BILL ANALYSIS Ó
SB 602
Page 1
Date of Hearing: June 21, 2011
ASSEMBLY COMMITTEE ON JUDICIARY
Mike Feuer, Chair
SB 602 (Yee) - As Amended: June 6, 2011
As Proposed to be Amended
SENATE VOTE : 40-0
SUBJECT : READER PRIVACY ACT
KEY ISSUE : SHOULD BOOK PROVIDERS BE PROHIBITED FROM DISCLOSING
PERSONAL INFORMATION ABOUT THEIR USERS WITHOUT A COURT ORDER
UNDER SPECIFIED STANDARDS?
FISCAL EFFECT : As currently in print this bill is keyed fiscal.
SYNOPSIS
This bill is sponsored by the American Civil Liberties Union
(ACLU) and the Electronic Frontier Foundation (EFF) to codify
explicit privacy protections for books and comparable materials
so that bookstores and other providers of book services as well
as government agencies, courts and private parties have clear
guidelines by which to evaluate attempts to obtain this
sensitive personal information. The bill, supported by Google
and other booksellers, would enact the Reader Privacy Act under
which book services providers may not disclose to any person or
entity the personal information of a user related to the use of
a book, except pursuant to a court order under specified
standards. Despite the broad values of the sponsors and author,
the bill is quite targeted. It does not require court orders
where the user consents to the disclosure, or if there was an
imminent danger of death or serious physical injury that
requires the immediate disclosure or if the provider believes in
good faith that the personal information is evidence directly
related and relevant to a crime against the provider or the book
service user. More importantly, the bill does not limit the
ability of the government or private parties to obtain book
information from any source other than defined book service
providers. This limitation is particularly noteworthy because
the bill does not prohibit book providers from voluntarily
sharing personal information with business partners, such as
third-party marketers. Prior to proposed amendments, the
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California District Attorneys Association expressed concerns
about the bill's interplay with federal law, which overlaps to
some extent regarding certain newspapers and books and makes
certain searches unlawful while exempting others. The author's
proposed amendments are believed to be responsive to these
concerns.
SUMMARY : Protects unauthorized disclosure of private
information regarding books and book readers. Specifically,
this bill :
1)Provides that a book service provider may not knowingly
disclose to any government entity, or be compelled to disclose
to a government entity or any private person or entity, a
user's personal information related to the use of a book or
part of a book, except as follows:
a) To a law enforcement entity pursuant to a court order
issued by a duly authorized court with jurisdiction over an
offense under investigation if the following conditions are
met:
i) The court issuing the order finds that probable
cause exists to believe the personal information
requested is relevant evidence to the investigation of an
offense and any of the grounds in Section 1524 of the
Penal Code (i.e., grounds for a search warrant) is
satisfied.
ii) The court issuing the order finds that the person or
entity seeking disclosure has a compelling interest in
obtaining the personal information sought;
iii) The court issuing the order finds that the
information cannot be obtained through less intrusive
means;
iv) The person or entity seeking disclosure gives the
provider reasonable notice and the opportunity to appear
and contest the issuance of the order prior to its
issuance; and
v) Notice of the order is given to the book service
user contemporaneous with execution of the order, unless
there is a judicial determination of a strong showing of
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necessity to delay that notification for a reasonable
period of time, not to exceed seven days.
b) To a non-law enforcement government entity pursuant to a
court order issued by a duly authorized court with
jurisdiction over an offense that is under investigation by
a non-law enforcement government entity, or to a non-law
enforcement government entity or a private person or entity
pursuant to a court order in a pending civil or
administrative action brought by a non-law enforcement
governmental entity, private person or governmental entity,
if all of the following conditions are met:
i) The court issuing the order finds that the person or
entity seeking disclosure has a compelling interest in
obtaining the personal information sought.
ii) The court issuing the order finds that the personal
information sought cannot be obtained by the person or
entity seeking disclosure through less intrusive means.
iii) The person or entity seeking disclosure provides the
provider with reasonable notice of the proceeding in a
timely manner prior to the issuance of the court order to
allow the user and provider the opportunity to appear and
contest the issuance of the court order.
iv) The provider refrains from disclosing any personal
information pursuant to the court order until it provides
notice in a timely manner to the user about the issuance
of the order and the ability to appear and quash the
order, and the user has been given a reasonable
opportunity to appear and quash the order of no less than
35 days.
