BILL ANALYSIS
SB 318
Page 1
Date of Hearing: June 30, 2009
Counsel: Gabriel Caswell
ASSEMBLY COMMITTEE ON PUBLIC SAFETY
Juan Arambula, Chair
SB 318 (Calderon) - As Amended: May 28, 2009
SUMMARY : Provides for forfeiture procedures for certain
property acquired through the crime of dog fighting, as
specified. Specifically, this bill :
1)Provides that any property interest, whether tangible or
intangible, acquired through the commission of any of
specified dog fighting crimes shall be subject to forfeiture,
including both personal and real property, profits, proceeds,
and the instrumentalities acquired, accumulated, or used by
dog fighting participants, organizers, transporters of animals
and equipment, breeders and trainers of fighting dogs, and
persons who steal or illegally obtain dogs or other animals
for fighting, including bait and sparring animals.
2)States that the prosecuting agency in a criminal proceeding in
which the defendant has been charged with the commission of
any specified dog fighting crime, in conjunction with the
criminal proceeding, file a petition for forfeiture. If the
prosecuting agency has filed a petition for forfeiture and the
defendant is convicted of any of the specified dog fighting
crimes, the specified assets shall be subject to forfeiture
upon proof of the required legal elements.
3)Excepts the following property from forfeiture under this
section:
a) Property solely owned by a bona fide purchaser for
value, who was without knowledge that the property was
intended to be used for a purpose which would subject it to
forfeiture under this section, or is subject to forfeiture
under this section; and,
b) Property used as a family residence and owned by two or
more inhabitants, one of whom had no knowledge of its
unlawful use.
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4)Requires that the prosecuting agency shall make service of
process of a notice regarding that petition upon every
individual who may have a property interest in the alleged
proceeds, which notice shall state that any interested party
may file a verified claim with the superior court stating the
amount of the party's claimed interest and an affirmation or
denial of the prosecuting agency's allegation.
a) Provides that if the notices cannot be served by
registered mail or personal delivery, the notices shall be
published for at least three consecutive weeks in a
newspaper of general circulation in the county where the
property is located.
b) States that if the property alleged to be subject to
forfeiture is real property, the prosecuting agency shall,
at the time of filing the petition for forfeiture, record a
lis pendens in each county in which real property alleged
to be subject to forfeiture is located.
5)Provides that the judgment of forfeiture shall not affect the
interest of any third party in real property that was acquired
prior to the recording of the lis pendens.
6)States that all notices shall set forth the time within which
a claim of interest in the property seized is required to be
filed pursuant to this section.
7)Provides any person claiming an interest in the property or
proceeds seized may, at any time within 30 days from the date
of the first publication of the notice of seizure, or within
30 days after receipt of the actual notice, file with the
superior court of the county in which the action is pending a
verified claim stating his or her interest in the property or
proceeds. A verified copy of the claim shall be given by the
claimant to the Attorney General, or the district or city
attorney, whichever is the prosecuting agency of the
underlying crime.
8)States that if, at the end of the specified time set forth, an
interested person, other than the defendant, has not filed a
claim, the court, upon a motion, shall declare that the person
has defaulted upon his or her alleged interest, and that
interest shall be subject to forfeiture upon proof of the
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specified legal elements.
9)Provides that the defendant may admit or deny that the
property is subject to forfeiture pursuant to this section.
If the defendant fails to admit or deny, or fails to file a
claim of interest in the property or proceeds, the court shall
enter a response of denial on behalf of the defendant.
10)Requires that the forfeiture proceeding be set for hearing in
the superior court in which the underlying criminal offense
will be tried. If the defendant is found guilty of the
underlying offense, the issue of forfeiture shall be promptly
tried, either before the same jury or before a new jury in the
discretion of the court, unless waived by the consent of all
parties.
11)States that at the forfeiture hearing, the prosecuting agency
shall have the burden of establishing beyond a reasonable
doubt that the defendant was engaged in any of the specified
dog fighting crimes and that the property comes within the
specified provisions.
12)Provides that concurrent with, or subsequent to, the filing
of the petition, the prosecuting agency may move the superior
court for the following pendente lite orders to preserve the
status quo of the property alleged in the petition of
forfeiture:
a) An injunction to restrain all interested parties and
enjoin them from transferring, encumbering, hypothecating,
or otherwise disposing of that property.
b) Appointment of a receiver to take possession of, care
for, manage, and operate the assets and properties so that
the property may be maintained and preserved.
