containing only the phrase "sorry no black guys," and juxtaposed a photo of Chazz immediately after displaying a "no black men" image. He used animal imagery in closing, referring to people "like Mr. Jackson" who "prey on the vulnerable."
Officer Paul Delgado, the arresting officer, testified at the preliminary hearing that "male blacks often recruit prostitutes," exhibiting racial bias at the earliest stage of prosecution.
Deputy DA Holly Woesner conceded at the January 23 hearing that "it's either/or, Your Honor"—admitting that racially discriminatory language alone, under § 745(a)(2), constitutes a violation of the Racial Justice Act. She had no further argument on the issue.
This is not a case of a single "diseased cell." This is a systemic infection.
2. THE LEGISLATURE HAS ALREADY DECIDED WHAT THIS REQUIRES
Assembly Bill 1071, section 1(e) declares:
"Racial bias in criminal prosecutions, in all its forms or degrees, is never minor or harmless. Like a metastatic cancer, racial bias in one part of a criminal prosecution infects the whole and cannot be remedied by removing a single diseased cell."
The Legislature did not leave room for interpretation. They declared that racial bias of this nature demands excision.
A new trial removes one cell. Dismissal excises the cancer.
3. THE STATE HAS NOT—AND CANNOT—MEET ITS BURDEN
Under Penal Code § 745(k), once a violation is proven, the state must prove beyond a reasonable doubt that the violation did not contribute to the judgment.
At the March 3 hearing, the DA offered nothing new. They relied on the same "overwhelming evidence" argument that courts have repeatedly rejected under Chapman and Sek. They never attempted to prove—because they cannot prove—that a judge's racial stereotyping, an expert's testimony that "pimps are generally black," and a prosecutor's "no black men" rule did not affect the verdict.
The burden is theirs. They have not met it.
4. THE DA'S OWN ADMISSIONS ARE LOCKED IN THE RECORD
The certified transcript from January 23, 2026, page 46, contains this exchange:
THE COURT: "If there is racially discriminatory language about the defendant's race, I read that as that's a violation."
MS. WOESNER: "It's either/or, Your Honor, yes."
THE COURT: "Anything further on that issue?"
MS. WOESNER: "No, Your Honor."
The DA conceded that racially discriminatory language alone violates the RJA. Lt. Friesen's testimony fits that definition precisely. There is no further argument to be made.
5. A NEW TRIAL WOULD BE FUTILE AND WASTEFUL
If this Court vacates the conviction but orders a new trial, the following will happen:
New charges will be filed. The defense will immediately file a new RJA motion based on the same evidence. Lt. Friesen's testimony about task force bias will still exist. Officer Delgado's preliminary hearing statements will still exist. The pattern of racially disproportionate arrests will still exist. The Court will be forced to litigate the same issues again.
This would waste judicial resources and prolong a case that has already consumed 11 years.
The only efficient, just outcome is dismissal with prejudice.
6. THE PATTERN BEYOND THIS CASE CONFIRMS WHAT HAPPENED HERE
The Orange County District Attorney's office has now lost three RJA discovery appeals in a single day—Cole, Sepulveda, and White—all defended by the same deputy, Holly Woesner. The Fourth District has repeatedly ordered the OCDA to stop blocking RJA claims.
The office has faced two multimillion-dollar jury verdicts for retaliation—Cope-Vega ($3.5 million) and Miller ($3 million plus $1.54 million in fees). Two additional cases settled for $1.3 million. Four more lawsuits are pending. The county has spent over $11 million defending misconduct in Spitzer's office.
This is not an isolated office. This is a pattern. And Chazz Jackson was caught in it.
7. THE COMMUNITY HAS WATCHED—AND WILL CONTINUE TO WATCH
Millions of views of our content. Thousands of accounts reached. A courtroom filled with silent supporters.
We have watched this case not as spectators, but as witnesses to history. We have read every filing. We have tracked every admission. We have seen what the DA refuses to answer.
We will continue to watch.
And when this Court issues its ruling, we will know whether the law has meaning—or whether the system protects itself at the expense of justice.
OUR REQUEST
Your Honor, you have before you:
A record of explicit, uncontested racial bias. A statute that mandates relief. A Legislature that has declared bias a "metastatic cancer." A DA's office that cannot meet its burden. A community that will not look away.
We respectfully urge you to:
- Find that RJA violations have been proven under both § 745(a)(1) and (a)(2)
- Hold that the state has failed to meet its burden under § 745(k)
- Grant the petition for writ of habeas corpus
- Vacate the conviction
- Dismiss the case with prejudice
Nothing less matches the harm. Nothing less serves the law. Nothing less restores faith that justice is possible.
Respectfully,
X____________________________________________________
Print Name:_________________________________________
The Undersigned Supporter of Justice.
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Honorable Richard M. King
Orange County Superior Court
Central Justice Center
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Santa Ana, CA 92701
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