BILL ANALYSIS Ó
AB 262
Page A
Date of Hearing: April 21, 2015
Chief Counsel: Gregory Pagan
ASSEMBLY COMMITTEE ON PUBLIC SAFETY
Bill Quirk, Chair
AB
262 (Lackey) - As Amended March 26, 2015
SUMMARY: Places additional residency restrictions on Sexually
Violent Predators (SVP's) conditionally released for community
outpatient treatment. Specifically, this bill:
1)Provides that a person adjudicated as an SVP shall only reside
in a dwelling or abode within 10 miles of a permanent physical
police or sheriff station that has jurisdiction over the
location and has 24 hour a day peace officer staffing on duty
and available to respond to call for service.
2)States that a person adjudicated as an SVP shall not lease,
rent, or otherwise reside in any dwelling or other abode, nor
shall a dwelling or other abode be leased or rented on behalf
of an SVP for purposes of residence by that person, if that
dwelling or a bode is occupied or owned in whole or in part by
a felon convicted of a "violent" or "serious" felony, as
specified.
3)Provides that the provisions of this measure are severable.
If any provision of this measure or its application is held
invalid, that invalidity shall not affect other provisions or
AB 262
Page B
applications that can be given effect without the invalid
provision or application.
EXISTING LAW:
1)Provides that n1)otwithstanding any other provision of law,
when a person is released on parole after having served a term
of imprisonment in state prison for any offense for which sex
offender registration is required, that person may not during
the period of parole, reside in any single family dwelling
with any other person also required to register as a convicted
sex offender, unless those persons are legally related by
blood. "Single family dwelling" shall not include a
residential facility that serves six or fewer persons. (Pen.
Code, § 3003.5, subd. (a).)
2)States notwithstanding any other provision of law, it is
unlawful for any person for whom sex offender registration is
required to reside within 2,000 feet of any public or private
school, or park where children regularly gather. (Pen. Code,
§ 3003.5, subd. (b).)
3)Provides for the civil commitment for psychiatric and
psychological treatment of a prison inmate found to be a SVP
after the person has served his or her prison commitment.
(Welf. & Inst. Code, § 6600, et seq.)
4)Defines a "sexually violent predator" as "a person who has
been convicted of a sexually violent offense against at least
one victim, and who has a diagnosed mental disorder that makes
the person a danger to the health and safety of others in that
it is likely that he or she will engage in sexually violent
criminal behavior." (Welf. & Inst. Code, § 6600, subd.
(a)(1).)
AB 262
Page C
5)Permits a person committed as a SVP to be held for an
indeterminate term upon commitment. (Welf. & Inst. Code, §
6604.1.)
6)Requires that a person found to have been a SVP and committed
to the Department of State Hospitals (DSH) have a current
examination on his or her mental condition made at least
yearly. The report shall include consideration of conditional
release to a less restrictive alternative or an unconditional
release is in the best interest of the person and also what
conditions can be imposed to adequately protect the community.
(Welf. & Inst. Code, § 6604.9.)
7)Allows a SVP to seek conditional release with the
authorization of the Director DSH when DSH determines that the
person's condition has so changed that he or she no longer
meets the SVP criteria, or when conditional release is in the
person's best interest and conditions to adequately protect
the public can be imposed. (Welf. & Inst. Code, § 6607.)
8)Allows a person committed as a SVP to petition for conditional
release or an unconditional discharge any time after one year
of commitment, notwithstanding the lack of recommendation or
concurrence by the Director of DSH. (Welf. & Inst. Code, §
6608, subd. (a).)
9)Provides that, if the court deems the conditional release
petition not frivolous, the court is to give notice of the
hearing date to the attorney designated to represent the
county of commitment, the retained or appointed attorney for
the committed person, and the Director of State Hospitals at
least 30 court days before the hearing date. (Welf. & Inst.
Code, § 6608, subd. (b).)
10)Requires the court to first obtain the written recommendation
of the director of the treatment facility before taking any
action on the petition for conditional release if the is made
without the consent of the director of the treatment facility.
(Welf. & Inst. Code, § 6608, subd. (c).)