13)States that no preliminary injunction may be granted or
receiver appointed without notice to the interested parties
and a hearing to determine that the order is necessary to
preserve the property, pending the outcome of the criminal
proceedings, and that there is probable cause to believe that
the property alleged in the forfeiture proceedings are
proceeds or property interests forfeitable. However, a
temporary restraining order may issue pending that hearing
pursuant to the specified provisions of Code of Civil
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Procedure.
14)Provides that if the trier of fact at the forfeiture hearing
finds that the alleged property or proceeds are forfeitable,
and that the defendant was convicted of a specified crime, the
court shall declare that property or proceeds forfeited to the
state or local governmental entity, subject to the specified
distribution scheme.
15)States that if the trier of fact at the forfeiture hearing
finds that the alleged property is forfeitable but does not
find that a person holding a valid lien, mortgage, security
interest, or interest under a conditional sales contract
acquired that interest with actual knowledge that the property
was to be used for a purpose for which forfeiture is
permitted, and the amount due to that person is less than the
appraised value of the property, that person may pay to the
state or the local governmental entity that initiated the
forfeiture proceeding the amount of the registered owner's
equity, which shall be deemed to be the difference between the
appraised value and the amount of the lien, mortgage, security
interest, or interest under a conditional sales contract.
Upon that payment, the state or local governmental entity
shall relinquish all claims to the property.
16)States that if the holder of the interest elects not to make
that payment to the state or local governmental entity, the
property shall be deemed forfeited to the state or local
governmental entity.
17)Provides the appraised value shall be determined as of the
date judgment is entered either by agreement between the legal
owner and the governmental entity involved, or if they cannot
agree, then by a court-appointed appraiser for the county in
which the action is brought.
18)States that if the amount due to a person holding a valid
lien, mortgage, security interest, or interest under a
conditional sales contract is less than the value of the
property and the person elects not to make payment to the
governmental entity, the property shall be sold at public
auction by the Department of General Services (DGS) or by the
local governmental entity which shall provide notice of that
sale by one publication in a newspaper published and
circulated in the city, community, or locality where the sale
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is to take place. Proceeds of the sale shall be distributed
pursuant to the specified distribution scheme.
19)States that in all cases where property is forfeited pursuant
to this section and is sold by the DGS or a local governmental
entity, the property forfeited or the proceeds of the sale
shall be distributed by the state or local governmental
entity, as follows:
a) To the bona fide or innocent purchaser, conditional
sales vendor, or holder of a valid lien, mortgage, or
security interest, if any, up to the amount of his or her
interest in the property or proceeds, when the court
declaring the forfeiture orders a distribution to that
person. The court shall endeavor to discover all those
lien holders and protect their interests and may, at its
discretion, order the proceeds placed in escrow for a
period not to exceed 60 additional days to ensure that all
valid claims are received and processed.
b) To the DGS or local governmental entity for all
expenditures made or incurred by it in connection with the
sale of the property, including expenditures for any
necessary repairs, storage, or transportation of any
property seized under this section.
c) To local, nonprofit organizations exempt, as specified,
of the Internal Revenue Code, the primary activities of
which include ongoing rescue, foster, or other care of
animals that are the victims of dog fighting, and to law
enforcement entities, including multi-agency task forces,
that actively investigate and prosecute animal fighting
crimes.
d) Any remaining funds not fully distributed to
organizations or entities shall be deposited in an escrow
account or restricted fund to be distributed as soon as
possible.
20)States that the intent of the Legislature in enacting this
act is to seek the eradication of dog fighting by
systematically reducing the economic resources available to
those criminals who facilitate and support the crime of dog
fighting.
