BILL ANALYSIS                                                                                                                                                                                                    Ó



          SENATE COMMITTEE ON PUBLIC SAFETY
                             Senator Loni Hancock, Chair
                                2015 - 2016  Regular 

          Bill No:    AB 443        Hearing Date:    July 14, 2015     
          
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          |Author:    |Alejo                                                |
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          |Version:   |May 4, 2015                                          |
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          |Urgency:   |No                     |Fiscal:    |Yes              |
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          |Consultant:|JM                                                   |
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                                Subject:  Forfeiture



          HISTORY
          
          Source:   Attorney General of California

          Prior Legislation:                           AB 2466  
          (Blumenfield) - Ch. 512, Stats. 2012
                         AB 364 (Bonilla) - Ch. 182, Stats. 2011
                         AB 1293 (Blumenfield) - Ch. 371 Stats. 2011
                         AB 17 (Swanson) - Ch. 211, Stats. 2010
                         AB 1199 (Richardson) - Ch. 408, Stats. 2007
                         SB 968 (Bowen) - Ch. 125, Stats. 2003
                         AB 215 (Leslie) - 2003; failed passage in  
          Assembly Public Safety
                         AB 1990 (Liu) - Ch. 991, Stats. 2002
                         AB 662 (Wesson) - 1999 Legislative Session;  
          vetoed

          Support:  Alameda County District Attorney; California District  
                    Attorneys Association;  California Police Chiefs  
                    Association; California Statewide Law Enforcement  
                    Association; Gonzalez Police Department; Law Center to  
                    Prevent Gun Violence;  Monterey County District  
                    Attorney; Peace Officers Research Association of  
                    California; Santa Clara County District Attorney;  
                    Soledad Police Department








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          Opposition:American Civil Liberties Union; California Attorneys  
          for Criminal Justice; California Public Defenders Association;  
          Gun Owners of California

          Assembly Floor Vote:                 71 - 5


          PURPOSE

          The purpose of this bill is to: 1) authorize a prosecutor in a  
          criminal profiteering (organized crime) matter to file a  
          petition for forfeiture of illicitly derived assets and profits  
          from  persons associated with transnational criminal  
          organizations up to 60 days prior to the filing of criminal  
          charges; 2) require the prosecutor to provide notice to any  
          party that may have an interest in property subject to  
          forfeiture; 3) authorize a person claiming an interest in seized  
          property to move the court "for return" of the property on the  
          grounds that there is no probable cause that the property is  
          forfeitable; and 4) provide that the court may issue the order  
          if it finds the following: there is a substantial probability  
          that criminal charges will be filed or a grand jury indictment  
          sought, there is a  substantial probability that the prosecuting  
          agency will prevail on the issue of forfeiture, and that failure  
          to enter the order will result in the property being destroyed,  
          removed from the court's jurisdiction, or otherwise kept from  
          forfeiture.

          Existing law:

             1)   Defines "criminal profiteering activity" as any act made  
               for financial gain or advantage if the act may be charged  
               as one of the following crimes:  arson, bribery, child  
               pornography, assault, embezzlement, extortion, forgery,  
               gambling, kidnapping, mayhem, murder, pimping and  
               pandering, receiving stolen property, robbery, criminal  
               solicitation, grand theft, drug trafficking, making a  
               fraudulent claim, money laundering, conspiracy, active  
               participation in a criminal street gang, any felony  
               committed for the benefit of a gang, beverage recycling  
               fraud, human trafficking, causing a minor through force,  
               coercion or deceit to engage in commercial sexual conduct,  
               abduction or procurement by fraud for prostitution, auto  
               theft, or identity theft(Pen. Code § 186.2, subd. (a).)








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             2)   Defines "pattern of criminal profiteering activity" as  
               engaging in at least two incidents of criminal profiteering  
               that meet the following requirements:

                           Have the same or a similar purpose, result,  
                    principals, victims, or methods of commission, or are  
                    otherwise interrelated by distinguishing  
                    characteristics;
                           Are not isolated events; and
                           Were committed as a criminal activity of  
                    organized crime.  (Pen. Code § 186.2, subd. (b).)

             3)   Provides that after conviction of the qualifying  
               offense, a person may be subject to asset forfeiture if the  
               prior act occurred within 10 years, excluding any period of  
               imprisonment, of the commission of the underlying offense.   
               (Pen. Code § 186.2, subd. (b).)