2)Provides that a book service provider must disclose the
personal information of a user to any person if the user has
given his or her informed, affirmative consent to the specific
disclosure for that particular purpose.
3)Provides that a book service provider may disclose the user's
personal information to a government entity if the government
entity asserts, and the book service provider in good faith
believes, that there is an imminent danger of death or serious
physical injury requiring the immediate disclosure of the
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information and there is insufficient time to obtain an order.
Under this exception, the government entity must give to the
provider a written statement describing the facts giving rise
to the emergency upon request or no later than 48 hours after
seeking disclosure.
4)Provides that a book service provider may disclose a user's
personal information to a government entity if the provider
believes in good faith that the personal information is
evidence directly related and relevant to a crime against the
provider or that book service user.
5)Provides that the act does not make it unlawful for a law
enforcement entity subject to 42 U.S.C. section 2000aa to
obtain a search warrant for a user's personal information
pursuant to otherwise applicable law in connection with the
investigation or prosecution of a criminal offense where there
is probable cause to believe that the person possessing such
information has committed or is committing a criminal offense
involving the production, possession, receipt, mailing, sale
distribution, shipment or transportation of child pornography,
the sexual exploitation of children, or the sale or purchase
of children under sections 2251, 2251a, 2252, or 2252a of
title 18 of the United States Code. Moreover, this section
does not prevent a provider from complying with a proper
search warrant issued by a duly authorized court in connection
with such an investigation or prosecution.
6)Requires any court issuing a search order or civil discovery
order requiring disclosure of a book user's personal
information to impose appropriate safeguards against the
unauthorized disclosure of personal information by the
provider pursuant to the order.
7)Provides that, except in an action for a violation of the
bill's provisions, no evidence obtained in violation of the
bill shall be admissible in any civil, administrative, or
other proceeding.
8)Makes knowing disclosure to governmental entities a violation
of its provisions subject to the following penalties:
a) a provider who knowingly provides a book service user's
personal information shall be subject to a civil penalty of
up to $500 for each violation, which may be recovered in a
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civil action brought by the book user.
b) a provider who knowingly provides a user's personal
information shall also be subject to a civil penalty of up
to $500 for each violation which may be assessed and
recovered in a civil action brought by the Attorney
General, any district attorney, city attorney, or specified
city prosecutor. This bill would allocate any penalties
collected when an action is brought by these government
entities, as specified.
9)Provides that a civil action brought pursuant to the bill must
be commenced within two years after the date upon which the
claimant first discovered the violation.
10)Provides that, if a book service provider reasonably relies
on a court order for the release of a user's personal
information or relies on any of the bill's specified
exceptions to confidentiality, the provider's reliance is a
complete defense to any civil action provided that the
reasonable reliance is objective.
11)Requires a book service provider to prepare a report to be
made publicly available in an online, searchable format by
March 1 of every year. That report must include specified
information, including the number of federal and state
warrants and orders requesting disclosure of a user's personal
information that the provider has received in the previous
year. The report must also include this same information for
any grand jury subpoenas, civil and administrative subpoenas,
and requests for information made with the user's informed
consent received by the provider during the prior year.
12)Provides that nothing in the bill shall otherwise affect the
rights of any person under the California Constitution or any
other law.
EXISTING LAW :
1)Provides that Congress shall make no law . . . abridging the
freedom of speech. (U.S. Const. Amend. I.) The First
Amendment is binding on the states through the due process
clause of the Fourteenth Amendment. (Gitlow v. New York
(1925) 268 U.S. 652.)
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2)Provides that "Ýt]he right of the people to be secure in their
persons, houses, papers, and effects, against unreasonable
searches and seizures, shall not be violated, and no Orders
shall issue, but upon probable cause, supported by Oath or
affirmation, and particularly describing the place to be
searched, and the persons or things to be seized." (U.S.
Const. amend. IV.)
3)Provides that all people have inalienable rights, including
the right to pursue and obtain privacy. (Cal. Const. art. I,
sec. 1.)
4)Guarantees that "Ýe]very person may freely speak, write and
publish his or her sentiments on all subjects, being
responsible for the abuse of this right. A law may not
restrain or abridge liberty of speech or press." (Cal. Const.
art. I, sec. 2.)