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21)Finds and declares the following:
a) That dog fighting is an insidious underground organized
crime and, notwithstanding its absolute prohibition in
America, this crime has reached epidemic proportions in all
urban communities and continues to thrive in many rural
areas as well.
b) That many communities have been morally, socially, and
culturally scarred by the continuing presence of dog
fighting. Children who are exposed to the unfathomable
violence of dog fighting are conditioned to believe that
violence is normal and are systematically desensitized to
the consequential suffering.
c) That dog fighters are violent criminals who engage in a
whole host of peripheral criminal activities. Many are
heavily involved in organized crime, racketeering, drug
distribution, and gang-related criminal activity, and they
arrange and attend the fights as a forum for gambling and
drug trafficking. These activities, both individually and
collectively, present a clear and present danger to public
order and safety and are not constitutionally protected.
d) That an effective means of punishing and deterring the
criminal activities of dog fighters is through forfeiture
of the property, both personal and real, profits, proceeds,
and the instrumentalities acquired, accumulated, or used by
dog fighting participants, organizers, transporters of
animals and equipment, property owners who allow their
premises to be used for dog fighting and other activities
in support of dog fighting, and breeders and trainers of
fighting dogs, and persons who steal and illegally obtain
dogs and other animals for fighting, including bait and
sparring animals.
e) That dog fighting not only encourages and furthers
antisocial values and violence but also results in the
anti-socialization of dogs, thereby making them a danger to
the community at large. Police officers, firefighters,
utility, and other municipal workers are at increasing risk
in the course of their employment on both public and
private property because of the epidemic number of dogs
that have been bred and trained to fight each other, as are
other animals, small children, and adults.
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f) That public animal shelters, humane societies, and
nonprofit animal rescue and adoption groups that rescue and
care for animals bear much of the social, economic, and
moral burden caused by dog fighting. Specialized
multi-agency law enforcement entities, such as anticruelty
task forces comprised of municipal animal control, local
police, sheriff, and city and district attorneys
investigating, arresting, and prosecuting dog fighting and
other crimes against animals, are a critical component of
the goal of reducing and eliminating this heinous crime in
California, yet these agencies suffer from limited
resources.
g) That forfeited property, profits, proceeds, and
instrumentalities acquired, accumulated, or used by dog
fighting participants and others acting in support of dog
fighting should be sold to support efforts to care for
abused animals and the law enforcement entities specially
formed to address dog fighting and animal cruelty, wherever
possible. Distribution of the above should be determined
by the state or local governing bodies, depending upon
which is responsible for the prosecution as a result of
which the proceeds were seized.
EXISTING LAW :
1)States that if any person owning or having custody and control
of a mischievous animal, knowing its propensities, willfully
suffers the animal to go at large, or keeps the animal without
ordinary care, and the animal, while at large or while not
kept with ordinary care, kills any human being who has taken
all precautions that the circumstances permitted or which a
reasonable person would ordinarily take in a similar
situation, is guilty of a felony. [Penal Code Section
399(a).]
2)Provides that if any person owning or having custody of a
mischievous animal, knowing its propensities, willfully
suffers it to go at large, or keeps the animal without
ordinary care, and the animal, while at large or while not
kept with ordinary care, causes serious bodily injury to any
human being who has taken all the precautions that
circumstances permitted, or which a reasonable person would
ordinarily take in the same situation, is guilty of a
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misdemeanor or a felony. [Penal Code Section 399(b).]
3)Provides that any person owning or having custody or control
of a dog trained to fight, attack, or kill is guilty of an
alternate misdemeanor/felony, punishable by imprisonment in
the state prison for two, three or four years; in the county
jail not to exceed one year; by a fine not exceeding $10,000;
or by both such fine and imprisonment if, as a result of the
human being on two separate occasions or on one occasion
causing substantial physical injury. Existing law also states
that no person shall be criminally liable under this section
unless he or she knew or reasonably should have known of the
vicious and dangerous nature of the dog, or if the victim
failed to take all the precautions that a reasonable person
would ordinarily take in the same situation. [Penal Code
Section 399.5(a).]
4)States that following a conviction under this section, a court
shall hold a hearing to determine whether conditions of the
treatment or confinement of the dog or other circumstances
existing at the time of the bite or bites have changed so as
to remove the danger to other persons presented by the animal.
Existing law also provides that the court, after the hearing,
may make any order it deems appropriate to prevent the
recurrence of such an incident including, but not limited to,
the removal of the animal from the area or destruction if
necessary. [Penal Code Section 399.5(b).]
5)States that nothing in this section shall be construed to
affect the liability of the owner of a dog under Penal Code
Section 399 or any other provision of law. [Penal Code
Section 399.5(d).]
6)States that this section shall not apply to a veterinarian or
an on-duty animal control officer while in the performance of
his or her duties or to a peace officer, as defined, if he or
she is assigned to a canine unit. [Penal Code Section
399.5(e).]
