BILL ANALYSIS                                                                                                                                                                                                    �




           


                      SENATE COMMITTEE ON PUBLIC SAFETY
                            Senator Loni Hancock, Chair              S
                             2013-2014 Regular Session               B

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          SB 710 (Nielsen)                                            
          As Introduced: February 22, 2013
          Hearing date:  April 23, 2013
          Penal Code
          JM:jr

                         CRIMINAL JUSTICE REALIGNMENT - PAROLE
                                           

                                       HISTORY

          Source:  Author

          Prior Legislation: AB 109 (Committee on Budget) Ch. 15, Stats.  
          2011
                       AB 117 (Committee on Budget) Ch. 39, Stats. 2011


          Support: Crime Victims United of California; Golden State Bail  
          Agents Association

          Opposition:California Attorneys for Criminal Justice



                                        KEY ISSUES
           
          SHOULD EVERY PERSON RELEASED FROM STATE PRISON BE PLACED ON PAROLE  
          UNDER THE SUPERVISION OF STATE PAROLE AGENTS?

          SHOULD THE DEPARTMENT OF CORRECTIONS AND REHABILITATION OPEN AND  
          OPERATE ADJUSTMENT AND REHABILITATION CENTERS FOR PAROLE VIOLATORS?





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                                       PURPOSE

          The purposes of this bill are to 1) provide that all inmates  
          released from state prison shall be placed on parole under the  
          supervision of state parole officers; 2) require the Department  
          of Corrections and Rehabilitation (CDCR) to open at least three  
          "adjustment and rehabilitation centers"; 3) provide that parole  
          violators shall serve an additional year on parole; 4) provide  
          that a  parolee shall not be discharged from parole without  
          completing 12 consecutive months without a parole violation or  
          being arrested on a new charge; 5) provide that parole violators  
          shall be "sentenced" by the Board of Parole Hearings (board) to  
          serve up to a year in adjustment center; 6) provide that a  
          specified drug-related violation of parole "shall be served on  
          nonrevoked status" if the parolee agrees to treatment in a  
          readjustment center for at least six months and then enters  
          residential treatment in the community; and 7) provide that CDCR  
          shall develop an individual parole plan for each parolee.
          
          Postrelease Community Supervision

           Existing law  provides, that certain persons released from prison  
          after serving a determinate sentence for a non-excluded felony  
          are subject to postrelease community supervision (PRCS). PRCS  
          shall be provided by a county agency designated by the board of  
          supervisors and shall be consistent with evidence-based  
          practices. (Pen. Code � 3451, subd. (a).)

           Existing law  provides that any inmate pending release who is in  
          one of the following categories   may not be placed on  
          postrelease community supervision:

               An inmate imprisoned for serious or violent felony.
               An inmate sentenced to a life term under the Three Strikes  
              law.




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               An inmate classified as a high-risk sex offender.
               A mentally disordered offender.  (Pen. Code � 3451, subd.  
              (b).)
            
          Existing law  provides that PRCS shall not extend beyond three  
          years from the date of the person's initial entry onto PRCS,  
          except where the period is tolled, as specified. PRCS is  
          required to be 'implemented by a county agency according to a  
          strategy designated by each county's board of supervisors.'   
          (Pen. Code �� 3451, subd. (c)(1) and 3455.)

           Existing law  sets out mandatory conditions of release to PRCS  
          including, among others, the following:

                 The defendant shall report to the supervising agency  
               within two days of release and as directed thereafter.
                 The defendant shall follow the directives of the agency.
                 The defendant shall report to the agency during the  
               supervision period as directed.
                 The defendant shall inform the agency of his or her  
               place of residence, employment, education or training.
                 The defendant shall be subject to search and seizure  
               without a warrant.
                 The defendant shall report to the agency any anticipated  
               changes in residence, employment, education or training.
                 The defendant shall obtain prior approval before  
               traveling more than 50 miles from his or her residence and  
               shall obtain a travel pass to leave the state or country  
               for more than two days.
                 The defendant shall immediately inform the agency if he  
               or she is arrested or receives a citation for any offense.
                 The defendant shall not be in the presence of a firearm  
               or ammunition.  (Penal Code � 3453.)

           Existing law  provides for "intermediate" and "appropriate"  
          sanctions for violations of the terms of PRCS before PRCS is  
          revoked.  The sanctions include 'flash incarceration' for up to  
          10 days.  (Pen. Code � 3454.)
           