5)Requires businesses that own or license personal information
about California residents to implement and maintain
reasonable security procedures and practices appropriate to
the nature of the information, to protect the personal
information from unauthorized access, destruction, use,
modification, or disclosure. (Civ. Code Sec. 1798.81.5.)
6)Defines "personal information" to mean any information that
identifies, relates to, describes, or is capable of being
associated with, a particular individual, including, but not
limited to, his or her name, signature, social security
number, physical characteristics or description, address,
telephone number, passport number, driver's license or state
identification card number, insurance policy number,
education, employment, employment history, bank account
number, credit card number, debit card number, or any other
financial information, medical information, or health
insurance information. (Civ. Code Sec. 1798.80.)
7)Provides various grounds for the issuance of a search order
and specifies that a search order cannot be issued but upon
probable cause supported by affidavit, naming or describing
the person to be searched or searched for, and particularly
describing the property, thing, or things and the place to be
searched. (Pen. Code Sections. 1524, 1525.)
8)Provides for the scope of discovery in civil actions and
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permits a party to obtain discovery by inspecting documents,
tangible things, land or other property, and electronically
stored information. (Code Civ. Proc. Sec. 2016.010 et seq.)
9)Exempts library circulation records from disclosure under the
California Public Records Act. Existing law provides that
those library records are confidential and shall not be
disclosed to any person, local agency, or state agency except:
(1) to a person acting within the scope of his or duties
within library administration; (2) to a person with written
authorization from the individual to whom the records pertain;
or (3) by order of the appropriate superior court. (Gov. Code
Sections 6254(j), 6267.)
10)Prohibits video stores from disclosing a customer's personal
information, including video tape sales or rental information,
to any other person without the written consent of the
customer, except in certain circumstances. (18 U.S.C. Sec.
2710; Civ. Code Sec. 1799.3.)
COMMENTS : The author explains the reason for the bill as
follows:
The books we read reveal private, often sensitive
information about our political and religious beliefs, our
health concerns, and our personal lives. Throughout
history, government and third parties have tried to collect
evidence of these reading habits to trample unpopular ideas
and beliefs and watch activists. That's why California law
has long recognized the importance of safeguarding reading
records and other expressive material.
Maintaining reader privacy is fundamental to the dignity of
Californians and to ensure that they can continue to enjoy
the full range of freedom of expression, inquiry and
thought.
As readers increasingly move away from borrowing books from
libraries and buying physical books in bookstores and
toward using electronic devices and online book services to
access and read books, California statutory law needs to
codify the privacy and free speech safeguards for
expressive records guaranteed by the California
Constitution and provide clear guidelines for government
and third party access to sensitive reading records.
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Currently, reader protections in California statutory law
only extend to library records, not records concerning
books browsed or purchased from online or physical
booksellers. Current federal statutory law also does not
safeguard book records.
The Reader Privacy Act of 2011 updates reader privacy laws
by mirroring the strong privacy and free speech standards
in California law - ensuring that government and third
parties cannot compel disclosure of private reading records
without proper justification.
Co-sponsor ACLU writes that "Ýu]nder SB 602, consumers may feel
more comfortable using new digital book services and technology
without worrying that their personal information will be
unprotected. California should promote the use of new
technology by ensuring that upgraded technology does not mean
downgraded privacy."
The Electronic Frontier Foundation (EFF), co-sponsor, writes in
support:
The books we choose to read reveal privacy information
about our political and religious beliefs, health concerns,
and our personal lives. Maintaining reader privacy is
fundamental to the dignity of Californians and to ensure
that they can continue to enjoy the full range of freedom
of expression, inquiry and thought.
This Bill Applies to Both Physical and Electronic Books and
Records - Including Newly Available and Highly Revealing
Electronic Data - and To Both Internet and "Bricks and Mortar"
Book Retailers. The sale of electronic books (e-books) has
increased significantly over the last several years. A recent
report by the Association of American Publishers indicated that
sales of e-books in January 2011 "increased by more than 115
percent compared to the same time the year before." ("E-book
sales jump at the start of 2011," The Christian Science Monitor,
March 18, 2011.) Sales of hardcover and paperback books, in
contrast, continue to fall. Amazon now reportedly sells more of
its electronic Kindle books than both paperback and hardcover
books, while Barnes & Noble recently reported that its e-book
outsold physical books on its website.