7)Provides that any person, who for amusement or gain, causes
any bull, bear, or other animal, not including any dog, to
fight with the like kind of animal or creature, or causes any
animal, including any dog, to fight with a different kind of
animal or creature, or with any human being; or who, for
amusement or gain, worries or injures any bull, bear, dog, or
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other animal, or causes any bull, bear or other animal, not
including any dog, to worry or injure each other; any person
who permits the same to be done on any premises under his or
her charge or control; and any person who aids, abets, is
guilty of a misdemeanor punishable by up to one year in jail
and/or a fine of $5,000. [Penal Code Section 597b(a).]
8)Makes it a misdemeanor to cause, for amusement or gain, an
animal to fight a like or different animal. The penalty for a
first offense is up to one year in county jail and/or a fine
of $5,000. A second or subsequent violation of this section
or Penal Code Sections 597c or 597j is a misdemeanor with a
penalty of up to one year in county jail and/or a fine up to
$25,000. [Penal Code Section 597b(b).]
9)Provides that any person who is knowingly present as a
spectator at any place, building, or tenement for an
exhibition of animal fighting, or who is knowingly present
where preparations are being made for animal fighting is
guilty of a misdemeanor. (Penal Code Section 597c.)
10)Makes it a misdemeanor for any person to own, possess, keep
or train any bird or animal with the intent that it be used in
an exhibition of fighting. The penalty for a first offense is
up to one year in county jail and/or a fine of $5,000. A
second or subsequent violation of this section or Penal Code
Sections 597b or 597c is a misdemeanor with a penalty of up to
one year in county jail and/or a fine up to $25,000. (Penal
Code Section 597j.)
11)Provides that peace officers do not need a warrant to enter a
building where there is an exhibition of the fighting of birds
or animals, or where preparations are being made for such an
exhibition and may arrest all persons present. (Penal Code
Section 597d.)
12)Provides that every owner, driver, or possessor of any animal
who permits the animal to be in any building, enclosure, lane,
street, square or lot, of any city, city and county, or
judicial district without proper care and attention, shall, on
conviction, be guilty of a misdemeanor. [Penal Code Section
597f(a).]
13)Provides that an officer making an arrest at an animal fight
may take possession of all birds or animals and all
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paraphernalia, implements or other property related to the
animal fighting. (Penal Code Section 599aa.)
14)Provides that any person who does any of the following is
guilty of a felony and is punishable by imprisonment in the
state prison for 16 months, two years or three years or by a
fine not exceeding $50,000 [Penal Code Section 597.5(a)]:
a) Owns, possesses, keeps, or trains any dog, with the
intent that the dog shall be engaged in an exhibition of
fighting with another dog.
b) For amusement or gain, causes any dog to fight with
another dog, or causes any dogs to injure each other.
c) Permits either of the above to be done on any premises
under his or her charge or control, or aids, or abets that
act.
15) Provides that any person who is knowingly present, as a
spectator, at any place, building, or tenement where
preparations are being made for an exhibition of the fighting
of dogs, with the intent to be present at those preparations,
or is knowingly present at the exhibitions or at any other
fighting or injuring with the intent to be present at that
exhibition, fighting or injuring, is guilty of a misdemeanor.
[Penal Code Section 597.5 (b).]
16) Provides that any officer making an arrest under specified
animal protection statute may lawfully take possession of all
birds or animals and all paraphernalia, implements or other
property or things used or employed or about to be employed in
the violation of any of the provisions of this code relating
to the fighting of birds or animals that can be used in animal
or bird fighting, in training animals or birds to fight, or to
inflict pain or cruelty upon animals or birds in respect to
animal or bird fighting and sets forth the care of the animals
and paraphernalia seized. Upon conviction, all property
seized shall be adjudged by the court to be forfeited and
shall then be destroyed or otherwise disposed of as the court
may order. The court may also order the person to make
payment to the appropriate public entity for the costs
incurred in the housing, care and feeding of the birds or
animals. (Penal Code Section 599aa.)
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17)Establishes the "California Control Profits of Organized
Crime Act." (Penal Code Section 186.)
18)Fails to list "dog fighting" as a "criminal profiteering
activity." [Penal Code Section 186.2(a).]