AB 262
Page D
11)Provides that the court shall hold a hearing to determine
whether the person committed would be a danger to the health
and safety of others in that it is likely that he or she will
engage in sexually violent criminal behavior due to his or her
diagnosed mental disorder if under supervision and treatment
in the community. Provides that the attorney designated the
county of commitment shall represent the state and have the
committed person evaluated by experts chosen by the state and
that the committed person shall have the right to the
appointment of experts, if he or she so requests. (Welf. &
Inst. Code, § 6608, subd. (e).)
12)Requires the court to order the committed person placed with
an appropriate forensic conditional release program operated
by the state for one year if the court at the hearing
determines that the committed person would not be a danger to
others due to his or her diagnosed mental disorder while under
supervision and treatment in the community. Requires a
substantial portion of the state-operated forensic conditional
release program to include outpatient supervision and
treatment. Provides that the court retains jurisdiction of the
person throughout the course of the program. (Welf. & Inst.
Code, § 6608, subd. (e).)
13)Provides that if the court denies the petition to place the
person in an appropriate forensic conditional release program,
the person may not file a new application until one year has
elapsed from the date of the denial. (Welf. & Inst. Code, §
6608, subd. (h)
14)Allows, after a minimum of one year on conditional release,
the committed person, with or without the recommendation or
concurrence of the Director of State Hospitals, to petition
the court for unconditional discharge, as specified. (Welf. &
Inst. Code, § 6608, subd. (k).)
FISCAL EFFECT: Unknown
AB 262
Page E
COMMENTS:
1)Author's Statement: According to the author, "AB 262
restricts sexually violent predators (SVPs) from residing in
rural areas, which are more than 10 miles away from a
full-time police station. It also stops SVPs from renting from
landlords who are registered sex offenders or living with
another sex offender.
2)SVP Law Generally: The Sexually Violent Predator Act (SVPA)
establishes an extended civil commitment scheme for sex
offenders who are about to be released from prison, but are
referred to the DSH for treatment in a state hospital, because
they have suffered from a mental illness which causes them to
be a danger to the safety of others.
The Department of State Hospitals uses specified criteria to
determine whether an individual qualifies for treatment as a
SVP. Under existing law, a person may be deemed a SVP if:
(a) the defendant has committed specified sex offenses against
two or more victims; (b) the defendant has a diagnosable
mental disorder that makes the person a danger to the health
and safety of others in that it is likely that he or she will
engage in sexually-violent criminal behavior; and, (c) two
licensed psychiatrists or psychologists concur in the
diagnosis. If both clinical evaluators find that the person
meets the criteria, the case is referred to the county
district attorney who may file a petition for civil
commitment.
Once a petition has been filed, a judge holds a probable cause
hearing; and if probable cause if found, the case proceeds to
a trial at which the prosecutor must prove to a jury beyond a
reasonable doubt that the offender meets the statutory
criteria. The state must prove "[1] a person who has been
convicted of a sexually violent offense against [at least one]
victim[] and [2] who has a diagnosed mental disorder that [3]
makes the person a danger to the health and safety of others
in that it is likely that he or she will engage in [predatory]
AB 262
Page F
sexually violent criminal behavior." (Cooley v. Superior
Court (Martinez) (2002) 29 Cal.4th 228, 246.) If the
prosecutor meets this burden, the person then can be civilly
committed to a DSH facility for treatment.
The Department of State Hospitals must conduct a yearly
examination of a SVP's mental condition and submit an annual
report to the court. This annual review includes an
examination by a qualified expert. (Welf. & Inst. Code, §
6604.9.) In addition, DSH has an obligation to seek judicial
review any time it believes a person committed as a SVP no
longer meets the criteria, not just annually. (Welf. & Inst.
Code, § 6607.)
The SVPA was substantially amended by Proposition 83 ("Jessica's
Law"), which became operative on November 7, 2006.
Originally, a SVP commitment was for two years; but now, under
Jessica's Law, a person committed as a SVP may be held for an
indeterminate term upon commitment or until it is shown that
the defendant no longer poses a danger to others. (See People
v. McKee (2010) 47 Cal. 4th 1172, 1185-87.) Jessica's Law
also amended the SVPA to make it more difficult for SVPs to
petition for less restrictive alternatives to commitment.
These changes have survived due process, ex post facto, and,
more recently, equal protection challenges. (See People v.
McKee, supra, 47 Cal. 4th 1172 and People v. McKee (2012) 207
Cal.App.4th 1325.)
3)Obtaining Release From Commitment; A person committed as a
SVP may petition the court for conditional release or
unconditional discharge after one year of commitment. (Welf.