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As e-books have increased in popularity so have privacy concerns
associated with their use. A March 2010 report by the ACLU
described the privacy implications of e-books:
Digital book services have the ability to collect and
retain very detailed information about readers. The level
of detail that these services can collect would require an
offline library or bookstore to hire an agent to follow
each individual patron around the stacks, throughout their
day, and finally into their homes. Digital book providers
can easily track what books an individual considers, how
often a given book is read, how long a given page is
viewed, and even what notes are written in the "margins."
As reading has moved online, it also has become much easier
to link books that are browsed or read with a reader's
other online activities, such as Internet searches, emails,
cloud computing documents, and social networking. With all
of this information, companies can create profiles about
individuals, their interests and concerns, and even those
of their family and friends.
This tracking is already occurring. For example, Google
Books currently tracks: 1) a reader's initial search query;
2) the specific book browsed and page viewed; 3) the
date/time of the search or page view; 4) the reader's
Internet Protocol address, browser, and computer operating
system; and 5) one or more cookies that uniquely identify
the reader's browser. . . . Amazon can and does track
similar information on readers who use its Kindle. As each
Kindle is unique and automatically linked to one particular
account holder, the potential for tracking specific reading
habits may be even greater than with Google Books. Amazon
retains information about the books, magazine
subscriptions, newspapers and other digital content on the
Kindle and the reader's interaction with that content.
This includes an automatic bookmark of the last page read,
the content deleted from the device, and any annotations,
bookmarks, notes, highlights, or similar markups made by
the reader. The company's control over its users' reading
habits extends beyond merely tracking them. Amazon's
ability to control content on the Kindle has allowed it to
delete whole books without the account holder's knowledge
or consent. ("Digital Books: A New Chapter for Reader
Privacy," ACLU of Northern California, March 2010, p. 7,
available online at www.dotrights.org.)
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While much of this information may be of more interest to
commercial entities (with whom book service providers would be
free to share the information under this bill) than it is to the
government or private parties whose access to the information
would be restricted, it is apparent that these book service
providers compile significant amounts of highly personal and
sensitive information which may be deserving of protection
against inappropriate scrutiny.
Types of Information Subject to the Bill's Restrictions. Under
this bill, book providers may not knowingly disclose, or be
compelled to disclose, a user's "personal information related to
the use of a book or part of a book." The bill defines
"personal information" to mean any information described in
Civil Code Section 1798.80 and to specifically include a unique
identifier or Internet Protocol (IP) address when that
identifier or address is being used to identify, relate,
describe, or be associated with, a particular individual. The
definition also includes "any information associated with a
particular user's access or use of a book service or a book in
whole or partial form."
This Bill Appears To Be Consistent With Existing Privacy And
Free Speech Principles. Under this bill, a book services
provider may not knowingly disclose a user's personal
information to any government entity, or be compelled to
disclose to any person or entity, except as specified.
Expressive materials such as books and other reading materials
have long been protected under both state and federal law. The
First Amendment to the U.S. Constitution "protects more than
simply the right to speak freely," it includes also the right to
distribute and sell expressive materials and the right to
receive information and ideas. (Tattered Cover v. City of
Thornton (2002) 44 P. 3d 1044, 1051.) In United States v.
Rumely (1953) 345 U.S. 41, the U.S. Supreme Court held that it
was unconstitutional for the government to require a publisher
of political books to disclose the names of purchasers of his
books, stating, "Ýo]nce the government can demand of a publisher
the names of the purchasers of his publications, the free press
as we know it disappears. Then the spectre of a government
agent will look over the shoulder of everyone who reads. The
purchase of a book or pamphlet today may result in a subpoena
tomorrow. Fear of criticism goes with every person into the
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bookstall." (Id. at 57.)
More recently, a federal district court in Wisconsin ruled on a
motion to quash a grand jury subpoena that initially sought the
identities of thousands of Amazon customers who had purchased
books from the target of the grand jury's tax evasion
investigation. Amazon refused to identify any of its customers
to the government, arguing that they had a "First Amendment
right to maintain the privacy of their reading choices." (In re
Grand Jury Subpoena to Amazon.com (2007) 246 F.R.D. 570, 572.)