             4)   Provides that upon proof of specified provisions, the  
               following assets shall be subject to forfeiture:

                           A property interest acquired through a pattern  
                    of criminal profiteering activity; and
                           All proceeds of a pattern of criminal  
                    profiteering activity, including all things of value .  
                    . . received in exchange for the proceeds . . .  
                    derived from the pattern of criminal profiteering  
                    activity.  (Pen. Code § 186.3.)

             5)   Provides that the prosecutor shall file the forfeiture  
               petition in conjunction with the criminal proceeding and  
               provide notice to persons who may have an interest in the  
               property that is alleged to be subject to forfeiture.   
               (Pen. Code § 186.4.)

             6)   Provides that when or after charges and a forfeiture  
               petition are filed in a criminal profiteering forfeiture  
               case, the prosecutor may move the court for orders  
               preserving the defendant's assets that may be subject to  
               forfeiture, as follows:

                 An injunction to restrain all interested parties from  
               transferring, encumbering or
                   otherwise disposing of property subject to forfeiture.   








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                 Appoint a receiver to manage the property. 
                           Require a surety bond if necessary to  
                    preserved the interests of interested parties.  (Pen.  
                    Code § 186.6.)
          
             7)   Provides that where the prosecutor seeks an order  
               preserving property for purposes of forfeiture, notice must  
               be given to interested parties and a hearing held to  
               determine that an order is necessary to preserve the  
               property pending disposition of the criminal case, there is  
               probable cause that the property is truly subject to  
               forfeiture.  Neither an injunction may be granted nor a  
               receiver appointed without a hearing.  The court may issue  
               a temporary restraining order pending a hearing.  (Pen.  
               Code § 186.6.) 

             8)   Provides that the forfeiture proceedings shall be set  
               for hearing in the superior court in which the underlying  
               criminal offense will be tried.  If the defendant is found  
               guilty of the underlying offense, the issue of forfeiture  
               shall be promptly tried, before the same jury or a new jury  
               in the discretion of the court, unless waived by all  
               parties. (Pen. Code § 186, subds. (c)-(d) .)

             9)   Requires that before assets are forfeited, the  
               prosecuting agency shall have the burden of establishing  
               beyond a reasonable doubt that the defendant was engaged in  
               a pattern of criminal profiteering activity.  (Pen. Code §  
               186.5.)

             10)  Provides that where a defendant is convicted of two or  
               more related felonies involving fraud or embezzlement, and  
               the pattern of conduct involves the taking or loss of more  
               than $100,000, the defendant shall be punished by an  
               "aggravated white collar crime [prison term] enhancement."   
               (Pen. Code § 186.11.)

             11)  Provides, with respect to white collar enhancement and  
               large-scale fraud cases, that to  "prevent dissipation or  
               secreting of assets or property, the [prosecutor] may, at  
               the same time as or subsequent to the filing of [the  
               applicable charges] seek a temporary restraining order ? or  
               any other protective relief necessary to preserve the  
               property or assets."  (Pen. Code §§ 186.11, subd. (e).)








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             12)  Authorizes the court to place a white collar crime  
               defendant on probation for up to 10 years to ensure payment  
               of restitution.  The provisions for protection of assets  
               seized from defendants shall remain in effect through  
               sentencing in order to satisfy fines and restitution  
               orders.  (Pen. Code § 186.11, subds. (d).)

             13)  Sets out detailed procedures that apply to a petition  
               for preserving property in a white collar crime cases.   
               These include, but are not limited to, the following:

                 The orders (preliminary injunction and temporary  
               restraining order) must be 
                    issued solely to preserve property so that restitution  
                    and fines will be paid;
                 The prosecutor shall file a lis pendens (notice of a  
               lawsuit affecting real property) 
                    as to all real property subject to the orders;
                           The prosecutor may obtain an order that any  
                    financial institution to disclose specified  
                    information about relevant accounts;
                           The court may issue a temporary restraining  
                    order (TRO) supported by an affidavit by a peace  
                    officer with personal knowledge about the case.  The  
                    TRO may be issued without notice to the defendant upon  
                    a showing of good cause;
                           A person who claims an interest in the  
                    protected property may file a claim concerning his or  
                    her interest in seized property, as specified; 
                           The defendant or a person who has filed a  
                    verified property claim may seek modification of any  
                    orders, including relief from a lis pendens;
                           The court may appoint a receiver to manage  
                    property.  The defendant may be ordered to post a  
                    bond;
                           The court may order sale of a property that is  
                    liable to perish or substantially drop in value; and
                           The court shall weigh the relative certainty  
                    of the outcome of the prosecution and the consequences  
                    to interested parties if property preservation orders  
                    are issued.