19)States that the following assets of any person who is
convicted a specified underlying offense and of engaging in a
pattern of criminal profiteering activity are subject to
forfeiture (Penal Code Section 186.3):
a) Any property interest whether tangible or intangible,
acquired through a pattern of criminal profiteering
activity.
b) All proceeds of a pattern of criminal profiteering
activity, which property shall include all things of value
that may have been received in exchange for the proceeds
immediately derived from the pattern of criminal
profiteering activity.
20)States that, notwithstanding that no response or claim has
been filed, in all cases where property is forfeited, as
specified, and, if necessary, sold by DGS or local
governmental entity, the money forfeited or the proceeds of
sale shall be distributed by the state or local governmental
entity as follows (Penal Code Section 186.8):
a) To the bona fide or innocent purchaser, conditional
sales vendor, or holder of a valid lien, mortgage, or
security interest, if any, up to the amount of his or her
interest in the property or proceeds, when the court
declaring the forfeiture orders a distribution to that
person. The court shall endeavor to discover all those
lien holders and protect their interests and may, at its
discretion, order the proceeds placed in escrow for up to
an additional 60 days to ensure that all valid claims are
received and processed.
b) To DGS or local governmental entity for all expenditures
made or incurred by it in connection with the sale of the
property, including expenditures for any necessary repairs,
storage, or transportation of any property seized, as
specified.
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c) To the State's General Fund or local governmental
entity, whichever prosecutes.
FISCAL EFFECT : Unknown
COMMENTS :
1)Author's Statement : According to the author, "[d]og fighting
is an insidious underground, organized crime and that has
reached epidemic proportions in urban communities and thrives
in many rural areas as well. Many communities have been
morally, socially and culturally scarred by the continuing
presence of dog fighting. Children who are exposed to the
unfathomable violence of dog fighting are conditioned to
believe that violence is normal and are systematically
desensitized to the consequential suffering. Dog fighters are
often violent criminals that engage in a whole host of
peripheral criminal activities, such as gangs, racketeering
and drug trafficking. These activities present a clear and
present danger to public order and safety and are not
constitutionally protected.
"In order to seek eradication of dog fighting by
systematically reducing the economic resources available to
these criminals who facilitate and support the crime of dog
fighting, Senator Calderon has introduced SB 1775.
"The measure is a means of punishing and deterring the
criminal activities of dog fighters is through forfeiture of
the property, both personal and real, profits, proceeds and
the instrumentalities acquired, accumulated or used by dog
fighting participants, organizers, transporters of animals and
equipment, property owners who allow their premises to be used
for dog fighting and other activities in support of dog
fighting, breeders of, trainers of, and persons who steal and
illegally obtain dogs and other animals for fighting,
including bait and sparring animals.
"Proceeds acquired through the post-conviction forfeiture
process will be distributed to law enforcement agencies to
help reimburse the costs associated with investigating and
prosecuting dog fighting cases and animal-welfare organization
that care for and rehabilitate animals rescued from dog
fighters."
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2)Criminal Profiteering Generally : Criminal profiteering asset
forfeiture is a criminal proceeding held in conjunction with
the trial of the underlying criminal offense. Often, the same
jury that heard the criminal charges also determines whether
the defendant's assets were the ill-gotten gains of criminal
profiteering. As a practical matter, the prosecution must
assemble its evidence for the forfeiture matter simultaneously
with the evidence of the crime.
In contrast, drug asset forfeiture is a separate civil action.
Except where the property forfeited is cash of value of at
least $25,000, a conviction for an underlying drug offense is
required. However, the rules of civil discovery and procedure
apply. The prosecution can conduct substantial civil
discovery to determine the extent of the defendant's assets.
Pursuant to Public Resources Code Section 14591, it is a crime
to defraud the State's Recycling Fund. However, in order for
the asset forfeiture laws to apply in a recycling fraud case,
the prosecutor must argue that the violation of Public
Resources Code Section 14591 is "grand theft" as defined in
Penal Code Section 487. The crime of grand theft is currently
included in the definition of criminal profiteering contained
in Penal Code Section 186.2. This bill removes the second
step of proving that the recycling fraud is grand theft in an
asset forfeiture case. By listing fraud of the California
Beverage Container Recycling and Letter Reduction Act in Penal
Code Section 186.2, a prosecutor can seek asset forfeiture
without proving grand theft.