          Existing law  requires CDCR to inform inmates subject to PRCS of  




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          the inmate's responsibility to report to the county agency that  
          will supervise the inmate.  CDCR shall also notify the county of  
          all information otherwise required for parolees, as specified,  
          thirty days prior to the inmate's release, as specified.  (Pen.  
          Code �� 3003, subd. (e) and 3451, subd. (c)(2).)  
           
           Existing law  provides that where a prison inmate is released on  
          PRCS, CDCR shall release the inmate to the county of last legal  
          residence prior to incarceration, unless it is in the best  
          interest of the public to release the person to another county.   
          (Pen. Code � 3003, subd. (a).)
           
          Parole
          
          Existing law  generally provides for a period of post-prison  
          supervision immediately following a period of incarceration in  
          state prison.  (Penal Code � 3000 et seq.)  

           Existing law  includes indeterminate sentencing schemes under  
          which a defendant is committed to prison for life and is  
          eligible for parole after a specified number of years, including  
          any determinate term.  If no other minimum term is specified,  
          the minimum term is seven years.  (Pen. Code �� 1168 and 3046)
           
          Current law  generally provides that persons released from state  
          prison on or after October 1, 2011, for any of the following  
          crimes are subject to parole supervision by the Department of  
          Corrections and Rehabilitation (CDCR): 

                 A serious felony as described in subdivision (c) of  
               Section 1192.7.
                 A violent felony as described in subdivision (c) of  
               Section 667.5.
                 A crime for which the person has been sentenced to a  
               life term under the 3-strikes law.
                 Any crime where the person eligible for release from  
               prison is classified as a HighRisk Sex Offender.
                 Any crime where the person is required, as a condition  
               of parole, to undergo treatment by the Department of Mental  
               Health as a mentally ill offender.




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                 Any felony committed while the person was on parole for  
               a period exceeding three years where the person was  
               required to register as a sex offender or was subject to  
               parole for life, as specified.  (Pen. Code � 3000.08; see  
               also Penal Code � 3451, subd. (b).)

           Existing law  authorizes parole officials to "impose additional  
          and appropriate conditions of supervision," upon a finding of  
          good cause that the parolee has committed a violation of law or  
          violated his or her conditions of parole; those may include  
          "rehabilitation and treatment services and appropriate  
          incentives for compliance, and impose immediate, structured, and  
          intermediate sanctions for parole violations, including flash  
          [short term] incarceration in a county jail. . . .     (Penal  
          Code � 3000.08, subd. (d).)

           Existing law  provides that the parole agent or peace officer may  
          bring a parolee before the court for a violation of the  
          conditions of parole.  If the court finds that the parolee has  
          violated a condition of parole, the court may impose any of the  
          following sanctions for parole violations, as specified:

                 Return the person to parole supervision with  
               modifications of conditions, if appropriate, including a  
               period of incarceration in county jail.
                 Revoke parole and order the person to confinement in the  
               county jail.
                 Refer the person to a reentry court pursuant to Section  
               3015 or other evidence-based program in the court's  
               discretion.
                 Confinement shall not exceed a period of 180 days in the  
               county jail.  (Penal Code � 3000.08, subd. (f).)
           
          This bill  provides that every person released from state prison  
          shall be placed on parole for at least three years and  
          supervised by the Department of Corrections and Rehabilitation  
          (CDCR) and the Board of Parole Hearings.

           This bill  provides that no person shall be released from parole  
          until he or she has completed "12 consecutive months of  




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          supervision without a parole violation or arrest on new criminal  
          charges."

           This bill  authorizes an additional year of parole for parole  
          violators. 

           This bill requires CDCR to establish at least three parole  
          violator "adjustment and rehabilitation facilities."

           This bill  requires that parole violators be confined for up to  
          one year in such a facility. 

           This bill  provides that a parolee who commits a drug related  
          parole violations must serve a term of at least 6 months in an  
          adjustment and rehabilitation facility; requires that parolee  
          who commits any other parole violation shall have his or her  
          parole revoked and serve the rest of his or her term in the  
          facility.

           This bill  requires CDCR to develop a treatment and programming  
          plan for each parole violator.