                 The court shall give significant weight to the following  
          factors:








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                 The public interest in preserving the property;
                 The difficult of preserving the assets;
                 The purpose for the preservation orders;
                 The likelihood that the charged crime caused substantial  
               public harm;
                           The court shall seek to protect the interests  
                    of innocent parties, including an innocent spouse;
                           The court may consider a defendant's request  
                    to release property to pay bail, legal fees, and  
                    living expenses, but must consider the public  
                    interest, the nature of the crime and the purpose for  
                    the preservation orders; and
                           The court may issue orders to preserve the  
                    continuing viability of any lawful business.  (Pen.  
                    Code §§ 186.11, subds. (d)-(f).)

             14)  Provides that where the jury finds the defendant not  
               guilty of the underlying fraud crime, or it finds the  
               white-collar enhancement allegation untrue, any preliminary  
               injunction or TRO shall be dissolved.  (Pen. Code §  
               186.11.)

             1)   Authorizes prosecuting agencies, at the same time as the  
               filing of a complaint or indictment charging human  
               trafficking, to file a petition for protective relief  
               necessary to preserve property or assets that could be used  
               to pay for remedies relating to human trafficking,  
               including, but not limited to, restitution and fines.   
               (Pen. Code § 236.6, subd. (a).)

             2)   Specifies the process by which a preliminary injunction,  
               temporary restraining order, or sale of property or assets  
               may be ordered.  The process is essentially the same as the  
               process set out in Penal Code Section 186.11 - preservation  
               of assets in white collar crime cases, and 186.12 -  
               preservation of assets in large-scale elder and dependent  
               abuse financial cases.  (Pen. Code § 236.6, subds.  
               (b)-(j).)

          This bill:  

             1)   Provides that to prevent dissipation or secreting of  
               assets or property in criminal asset forfeiture matter  
               involving a transnational criminal organization, as  
               defined, the prosecuting agency may file a petition for  








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               forfeiture prior to commencement of criminal proceedings  
               upon the following showing:
          
                 The value of the assets to be seized exceeds $100,000. 
                           There is a substantial probability that the  
                    prosecuting agency will file a criminal complaint or  
                    seek a grand jury indictment against the defendant.
                           There is a substantial probability that the  
                    prosecuting agency will prevail on the issue of  
                    forfeiture and that failure to enter the order will  
                    result in the property being destroyed, removed from  
                    the jurisdiction of the court, or otherwise made  
                    unavailable for forfeiture.
                           The need to preserve the availability of the  
                    property through the entry of the requested order  
                    outweighs the hardship on any party against whom the  
                    order is to be entered.
                           There is a substantial probability that the  
                    assets subject to forfeiture represent direct or  
                    indirect proceeds of criminal activity committed for  
                    the benefit of, at the direction of, or in association  
                    with, a transnational criminal organization, as  
                    defined.

             1)   Defines, for purposes of criminal profiteering  
               forfeiture, a "transnational criminal organization" as "any  
               ongoing organization, association, or group, having  
               leaders, associates, operations, or activities in more than  
               one country, with one of its primary activities being the  
               commission of one or more" specified criminal profiteering  
               related acts.

             2)   States that if a forfeiture petition is filed prior to  
               the filing of the complaint in a criminal action, the  
               petition and any injunctive order shall be dismissed by  
               operation of law unless a criminal complaint or grand jury  
               indictment is filed within 60 days of the grant of the  
               motion.

             3)   Provides that if a forfeiture petition is dismissed  
               because criminal charges were not filed within 60 days, the  
               motion shall not be refiled, except upon the filing of a  
               criminal complaint.

             4)   Provides that if a forfeiture petition is filed prior to  








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               the filing of criminal charges, a person claiming an  
               interest in the property may move for the return of the  
               property on the grounds that there is not probable cause to  
               believe the property is forfeitable and is not otherwise  
               subject to court order of forfeiture or destruction by  
               another specified statute. 

             5)   Provides that a motion for return of property may be  
               made prior to, during, or subsequent to the filing of  
               criminal charges or a grand jury indictment.  If the  
               prosecuting agency does not establish a substantial  
               probability that the property is subject to forfeiture, the  
               court shall order the seized property released to the  
               person it determines is entitled to the property.

                    RECEIVERSHIP/OVERCROWDING CRISIS AGGRAVATION

          For the past eight years, this Committee has scrutinized  
          legislation referred to its jurisdiction for any potential  
          impact on prison overcrowding.  Mindful of the United States  
          Supreme Court ruling and federal court orders relating to the  
          state's ability to provide a constitutional level of health care  
          to its inmate population and the related issue of prison  
          overcrowding, this Committee has applied its "ROCA" policy as a  
          content-neutral, provisional measure necessary to ensure that  
          the Legislature does not erode progress in reducing prison  
          overcrowding.   