Dog fighting crimes are not listed within the criminal
profiteering section. One alternative to this bill is to
include dog fighting crimes within this section, where the law
is settled and established, rather than creating an entirely
new section specifically for dog fighting crimes.
3)Criminal Profiteering Proceeds : Under existing law, the
forfeited proceeds of criminal profiteering are placed in the
county general fund with no directions for use. There is an
exception for forfeiture in child pornography cases. In such
cases, the money is deposited in the county or State
Children's Trust Fund for child abuse and neglect prevention
and intervention. (Penal Code Section 186.8 and Welfare and
Institutions Code Sections 18966 and 18969.)
In California drug asset forfeiture, law enforcement receives
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65% of forfeiture proceeds. (Health and Safety Code Sections
11469 et seq.) Of this amount, 15% must be placed in a
special county or city fund used "to combat drug abuse and
divert gang activity." Under federal forfeiture law allowing
"adoption" of state seizures of drug proceeds, the agency
seizing that property may receive as much as 80% of these
proceeds. This money must be used according to guidelines set
by the United States Department of Justice and require that
the money be used largely for law enforcement.
4)Forfeiture for Dog Fighting : Existing law permits forfeiture
for any property interest whether tangible or intangible
acquired through a pattern of criminal profiteering activity.
Criminal profiteering activity includes any act committed or
attempted or any threat made for financial gain or advantage
which act or threat may be charged as a crime under specified
enumerated felony sections. (Penal Code Sections 186.2;
186.3.) The law establishes procedures for forfeiture upon a
conviction of a pattern of criminal profiteering. (Penal Code
Section 186 et seq.) "A pattern of criminal profiteering" is
defined as engaging in at least two incidents of criminal
profiteering. [Penal Code Section 186.2(b).]
Existing law also permits the seizure of any animals used in
fighting, as well as all paraphernalia, implements or other
property or things used or employed, or about to be employed,
in violation of any bird or animal fighting statute. Upon
conviction, the items seized shall be deemed forfeited.
(Penal Code Section 599aa.)
5)Eliminates the Requirement of a Pattern of Criminal
Profiteering : This bill takes procedures established for
forfeiture for criminal profiteering and applies those
procedures to forfeiture of property acquired through the
commission of felony dog fighting-related crimes. The only
distinction between this bill and what would exist if dog
fighting felonies were added to the list of criminal
profiteering crimes is that no "pattern of criminal
profiteering" must be shown under this bill. Under the
criminal profiteering statute, the law requires that at least
two incidents of the specified criminal activity must be shown
prior to forfeiture of assets or property. This bill fails to
require a showing of a pattern of criminal profiteering.
6)Distribution of Funds : The existing forfeiture for criminal
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profiteering statutes specifies how the funds shall be
distributed. This bill copies that existing scheme but also
includes the distribution of funds to "local non-profits whose
primary activities include ongoing rescue, foster, or other
care of animals that are the victims of dog fighting; and to
law enforcement entities, including multiagency task forces,
that actively investigate and prosecute animal fighting
crimes."
Supporters of this bill point out that having part of the
forfeiture money distributed to nonprofits will assist in
their burden of rescuing and caring for the animals. A
question could be raised, however, about whether having part
of the proceeds distributed to law enforcement investigating
and prosecuting these crimes could lead to an overbroad reach
of what items are forfeitable in a statute where what is used
to "facilitate" the crime could be interpreted quite broadly.
7)Argument in Support : According to the California State
Sheriffs' Association , "SB 318 authorizes the forfeiture of
specified property that is used in the commission of certain
dog fighting crimes. With the existence and practice of
organized dog fighting in California, we consider asset
forfeiture an effective means of deterring and punishing these
criminal activities and believe it is a responsible means to
address this growing trend."
8)Prior Legislation : SB 1775 (Calderon), 2007-08 Legislative
Session, would have provided for the forfeiture of any
property interest that was either acquired through the
commission of dog fighting or being a spectator at a dog fight
or used to promote, further or facilitate dog fighting. SB
1775 failed passage in the Senate Public Safety Committee.
REGISTERED SUPPORT / OPPOSITION :
Support
California State Sheriffs' Association
Los Angeles District Attorney's Office
Opposition
None
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Analysis Prepared by : Gabriel Caswell / PUB. S. / (916)
319-3744