                    RECEIVERSHIP/OVERCROWDING CRISIS AGGRAVATION

          For the last several years, severe overcrowding in California's  
          prisons has been the focus of evolving and expensive litigation  
          relating to conditions of confinement.  On May 23, 2011, the  
          United States Supreme Court ordered California to reduce its  
          prison population to 137.5 percent of design capacity within two  
          years from the date of its ruling, subject to the right of the  
          state to seek modifications in appropriate circumstances.   

          Beginning in early 2007, Senate leadership initiated a policy to  
          hold legislative proposals which could further aggravate the  
          prison overcrowding crisis through new or expanded felony  
          prosecutions.  Under the resulting policy known as "ROCA" (which  
          stands for "Receivership/ Overcrowding Crisis Aggravation"), the  
          Committee held measures which created a new felony, expanded the  
          scope or penalty of an existing felony, or otherwise increased  
          the application of a felony in a manner which could exacerbate  




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          the prison overcrowding crisis.  Under these principles, ROCA  
          was applied as a content-neutral, provisional measure necessary  
          to ensure that the Legislature did not erode progress towards  
          reducing prison overcrowding by passing legislation which would  
          increase the prison population.  ROCA necessitated many hard and  
          difficult decisions for the Committee.

          In January of 2013, just over a year after the enactment of the  
          historic Public Safety Realignment Act of 2011, the State of  
          California filed court documents seeking to vacate or modify the  
          federal court order issued by the Three-Judge Court three years  
          earlier to reduce the state's prison population to 137.5 percent  
          of design capacity.  The State submitted in part that the, ". .  
          .  population in the State's 33 prisons has been reduced by over  
          24,000 inmates since October 2011 when public safety realignment  
          went into effect, by more than 36,000 inmates compared to the  
          2008 population . . . , and by nearly 42,000 inmates since 2006  
          . . . ."  Plaintiffs, who opposed the state's motion, argue in  
          part that, "California prisons, which currently average 150% of  
          capacity, and reach as high as 185% of capacity at one prison,  
          continue to deliver health care that is constitutionally  
          deficient."  In an order dated January 29, 2013, the federal  
          court granted the state a six-month extension to achieve the  
          137.5 % prisoner population cap by December 31st of this year.  

          In an order dated April 11, 2013, the Three-Judge Court denied  
          the state's motions, and ordered the state of California to  
          "immediately take all steps necessary to comply with this  
          Court's . . . Order . . . requiring defendants to reduce overall  
          prison population to 137.5% design capacity by December 31,  
          2013."         

          The ongoing litigation indicates that prison capacity and  
          related issues concerning conditions of confinement remain  
          unresolved.  However, in light of the real gains in reducing the  
          prison population that have been made, although even greater  
          reductions are required by the court, the Committee will review  
          each ROCA bill with more flexible consideration.  The following  
          questions will inform this consideration:





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                 whether a measure erodes realignment;
                 whether a measure addresses a crime which is directly  
               dangerous to the physical safety of others for which there  
               is no other reasonably appropriate sanction; 
                 whether a bill corrects a constitutional infirmity or  
               legislative drafting error; 
                 whether a measure proposes penalties which are  
               proportionate, and cannot be achieved through any other  
               reasonably appropriate remedy; and
                 whether a bill addresses a major area of public safety  
               or criminal activity for which there is no other  
               reasonable, appropriate remedy.

                                      COMMENTS

          1.  Need for this Bill 

          According to the author:

               SB 710 requires the Board of Parole Hearings to have  
               exclusive jurisdiction over the supervision and  
               revocation of parole of all inmates upon their release  
               from prison, thereby repealing the scheduled transfer  
               of that authority to the courts on July 1, 2013. The  
               bill provides that no person may be discharged from  
               parole while incarcerated or if his or her whereabouts  
               are unknown. Additionally, 
               SB 710 would make the provisions of postrelease  
               community supervision applicable only to persons  
               released from prison prior to January 1, 2014.  It  
               would require the department of Corrections and  
               Rehabilitation to develop a minimum of three parole  
               violator adjustment and rehabilitation facilities;  
               and, parolees who violate the conditions of parole  
               shall be sentenced to up to one year in one facility.
               Finally, the bill would allow the board sufficient  
               autonomy to protect the rights of crime victims.