& Inst. Code, § 6608, subd. (a).) The petition can be filed
with, or without, the concurrence of the Director of State
Hospitals. The Director's concurrence or lack thereof makes a
difference in the process used.
A SVP can, with the concurrence of the Director of State
Hospitals, petition for unconditional discharge if the patient
"no longer meets the definition of a SVP," or for conditional
AB 262
Page G
release. (Welf. & Inst. Code, § 6604.9, subd. (d).) If an
evaluator determines that the person no longer qualifies as a
SVP or that conditional release is in the person's best
interest and conditions can be imposed to adequately protect
the community, but the Director of State Hospitals disagrees
with the recommendation, the Director must nevertheless
authorize the petition. (People v. Landau (2011) 199
Cal.App.4th 31, 37-39.) When the petition is filed with the
concurrence of the DSH, the court order a show cause hearing.
(Welf. & Inst. Code, § 6604.9, subd. (f).) If probable cause
is found, the patient thereafter has a right to a jury trial
and is entitled to relief unless the district attorney proves
"beyond a reasonable doubt that the committed person's
diagnosed mental disorder remains such that he or she is a
danger to the health and safety of others and is likely to
engage in sexually violent behavior if discharged." (Welf. &
Inst. Code, § 6605.)
A committed person may also petition for conditional release or
unconditional discharge notwithstanding the lack of
recommendation or concurrence by the Director of State
Hospitals. (Welf. & Inst. Code, § 6608, subd. (a).) Upon
receipt of this type of petition, the court "shall endeavor
whenever possible to review the petition and determine if it
is based upon frivolous grounds and, if so, shall deny the
petition without a hearing." (Welf. & Inst. Code, § 6608,
AB 262
Page H
subd. (a).)<1> If the petition is not found to be frivolous,
the court is required to hold a hearing. (People v. Smith
(2013) 216 Cal.App.4th 947.)
The SVPA does not define the term "frivolous." The courts have
applied the definition of "frivolous" found in Code of Civil
Procedure section 128.5, subdivision (b)(2): "totally and
completely without merit" or "for the sole purpose of
harassing an opposing party." (People v. Reynolds (2010) 181
Cal.App.4th 1402, 1411; see also People v. McKee, supra, 47
Cal.4th 1172; People v. Collins (2003) 110 Cal.App.4th 340,
349.) Additionally, in Reynolds, supra, 181 Cal.App.4th at p.
1407, the court interpreted Welfare and Institutions Code
section 6608 to require the petitioner to allege facts in the
petition that will show he or she is not likely to engage in
sexually-violent criminal behavior due to a diagnosed mental
disorder, without supervision and treatment in the community,
since that is the relief requested.
Once the court sets the hearing on the petition, then the
petitioner is entitled to both the assistance of counsel, and
the appointment of an expert. (People v. McKee, supra, 47
Cal.4th 1172, 1193.) At the hearing, the person petitioning
for release has the burden of proof by a preponderance of the
evidence. (Welf. & Inst. Code, § 6608, subd. (i); People v.
---------------------------
<1> Recently, in People v. McCloud (2013) 213 Cal.App.4th 1076,
the Court of Appeal recognized that the provision in Welfare and
Institutions Code section 6608, subdivision (a) allowing for
dismissal of a frivolous petition for release without a hearing,
may violate the equal protection clause. The petitioner's equal
protection claim was based on the fact that "[n]o other
commitment scheme allows the judge to deem the petition
'frivolous' and thereby deny the petitioner a hearing." (Id. at
p. 1087.) The court found there might well be actual disparate
treatment of similarly situated persons-and if there was
disparate treatment, the State might or might not be justified
in so distinguishing between persons. The court remanded the
case for further proceedings on the equal protection claim.
(Id. at p. 1088.)
AB 262
Page I
Rasmuson (2006) 145 Cal.App.4th 1487, 1503.) If the petition
is denied, the SVP may not file a subsequent petition until
one year from the date of the denial. (Welf. & Inst. Code, §
6608, subd. (h).)
