A California appeals court has thrown out the pimping and human trafficking conviction of an East Palo Alto man sentenced to 14 years in prison, ruling that the San Mateo County judge who presided over his 2023 trial let prosecutors improperly strike a Black prospective juror. The decision sends Dwayne Robinson's case back to San Mateo County, where prosecutors must now decide whether to retry him from scratch.
The First District Court of Appeal, Division Three, issued the unpublished opinion on June 12, finding that Judge Amarra Lee erred under California Code of Civil Procedure Section 231.7 by allowing the prosecution to reject a potential juror identified as R.M. without clear and convincing evidence that race was not a factor in the strike, according to The Press Democrat. Justice Carin T. Fujisaki, writing for the court, found that the prosecution's challenge was based explicitly and primarily on R.M.'s past negative experience with the criminal justice system, according to the Metropolitan News-Enterprise.
During jury selection, R.M. told the court he had a little bias toward how the judicial system operated because he and his grandson were victims in a criminal case, after a man pointed a gun at the two of them. Prosecutors said their primary reason for challenging R.M. was his discontent with that case, in which a light sentence was given to the person who threatened him and his grandson, while also citing his failure to disclose three prior criminal cases on his juror questionnaire. The defense objected, but Judge Lee overruled it, finding no substantial likelihood of discrimination — a standard the appellate panel found fell short of what Section 231.7 requires.
A 2020 Law Meant to Curb Bias in Jury Selection
Section 231.7 was enacted through Assembly Bill 3070 in 2020 and took effect for criminal jury selection on January 1, 2022, replacing California's traditional Batson/Wheeler standard with a list of presumptively invalid reasons for striking jurors, according to Kelmansky Law. The statute shifts the legal question away from proving intentional discrimination and toward whether an objective observer would view race as a factor at all. Expressing negative experiences with the criminal legal system is explicit grounds for presumptive invalidity under the law.
The stakes of getting that finding wrong are severe. Subdivision (j) of Section 231.7 mandates automatic reversal whenever a trial court improperly allows a presumptively invalid peremptory challenge, a provision the state Attorney General's Office did not challenge in this appeal, per the Metropolitan News-Enterprise. That automatic-reversal standard remains subject to ongoing constitutional debate among some appellate judges over miscarriage-of-justice standards, though it applied without dispute here.
The law's reach was reinforced further just weeks before the Robinson ruling became public. In a July 2026 decision in People v. Sanmiguel, the California Supreme Court ruled that attorneys offering behavior- or demeanor-based justifications for striking jurors must confirm the observed behavior and explicitly explain its relevance to the case, according to Justia Law. Trial judges statewide are increasingly expected to build exhaustive on-the-record findings before overriding a defense objection to a peremptory strike.
The Underlying Case: A Redwood City Sting
Robinson's prosecution stemmed from a May 2023 police sting in which an undercover officer arranged to meet a 22-year-old woman, referred to in court records as Peach, at a Redwood City hotel, prosecutors said. Investigators allege Robinson brought Peach to the hotel and that further investigation showed she had also been involved in sex work with clients in Gilroy and Morgan Hill. Prosecutors said Robinson received money from her sex work and sent her text messages demanding payment, alleging he trafficked the then-22-year-old against her will and lived off her earnings.
Prosecutors also said Peach was found hysterical and intoxicated with a scraped knee in April 2023 after Robinson allegedly pushed her to the ground. A jury convicted Robinson in November 2023 on one felony count of human trafficking and one felony count of pimping, according to court records, and Judge Lee sentenced him to concurrent terms of 14 years and three years. As Hoodline previously reported, the trial also featured a dramatic moment when the victim, who did not testify, interrupted defense closing arguments to proclaim her love for Robinson and accuse defense attorneys of lying before a bailiff escorted her out. Robinson had accumulated seven prior commitments to California state prison before his 2023 arrest.
Prosecutors Weigh Whether to Retry the Case
San Mateo County District Attorney Stephen Wagstaffe said his office had not decided as of Wednesday whether to retry Robinson, but maintained the case was provable and could be retried, according to the Press Democrat. Wagstaffe acknowledged that Judge Lee did not create a strong enough record or conduct enough inquiry to override the defense's objection to the juror strike. The district attorney's office now has 60 days from finalization of the ruling to decide whether to pursue a new trial.
Robinson's defense attorney, Charlie Smith, said he was happy for his client and pleasantly surprised by the ruling, noting that appellate courts rarely reverse a trial in its entirety and order a completely new one. Smith has requested an order for Robinson's return to jail in San Mateo County. Robinson, who is currently in state prison, will remain in custody until a judge rules on his custody status at an upcoming hearing; if the case proceeds toward retrial, he would be transferred to the Maguire Correctional Facility in Redwood City, which serves as the county's primary jail for adult male pretrial detainees, according to Local Crime News.
Judge Lee, who sentenced Robinson after the 2023 conviction, was appointed to the San Mateo County Superior Court in 2018 as the bench's first African American woman judge, following six years as a deputy district attorney in the same county's District Attorney's office, according to the Bar Association of San Francisco. Whether the case returns to trial now hinges on a decision from Wagstaffe's office, which must weigh the strength of its digital and sting-operation evidence against the demands of a law built specifically to prevent the kind of jury-selection error that just unraveled its earlier win.