          2.   Unlimited Extensions of Parole  





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          Indefinite Parole Generally
          
          This bill provides that where a parolee violates a condition of  
          parole, an additional year of parole can be added to his or her  
          parole period.  The bill also provides that no person may be  
          discharged from parole unless he or she has completed 12  
          consecutive months of parole without a parole violation or  
          arrest for a new charge.<1>

          This bill thus arguably creates the equivalent of a life  
          sentence through unlimited extensions of parole.   The  
          California Supreme Court has described the differences between  
          parole for a determinate sentence and parole for a life term:   
          "As we have pointed out, under the current [determinate]  
          sentencing scheme the parole release date marks the end of the  
          prison term."  The parole period for a determinate term prison  
          sentence constitutes a separate, determinate term.  (People v.  
          Jefferson (1999) 21 Cal.4th 86, 93, 95, emphasis added.)  Under  
          the indeterminate sentencing law, the period of parole is "part  
          of a defendant's prison term . . ."  The inmate remains in the  
          constructive custody of the Department of Corrections throughout  
          the entire period of parole, including his or her life for a  
          life sentence.  (Id, at pp. 93 and 95.) 

          That is, a person who does not complete 12 continuous months  
          without a parole violation or arrest for a new crime can remain  
          on parole for life.  He or she can also be returned to custody  
          for up to one year at a time for any violation of parole.

          The Prohibition on Ex-Post Facto Criminal Penalties would  
          Require this Bill to Apply Prospectively only
          ---------------------------
          <1> The bill creates an exception to the limits on parole terms  
          specified in Penal Code Section 3000 (b)(6). Section 3000,  
          subdivision (b))6) provides that a person subject to a three  
          years of parole shall be held in custody or on parole  
          supervision for a period no longer than four years.  The maximum  
          period of custody or parole supervision is seven years for a  
          person subject to five-year parole term and 15 years for a  
          person subject to a 10-year parole term. 




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          A law that changes the punishment for a crime after the crime  
          has been committed is a constitutionally prohibited ex-post  
          facto law.  (U.S. Const., Art. I, � 9, 10; Cal. Const., Art. I,  
          � 9; In re Arafiles (1992) 6 Cal.App.4th 1467, 1481-1482.)  The  
          parole period is a part of a defendant's punishment.  A change  
          in the length of a parole period of a change in the basic nature  
          of parole is an ex-post facto law if it applies to crimes  
          committed before the change in the law. (In re Arafiles, supra,  
          at pp. 1481-1487.)  Thus, this bill can only apply to defendants  
          sentenced for determinate terms for crimes committed after the  
          effective date of the bill.

          DOES THIS BILL EFFECTIVELY CREATE A FORM OF INDEFINITE PAROLE  
          FOR ANY PAROLEE WHO DOES NOT COMPLETE ONE CONTINUOUS YEAR OF  
          PAROLE WITHOUT A VIOLATION OR ARREST FOR A NEW CRIME?

          3.  This Bill may be in Conflict with the Substance Abuse and  
            Crime Prevention Act of 2000  

          The Substance Abuse Treatment and Crime Prevention Act of  
          2000<2> (SACPA), provides that parole shall not be suspended or  
          revoked if the parolee commits a "non-violent drug possession  
          offense" or violates a "drug-related" condition of parole.   
          Such a parolee must be offered treatment in the community  
          without return to custody.  (Pen. Code � 3063.1, subd. (a) and  
          (c).)  

          This bill requires that any parolee who commits a drug related  
          violation of probation shall serve a term of at least six month  
          in an "adjustment and rehabilitation" facility.  The term can be  
          served on "nonrevoked status" if the parolee agrees to submit to  
          drug treatment. This bill thus appears to conflict with SACPA.   
          SACPA is an initiative measure that can only be amended by a 2/3  
          vote of the Legislature or another initiative submitted to the  
          voters.  SACPA also provides 
          that all amendments to the act must further its purpose.   
          (Gardener v. Schwarzenegger (2009) 178 Cal.App.4th 1366, 1370.) 



          ---------------------------
          <2> Prop. 36 of the November 2000 General Election



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          DOES THIS BILL CONFLICT WITH THE SUBSTANCE ABUSE AND CRIME  
          PREVENTION ACT OF 2,000 BY REQUIRING THAT PAROLEES WHO COMMIT A  
          DRUG RELATED VIOLATION OF PAROLE BE PLACED IN CUSTODY FOR AT  
          LEAST SIX MONTHS?