1)Difficulty in Finding Compliant Housing: Among other things,
this bill provides that a person adjudicated as an SVP shall
only reside in a dwelling or abode within 10 miles of a
permanent physical police or sheriff station that has
jurisdiction over the location and has 24 hour a day peace
officer staffing on duty and available to respond to call for
service. This, effectively, would prevent an SVP from
residing in a rural area, and rural locations, often, are the
only areas where an SVP can find a residence which complies
with "Jessica's Law", which prohibits a person required to
register as a convicted sex offender from residing within
2,000 feet of a public or private school, or park where
children regularly congregate.
Liberty Health Care, the contract provider for DSH, goes to
great lengths at considerable expense to find suitable housing
for an SVP on conditional release in the community. In the
case of People v. Superior Court (Karsai) (2013) 213 Cal App
4th 774, Liberty Health Care reported that its staff had
travelled 6,793 miles in one year searching for a residence
for Karsai and had viewed 1,261 properties in Santa Barbara,
Ventura, and San Luis Obispo Counties. The only potential
residence was Karsai's mother's home in Santa Maria, and the
Court determined that Karsai's mother's home was not
disqualified as a potential residence despite its proximity to
a park and an elementary school. Later, Liberty informed the
court that the Karsai family had withdrawn his mother's home
as a placement/residence site because the family had been
beset upon by the local media.
The court then found that "extraordinary circumstances existed,
justifying a search for 'any' available housing "without being
constrained to San Luis Obispo or Santa Barbara County."
Approximately five months later, Liberty had reviewed more
AB 262
Page J
than 1,830 sites and had identified two possible locations:
an apartment in Sacramento and a small home in Auburn. At a
hearing, both the People and Karsai objected to the locations.
The People objected due to the proximity of Karsai's victims,
and both sides objected "on the basis that the placement would
provide no support structure for Mr. Karzai". Agreeing that
it would be "fruitless" to pursue those placements, the court
ordered Liberty to check into the option of placing Karzai in
a travel trailer on a pad next to the San Luis Obispo County
Sheriff's Office. Liberty shortly informed the court that
there had been objections to Karzai's placement in a trailer
and that the pad was "not Jessica's law compliant. Because it
appeared to the court that "there was no suitable placement
available either in Mr. Karsai's county of domicile, or
elsewhere," the court ordered Karsai be "released in Santa
Barbara County as a transient." Santa Barbara then sought a
writ of mandate in the court of appeal, seeking to vacate the
superior court's order releasing Karsai into Santa Barbara as
a transient.
The court eventually ruled that nothing in the law forbids the
conditional release of an SVP as a transient. "Moreover, to
imply such imply such a limitation into the law would raise
serious constitutional issues. 'Because civil commitment
involves a significant deprivation of liberty, a defendant in
an SVP proceeding is entitled to due process protections.'
(People v. Otto (2001) 26 Cal.4th 200, 209 [109 Cal. Rptr. 2d
327, 26 P.3d 1061].) Once a court has determined that a
particular SVP would not be a danger to the health and safety
of others in that it is not likely that he or she would engage
in sexually violent criminal [*789] behavior due to his or her
diagnosed mental disorder if under supervision and treatment
in the community, that person unquestionably has a significant
liberty interest in being released. To authorize an
unspecified delay in that release by implying in the SVPA a
requirement that the person must have a specific resident
before release, when under the statutory scheme the securing
of a specific residence is not a prerequisite to a finding
that the person would pose no danger to others if under
AB 262
Page K
outpatient supervision and treatment, would run the risk that
a person who is no longer dangerous will nonetheless have to
remain in custody in a secure facility indefinitely simply
because of some [***28] extraneous factor, such as public
outrage, that interferes with finding and securing a fixed
residence for that person. To avoid such a potential due
process problem, we believe the more prudent-as well as that
most consistent with the established canons of statutory
interpretation-is to not imply in the SVPA something the
Legislature did not expressly include in it: the limitation
that an SVP cannot be conditionally released in the community
without a specific residence."
If this bill were to pass, and it becomes impossible to place
SVP's in a compliant residence in the community, the courts
could be compelled to release SVP's in the community as
transients, which would present a risk to the public safety,
as they would not be under the watchful eye of Liberty Health
Care. It should be noted, that DSH has informed Committee
staff that there has never been instance of an SVP on
conditional release having committed a new offense. This is
largely due to the stringent protocol imposed on SVP's by
Liberty Health Care, which includes a compliant and stable
residence.