The court agreed, noting "it is an unsettling and un-American
scenario to envision federal agents nosing through the reading
lists of law-abiding citizens while hunting for evidence against
somebody else. . . . if word were to spread across the
Net-and it would-that the FBI and the IRS had demanded and
received Amazon's list of customers and their personal
purchases, the chilling effect on expressive e-commerce would
frost keyboards across America." (Id. at 573.)
As the author notes, California's Constitution contains
important privacy safeguards for expressive materials, providing
that all people have inalienable rights, including the right to
pursue and obtain privacy. (Cal. Const. art. I, sec. 1.) The
state Constitution also guarantees that "Ýe]very person may
freely speak, write and publish his or her sentiments on all
subjects, being responsible for the abuse of this right. A law
may not restrain or abridge liberty of speech or press." (Cal.
Const. art. I, sec. 2.)
As expressive materials move towards the digital age and e-books
increase in popularity, these privacy safeguards may be
challenged. As described in more detail below, many provisions
contained in this bill appear to be based on case law and
California's constitutional privacy protections, although
constitutional and other protections may be broader.
Prohibition Against Knowing Disclosure To Government Entities
Without Court Order, Subject to Exceptions. This bill would
generally prohibit a book provider from knowingly disclosing a
user's personal information to any government entity. The
intent of this provision is to restrict book providers from
disclosing a user's personal information simply upon the request
of law enforcement or other government entities without a court
order. With respect to criminal prosecutors, the court's
inquiry would include an assessment of probable cause and
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grounds for a search warrant (although not a warrant itself),
compelling interest, no less intrusive means, notice and an
opportunity for the provider to appear and contest the request,
and notice to the user (unless there is good reason to delay
that notice). For governmental entities other than criminal
prosecutors, there would be no requirement of probable cause.
Notwithstanding these general rules, a provider may disclose a
user's personal information to a government entity, if the
government entity asserts, and the provider in good faith
believes, that there is an imminent danger of death or serious
physical injury requiring the immediate disclosure of the
requested personal information and there is insufficient time to
obtain a court order. The government entity seeking the
disclosure shall provide the provider with a written statement
setting forth the facts giving rise to the emergency upon
request or no later than 48 hours after seeking disclosure. In
addition, a provider may disclose personal information of a user
to a government entity if the provider in good faith believes
that the personal information is evidence directly related and
relevant to a crime against the provider or that user.
The bill also permits the disclosure of personal information
about a book service user to the government - or to any private
person - with the informed, affirmative consent of that user.
This Bill Also Does Not Limit Government Access to Reader
Information From Sources Other Than a Book Provider. The
prohibition against knowing disclosure of reader information to
the government without a court order applies only to providers
of book services. Under the bill, a provider is defined as a
commercial entity offering a book service to the public. "Book
service" is defined to mean a service that, as its primary
purpose, provides the rental, purchase, borrowing, browsing, or
viewing of books. Thus, entities that do not fall within these
definitions are not subject to the bill's requirement that a
court order be obtained.
Protection for Book Providers Against Compelled Disclosure By
Private and Government Entities Absent Court Approval. The bill
also provides guidelines to courts when private parties seek to
compel book providers to release user information in a pending
court proceeding. Recognizing the governmental entities may
also be parties in these proceedings, the restrictions on
compelled disclosure apply to government entities as well. With
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respect to efforts to compel the release of book user
information, the bill adopts the same standards as the "civil"
provision described above: compelling interest, no less
intrusive means, notice and an opportunity for the provider to
appear and contest the request, and notice to the user. As
above, no court order would be required to disclose information
to a government entity where there is an imminent danger of
death or serious physical injury requiring the immediate
disclosure of the requested personal information and
insufficient time to obtain a court order, or where the provider
in good faith believes that the personal information is evidence
directly related and relevant to a crime against the provider or
that user.
This Bill Does Not Limit The Ability Of Book Providers To
Voluntarily Share A Consumer Or Other User's Personal
Information With Private Entities For Commercial Or Other
Purposes. The bill's prohibition against knowing disclosure to
the government does not apply to any private person or entity.