          3.  This Bill Authorizes the Board of Parole Hearings to  
            "Sentence" a Parole Violator to a term in Custody  

          This bill provides that "parolees who violate the conditions of  
          parole shall be sentenced up to one year in a parole adjustment  
          and rehabilitation facility."  If this bill is interpreted to  
          mean that the Board of Parole Hearings may revoke a person's  
          parole and return him or her to custody pursuant to the sentence  
          imposed by the court, this provision was likely found to simply,  
          but in-artfully describe a proper function of the board.

          However, if the bill actually allows the board to impose some  
          sort of sentence, the bill is likely unconstitutional.  Judges  
          alone have the power to sentence.  (People v. Tenorio (1970) 3  
          Cal.3d 89, 90-93; People v. Navarro (1972) 7 Cal.3d 248, 258;  
          People v. Superior Court (Fellman) (1976) 59 Cal.App.3d 270,  
          275.)  A discretionary power to impose a penalty for an offense,  
                 where that penalty was not part of the original sentence, cannot  
          be exercised by the board.  

          DOES THIS BILL GRANT A JUDICIAL POWER TO THE BOARD TO IMPOSE A  
          "SENTENCE" ON A PAROLEE FOR A VIOLATION OF A CONDITION OF  
          PAROLE?

          4.   Parole Population; Parole and Probation Supervision Issues 

           This bill eliminates post release supervision and reinstates the  
          parole system.  The bill appears to essentially create an  
          indefinite parole period for any parole or parolee who does not  
          avoid a parole violation of arrest for a new offense within a  
          period of 12 consecutive months   This bill requires CDCR to  
          open new parole revocation facilities and authorizes the parole  
          board to impose 'sentences" of up to one year, with minimum  
          terms for specified violations.





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          This bill would thus substantially change the provisions of  
          realignment applicable to released felony offenders.  These  
          changes would have significant costs and affect the pending  
          prison receivership matters.  The bill squarely presents issues  
          of the benefits and efficacy of parole supervision in contrast  
          with supervision by county probation officers.





          In its analysis of the Governor's proposed 2013-14 budget the  
          Legislative Analyst's Office states in part:

               The average daily parole population is projected to be  
               about 43,000 parolees in the budget year, a decline of  
               about 15,000 parolees (25 percent) from the 

               estimated current-year level.  This decline is also  
               largely a result of the 2011 realignment, which  
               shifted from the state to the counties the  
               responsibility for supervising certain offenders  
               following their release from prison.  The average  
               daily population projected for 2013-14 is about 4,500  
               parolees lower than was initially projected by the  
               department in spring 2012.  According to CDCR, this is  
               due to more parolees being discharged from supervision  
               than expected in the first six months of 2012.  In  
               addition, CDCR projections show that the decline in  
               the parole population is expected to slow down and  
               even increase in coming years. 

               . . . The current-year net reduction in costs is  
               primarily due to savings from the larger than expected  
               decline in the 2012-13 parolee population . . .<3>

          In its 2013 "primer" on California's criminal justice system,  
          LAO noted in part:

          ---------------------------
          <3>  The Legislative Analyst's Office, The 2013-14 Budget:  
          Governor's Criminal Justice Proposals.



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                 In 2010, the probation "failure" rate-measured as  
               the percent of the probation population that committed  
               violations resulting in incarceration or absconded  
               from supervision-in California was somewhat lower than  
               in other states.  California parolees, on the other  
               hand, failed at a much higher rate than parolees in  
               other states.

                 Some differences among states are likely due to  
               factors such as policy differences regarding who goes  
               onto probation and parole, the amount of supervision  
               provided, revocation decisions, and the availability  
               of treatment services.

          One Goal of Realignment Was a More Cost-Effective  
          Correctional System.  