2)Impact of Residency Restrictions: In October of 2014, the
Office of the Inspector General (OIG) conducted a review and
assessment of sex offenders on parole and the impact of
residency restrictions on this same population. The Executive
Summary of the OIG Report concluded, "The residency
restrictions imposed by Jessica's Law, which prohibit parole
sex offenders from living within 2,000 feet of a school or
park where children congregate, contribute to homelessness
among parole sex offenders. According to the California Sex
Offender Management Board, there were only 88 sex offenders on
parole registered as transient when Proposition 83 was passed
in November 2006. As of June 2014, there were 1556 sex
offender parolees identified as transient by the California
Department of Corrections and Rehabilitation (CDCR). While
AB 262
Page L
this represents 3.38 percent of all parolees, the incidence of
homelessness is 19.95 percent (approximately one in five)
among the subset of parolees who are sex offenders"
"Transient sex offenders are more 'labor intensive' than are
parolees who have a permanent residence. The OIG interviewed
parole administrators in 12 parole districts, who said that
because transient sex offenders are moving frequently,
monitoring their movement is time consuming. Transient sex
offenders must register with law enforcement monthly (as
opposed to yearly for those with permanent residences), thus
requiring more frequent registration compliance tracking by
parole agents. Adding further to the workload associated with
monitoring transients, agents are required to conduct weekly
face-to-face contacts with them."
"While Jessica's Law leaves open the door for local governments
to impose their own restrictions on paroled sex offenders,
parolees are finding relief from residency restrictions in the
courts."
The California Supreme Court in In Re Taylor (2014) 60 Cal. 4th
1019, recently, ruled that CDCR's enforcement of the Jessica's
Law residency restrictions was unconstitutionally unreasonable
as applied to San Diego County. The court held that because
blanket enforcement had caused many parolees to be homeless
and thus had hampered efforts to supervise and rehabilitate
them in the interests of public safety, such enforcement was
arbitrary and oppressive, violating due process under the 14th
Amendment to the U.S. Constitution, under a rational basis
analysis because it bore no rational relationship to advancing
the state's legitimate goal of protecting children from sexual
predators. On March 26th of this year the CDCR announced,
that upon advice of the Attorney General, it would no longer
be enforcing Jessica's Law's blanket residency restrictions in
any parole region in the state. To the extent that the
residency restriction in this bill would result in SVP's
becoming homeless, these restrictions would likely, also be
found to be unconstitutional.
AB 262
Page M
3)Severability Clause: This bill contains a provision which
states, "The provisions of this measure are severable. If any
provision of this measure or its application is held invalid,
that invalidity shall not affect other provisions or
applications that can be given effect without the invalid
provision or application." Severability clauses are
frequently contained in Voter Initiatives because the
constitutionality of the measure has not been subjected to
scrutiny. However, it is an unusual provision in a bill
introduced in the Legislature. Is the severability clause a
recognition by the author of the significant constitutional
issue in this bill?
4)Argument in Support: Supervisor Michael Antonovich of the Los
Angeles County Board of Supervisors states, "In 1995, the
Sexually Violent Predators (SVP) Program was established. An
SVP is a separate category of sex offender, and is defined as
"a person who has been convicted of a sexually violent offense
against one or more victims and who has a diagnosed mental
disorder that makes the person a danger to the health and
safety of others in that it is likely that he or she will
engage in sexually violent criminal behavior." As a result,
SVP's are admitted into State Hospitals for further treatment
following the end of their prison sentence.
"SVP's have committed very serious crimes, such as Christopher
Hubbart who was dubbed the "pillowcase rapist" for assaulting
more than 40 women between 1971 and 1983.
"After being granted conditional release, numerous sexually
violent predators have been given conditional releases into
Southern California communities-most of which are rural. These
are areas lack sufficient law enforcement protection to
quickly respond to incidents should an SVP cause a problem.
This makes the placement of a SVP in a rural area highly
problematic for the community's safety and residents are
understandably concerned.
AB 262
Page N
"AB 262 offers a solution to this problem by designating
appropriate locations for sexually violent predators to be
released by requiring that a full-time police or sheriff
station be within 10 miles of the placement. It also prevents
sexually violent predators from engaging in a tenant-landlord
relationship or living with other sex offenders.
"The goal is to provide a safe environment for community where
law enforcement is available to quickly respond in an
emergency, and help reduce the potential for negative
influences on SVP's by other sex offenders who may be a
roommate or landlord."