As a result, the bill would not restrict book providers to
knowingly disclose a user's personal information to any other
person or entity, including, potentially, third party marketers.
To the extent the entities that receive this information are
not themselves book providers, they are not subject to the
bill's requirements, although other privacy laws may govern
their receipt, use, or disclosure of this information.
Penalty Provisions And Defense for Reasonable Reliance. This
bill would make it a violation of law for a provider to
knowingly provide a book user's personal information to a
government entity, subject to a civil penalty of up to $500 for
each violation, which may be recovered in a civil action brought
by the book user. In addition, a book service provider who
knowingly provides a user's personal information to a government
entity in violation of the bill would also be subject to a civil
penalty of up to $500 for each violation which may be assessed
and recovered in a civil action brought by the Attorney General,
any district attorney, city attorney, or specified city
prosecutor.
The bill provides that an objectively reasonable reliance by a
book service provider on an order for the release of a user's
personal information, or on any of the bill's exceptions to
confidentiality, is a complete defense to any civil,
administrative, or criminal action.
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Concerns of District Attorneys Association. The California
District Attorneys Association opposes the bill in its last
amended version. The CDAA argues first that the federal Privacy
Protection Act prohibits certain searches that are not
prohibited by the bill. CDAA explains:
Our opposition to this bill stems mainly from the fact that
it potentially conflicts with and/or exceeds the
requirements of existing federal law. The Personal Privacy
Act (42 USC 2000aa et seq.) prohibits the use of search
warrants to gather information from newsrooms and
disseminators of books and other publications. Previous
iterations of SB 602 clashed with federal law because it
purported to authorize search warrants for commercial
providers of book services, albeit subject to strenuous
conditions.
To respond to this concern the author's proposed amendments
state explicitly that nothing in the act conflicts with the
federal Privacy Protection Act, 42 USC 2000aa.
The other concern of the CDAA is with respect to certain types
of criminal matters that are exempted from the prohibitions of
the Privacy Protection Act. CDAA states:
And though federal law generally precludes the use of
search warrants when seeking information from the press and
book distributors, it wisely includes exceptions from this
prohibition in situations involving child pornography,
sexual exploitation of children, and the sale of children.
SB 602 contains no similar exceptions for the burdensome
processes it contemplates. It should pose no difficulty for
a publisher of pornography to present his wares in a manner
meeting the definition of "book" used in SB 602. The
government would have difficulty obtaining such materials
without jumping through all the hoops included in the bill,
including giving a suspect an opportunity for notice and a
hearing before we seize the evidence.
In response to this concern, the author's proposed amendments
clarify that the bill matches the exemptions in federal law by
stating expressly that it does not make it unlawful for a law
enforcement entity subject to 42 U.S.C. section 2000aa to obtain
a search warrant for a user's personal information with regard
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to the specified offenses.
CDAA also expressed concern that the provision of the bill
relating to the admissibility of evidence conflicted with
existing law regarding criminal prosecutions. Specifically,
CDAA states:
Finally, federal statute provides that evidence seized in
violation of the statute may still be admissible in a
criminal prosecution, apparently out of deference to the
U.S. Supreme Court as the final arbiter of when evidence
should be suppressed. SB 602 takes the opposite approach
and makes inadmissible evidence obtained in violation of
its terms. The California Constitution's truth-in-evidence
provision added by Proposition 8 from 1982 prevents SB
602's rule from having any effect and it should therefore
be removed.
This issue has also been addressed in the author's proposed
amendments.
Author's Narrowing And Clarifying Amendments. In response to
concerns expressed by opponents and to otherwise narrow and
clarify the bill, the author prudently proposes to amend the
bill as reflected in the attached mockup.
REGISTERED SUPPORT / OPPOSITION :
Support
American Civil Liberties Union (co-sponsor)
Electronic Frontier Foundation (co-sponsor)
Alibris
Californians Aware
California Library Association
Center for Democracy and Technology
Consumer Federation of California
GoodReads
Google, Inc.
Monsoon Commerce Solutions
Privacy Activism
Privacy Rights Clearinghouse
one individual
Opposition (prior to proposed amendments)
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California Correctional Supervisors Organization
California District Attorneys Association
Analysis Prepared by : Kevin G. Baker / JUD. / (916) 319-2334