          As described above, the state enacted several bills in 2011  
          to realign to county governments the responsibility for  
          managing and supervising certain lower level offenders.  In  
          adopting this realignment, the Legislature had multiple  
          goals, including





















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          reducing the prison population to meet a federal  
          court-ordered cap (in a case related to inmate health care  
          discussed in more detail below) and to reduce state  
          correctional costs.  Another stated goal of realignment was  
          to improve public safety outcomes by keeping lower-level  
          offenders in local communities where treatment services  
          exist and where local criminal justice agencies can  
          coordinate efforts to ensure that offenders get the  
          appropriate combination of incarceration, community  
          supervision, and treatment.  The expectation was that  
          counties would be more effective and efficient than the  
          state at managing these offenders and could reduce the high  
          recidivism rates experienced by state parolees.<4>

          Ten years ago, the Little Hoover Commission called California's  
          parole system "a billion dollar failure."<5>   In its Winter  
          2012 issue brief, the Chief Probation Officers of California  
          stated in part:
               Probation has reduced caseload sizes of high risk  
               offenders to ensure proper levels of supervision by  
               officers; implemented tools for assessing risks and  
               needs; and trained officers in techniques proven to  
               increase chances of successful supervision, and reduce  
               recidivism.  These investments have led to probation's  
               demonstrated success in supervising California's  
               felony offenders.  California Probation Departments  
               have made a commitment to the use of evidence based  
               practices to match offender's actual needs with  
               appropriate services and structure supervision around  
               an offenders risk to reoffend.  These improvements and  
               techniques should also be successful with the new  
               realigned populations, but the entire justice system  
               must be addressed in order to make the system  


               ----------------------
          <4>   Legislative Analyst's Office, California's Criminal  
          Justice System: A Primer (Jan. 2013).
          <5>   Little Hoover Commission, Back to the Community: Safe and  
          Sound Parole Policies (Nov. 2003).






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               successful and our communities safer.<6>

          Members may wish to discuss whether this bill is premised on the  
          assumption that parole supervision is more effective than  
          probation supervision and, if so, if that assumption is correct.

          WOULD THE PAROLE SUPERVISION REQUIRED BY THIS BILL BE MORE  
          EFFECTIVE THAN PROBATION SUPERVISION?  

          IS PAROLE "BETTER" THAN PROBATION IN TERMS OF ACHIEVING PUBLIC  
          SAFETY OUTCOMES FROM AN OFFENDER POPULATION SUPERVISED IN THE  
          COMMUNITY?

          5.  Realignment Funding Shift    

          As part of realignment, the state shifted certain revenues to  
          local governments.  As explained by the LAO:

               . . .  (T)he 2011-12 budget package included statutory  
               changes to realign several criminal justice and other  
               programs from state responsibility to local  
               governments, primarily counties.  Along with the  
               shift-or realignment-of programs, state law realigned  
               revenues to locals.  Specifically, current law shifts  
               a share of the state sales tax, as well as Vehicle  
               License Fee revenue, to local governments.  The  
               passage of Proposition 30 by voters in November 2012,  
               among other changes, guaranteed these revenues to  
               local governments in the future.  The Governor's  
               budget includes an estimate of revenues projected to  
               go to local governments over the next few years.   
               These estimates are generally in line with prior  
               estimates. . . . (T)otal funding for the criminal  
               justice programs realigned is expected to increase  
               from $1.4 billion in 2011-12 to $2.2 billion in  
               2013-14.<7>

          ---------------------------
          <6>   Chief Probation Officers of California, Mandatory  
          Supervision: The Benefits of Evidence Based Supervision
               under Public Safety Realignment (Winter 2012.)
          <7>   Id.











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          This bill does not make any changes to the funding realigned  
          pursuant to realignment and guaranteed to local governments by  
          Proposition 30.  Members may wish to discuss the fiscal  
          implications of this bill, including: 
           
                 What are the implications of this bill with respect to  
               the fiscal guarantees assured in Proposition 30, passed  
               last November?
                 What are the implications of this bill with respect to  
               the state's General Fund?

          IF OFFENDERS ARE SHIFTED FROM COUNTY PROBATION SUPERVISION TO  
          STATE SUPERVISION, WOULD THE STATE ESSENTIALLY "PAY TWICE" FOR  
          THE SUPERVISION OF THESE OFFENDERS?

          IS PROBATION LIMITED IN SOME COUNTIES BECAUSE OF THE  
          DISTRIBUTION OF REALIGNMENT FUNDING?  IF SO, IS THAT CONCERN  
          BEST ADDRESSED BY SHIFTING SOME OF PROBATION'S "PRCS" POPULATION  
          BACK TO THE STATE?

          WOULD THIS BILL ERODE REALIGNMENT?
           
          
          
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