5)Argument in Opposition: According to The California Public
Defenders Association, "AB 262 is a bald example of "Not in My
Backyard" legislation. By prohibiting sexually violent
predators from living further than 10 miles from a fully
staffed police station, AB 262 would force individuals who
have been adjudicated as sexually violent predators to be
placed by the state contractor for conditional release to the
community, Liberty Healthcare, in urban or suburban areas.
Such legislation in not in the best interests of all of the
people of the State of California, regardless of where they
reside.
"AB 262 may also be unconstitutional because in some cases it
would be tantamount to banishment. Liberty Healthcare has had
tremendous difficulty finding housing for individuals who have
completed sex offender treatment and have been found by the
courts to be appropriate candidates for conditional release.
According to the Executive Director of Liberty, the average
wait for Liberty to find housing is one year.<2>
"The court in People v. Superior Court (Karsai) (2013) 213
--------------------------
<2> Alan Stillman, Executive Director of Liberty, talk to
California Coalition on Sexual Offending, East Bay Chapter,
March 31, 2014.
AB 262
Page O
Cal.App. 4th 774 detailed the extraordinary efforts that
Liberty went through to place Mr. Karsai in the community over
a span of several years. Housing offers were repeatedly
withdrawn including a trailer next to the San Luis Obispo
County Sheriffs' Department. The Karsai court noted that
"Liberty (Health Care) (the conditional release provider for
the State) reported that its staff had traveled 6,793 miles in
a year of searching for a residence for Karsai and had viewed
1,261 properties in Santa Barbara, Ventura, and San Luis
Obispo Counties." (Id at 781-782.)
"The United States Supreme Court has allowed the civil
commitment and custody of individuals as long as they have a
currently diagnosed mental disorder which causes them to be a
danger to the community in that they are likely to reoffend.
Holding individuals who are not likely to reoffend and are no
longer dangerous in custody merely because of community
pressure or displeasure would not pass constitutional muster.
The constitutional problems with AB 262 are compounded by the
prohibition against living with or in properties owned or
rented by people with serious or violent felonies. This
prohibition has no exceptions for family members.
AB 262 wastes scarce public resources. Liberty has reported
that it typically pays two to three times fair market rate to
secure housing for individuals placed on conditional
release.<3> Most individuals released pursuant to W&I section
6608 need financial assistance. Given the low vacancy rates
and high occupancy rates in California's cities, excluding
individuals on conditional release will cost taxpayers even
more.
--------------------------
<3> Alan Stillman, Executive Director of Liberty, talk to
California Coalition on Sexual Offending, East Bay Chapter,
March 31, 2014.
AB 262
Page P
"Again the financial waste in AB 262 is exacerbated by the
prohibition against individuals released pursuant to W&I
section 6608 living with or in properties owned or rented by
people with serious or violent felonies. Since it would bar
any transitional housing or half house or religious program
that sought to help convicted felons and sex offenders
rehabilitate and reintegrate into society. Many church groups
offer housing to help felons and sex offenders. Under this
proposed legislation, they would be curtailed in their efforts
to do so. Some research has found that housing people
together who have been previously convicted of serious
offenses can have beneficial consequences since they tend to
police each other better and be more attuned to a misstep by
other members of the community.
"Finally, the prohibition against individuals released
pursuant to W&I section 6608 living with or in properties
owned or rented by people with serious or violent felonies is
unnecessarily restrictive and duplicative. Penal Code section
3003.5 bars registered sex offenders who are released on
parole from living with any other sex offender. The parole
tolling provision of Penal Code section 3000(a)(4) which
states that for anyone adjudicated a sexually violent predator
their parole is tolled until they are released."
REGISTERED SUPPORT / OPPOSITION:
Support
Supervisor Michael D. Antonovich, Los Angeles County Board of
Supervisors
Supervisor Diane Jacob, San Diego County
Agua Dulce Town Council
Santa Ana Police Officers Association
Long Beach Police Officers Association
California Fraternal Order of Police
Los Angeles County Professional Peace Officers Association
Sacramento County Deputy Sheriffs' Association
AB 262
Page Q
Crime Victims United
Opposition
American Civil Liberties Union
California Attorneys for Criminal Justice
California Public Defenders Association
Legal Services for Prisoners with Children
Analysis Prepared
by: Gregory Pagan / PUB. S. / (916) 319-3744