          On February 10, 2014, the federal court ordered California to  
          reduce its in-state adult institution population to 137.5% of  
          design capacity by February 28, 2016, as follows:   

                 143% of design bed capacity by June 30, 2014;
                 141.5% of design bed capacity by February 28, 2015; and,
                 137.5% of design bed capacity by February 28, 2016. 

          In February of this year the administration reported that as "of  
          February 11, 2015, 112,993 inmates were housed in the State's 34  
          adult institutions, which amounts to 136.6% of design bed  
          capacity, and 8,828 inmates were housed in out-of-state  
          facilities.  This current population is now below the  
          court-ordered reduction to 137.5% of design bed capacity."(  
          Defendants' February 2015 Status Report In Response To February  
          10, 2014 Order, 2:90-cv-00520 KJM DAD PC, 3-Judge Court, Coleman  
          v. Brown, Plata v. Brown (fn. omitted).








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          While significant gains have been made in reducing the prison  
          population, the state now must stabilize these advances and  
          demonstrate to the federal court that California has in place  
          the "durable solution" to prison overcrowding "consistently  
          demanded" by the court.  (Opinion Re: Order Granting in Part and  
          Denying in Part Defendants' Request For Extension of December  
          31, 2013 Deadline, NO. 2:90-cv-0520 LKK DAD (PC), 3-Judge Court,  
          Coleman v. Brown, Plata v. Brown (2-10-14).  The Committee's  
          consideration of bills that may impact the prison population  
          therefore will be informed by the following questions:

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



          COMMENTS

          1.Need for This Bill

          According to the author:

               AB 443 - sponsored by Attorney General Kamala Harris -  
               will allow a prosecuting agency to file a petition of  
               forfeiture for good cause prior to the commencement of  
               a criminal proceeding in cases of criminal  
               profiteering.  The bill is focused at freezing and  
               preserving the assets of transnational criminal  
               organizations. Gang violence and crime continue to be  
               serious problems across the state, and we must take  
               steps to diminish the grip they have on many of our  
               most disadvantaged communities.  By freezing the  
               assets of criminal organizations, we hit them where it  








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               hurts most, and we can put a halt to their operations.  


               According to a report released by Attorney General  
               Harris  - "Gangs Beyond Boarders: California and the  
               Fight Against Transnational Organized Crime,"  
               "[t]ransnational Criminal Organizations are  
               self-perpetuating associations operating across  
               national borders that use violence, corruption, and  
               fraud to protect and disguise their illicit, and  
               profit-driven activities." 

               This bill comes directly from a recommendation in the  
               stating "[t]he Legislature should amend California law  
               to enable prosecutors to temporarily freeze the assets  
               of transnational criminal organizations and their gang  
               associates before the filing of an indictment."   A  
               void in current law essentially gives transnational  
               criminal organizations notice prior to the freezing of  
               assets, allowing the organization to move funds beyond  
               the prosecutor's reach.  This perpetuating system that  
               gives criminals a leg up over law enforcement must  
               end.  AB 443 shifts the advantage and allows law  
               enforcement to effectively address transnational crime  
               in our state.

          2.Background on Criminal Asset Forfeiture
          
          In 1982, the California Legislature passed the California  
          Control of Profits of Organized Crime Act.  The express purpose  
          of the Act was to punish the activities of organized crime  
          through the forfeiture of profits acquired and accumulated as a  
          result of engaging in a pattern of criminal profiteering  
          activity.  All property gained through that activity is subject  
          to forfeiture.  (Penal Code §§ 186 and 186.1.)

          Criminal profiteering asset forfeiture is a criminal proceeding  
          held in conjunction with the trial of the underlying criminal  
          offense.  Often, the same jury that heard the criminal charges  
          determines whether the defendant's assets were the ill-gotten  
                                                                                gains of criminal profiteering.  As a practical matter, the  
          prosecution must assemble its evidence for the forfeiture matter  
          simultaneously with the evidence of the crime.

          Under existing law the forfeited proceeds of criminal  








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          profiteering are placed in the county general fund with no  
          directions for use.  There are limited exceptions. For example,  
          forfeiture in child pornography cases is deposited in the county  
          or State Children's Trust Fund for child abuse and neglect  
          prevention and intervention.  (Pen. Code § 186.8; Welf. Inst.  
          Code §§ 18966 and 18969.)

          In contrast to criminal asset forfeiture, drug asset forfeiture  
          is a separate civil action.  With limited exceptions, a  
          conviction for an underlying drug offense is required.  However,  
          the prosecution in drug asset forfeiture can conduct substantial  
          civil discovery to find the defendant's assets.  Law enforcement  
          receives 65% of drug forfeiture proceeds.  Federal forfeiture  
          law authorizes a federal agency to "adopt" a state seizure and  
          return as much as 80% of the proceeds to the state or local  
          agency.  The United States Attorney General has recently limited  
          adoption of state forfeitures.<1>  

          3.History of Seize and Freeze Statutes; This Bill  
          
          In 1995, SB 950 (Killea) created a special sentencing scheme for  
          defendants convicted of relatively egregious forms of white  
          collar crime.  The law provided for sentence enhancements and  
          high fines.  The law included a procedure for the preservation  
          of the assets of persons alleged to be subject to this  
          punishment enhancement.  The law authorized the court to levy  
          upon the assets upon the defendant's conviction, in order to pay  
          restitution and fines.

          In 2011, the white collar crime asset preservation law was  
          extended to any case involving white collar financial fraud over  
          $100,000.  (AB 364 (Bonilla) Ch. 182, Stats. 2011.)  Also in  
          2011, the asset preservation provisions were adapted to cases of  
          large-scale elder and dependent abuse.  (AB 1293 (Blumenfield)  
          Ch. 371 Stats.  2011.)  The process in each kind of case is  
          essentially the same.   
          ---------------------------
          <1> SB 443 (Mitchell), which passed this Committee (5-2) and is  
          scheduled to be heard on July 14, 2015 in the Assembly Public  
          Safety Committee, would prohibit state or local law enforcement  
          agencies from transferring seized property to a federal agency  
          for adoption, require that property seized pursuant to federal  
          law be distributed to state and local law enforcement agencies  
          according to state law formulas, and that convictions be  
          obtained before the agencies could share in federal forfeiture  
          proceeds.   







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          Human trafficking laws include a seize and freeze asset  
          preservation process.  The process is largely equivalent to the  
          white collar crime and elder abuse asset preservation statutes.   
           
          
          This bill would allow prosecutors to seize assets up to 60 days  
          prior to filing a criminal action in an organized crime -  
          criminal profiteering matter.  To obtain the order, the  
          prosecutor must show the following:

           The value of the assets to be seized exceeds $100,000. 
                 There is a substantial probability that the prosecuting  
               agency will file a criminal complaint or seek a grand jury  
               indictment against the defendant.
                 There is a substantial probability that the prosecuting  
               agency will prevail on the issue of forfeiture and that  
               failure to enter the order will result in the property  
               being destroyed, removed from the jurisdiction of the  
               court, or otherwise made unavailable for forfeiture.
                 The need to preserve the availability of the property  
               through the entry of the requested order outweighs the  
               hardship on any party against whom the order is to be  
               entered.
                 There is a substantial probability that the assets  
               subject to forfeiture represent direct or indirect proceeds  
               of criminal activity committed for the benefit of, at the  
               direction of, or in association with, a transnational  
               criminal organization, as defined.

          4.Constitutional Issues
          
          Constitutional due process generally requires that a person's  
          property may not be confiscated by the state without "some kind  
          of notice and opportunity to be heard."  (Fuentes v. Shevin  
          (1972) 407 U.S. 67, 79-80.)  "We start with the basic  
          proposition that in every case involving a deprivation of  
          property within the purview of the due process clause, the  
          Constitution requires some form of notice and a hearing."   
          Beaudreau v. Superior Court (1975) 14 Cal.3d. 448, 458; See  
          also, Horn v. County Of Ventura (1979) 24 Cal. 3d 605; 612.)

          This bill does not expressly state that the initial hearing on a  
          petition for forfeiture is an ex parte hearing - a hearing where  
          only one party addresses the court, and would not eliminate the  








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          requirement in existing law that the prosecutor provide notice  
          to persons or entities affected by the seizure.  However, it is  
          not entirely clear when the notice must be given.  Under the  
          bill, a person whose property has been seized would appear to be  
          limited to disputing the prosecutor's factual allegations and  
          legal argument through a motion for return of property after it  
          has been seized.  

          The United States Supreme Court has explained the very limited  
          exceptions to the requirement of notice and the opportunity to  
          be heard before a person is deprived of property:

               We tolerate some exceptions to the general rule  
               requiring pre-deprivation notice and hearing, but only  
               in extraordinary situations where some valid  
               governmental interest is at stake that justifies  
               postponing the hearing until after the event.  ?The  
               three-part inquiry set forth in Mathews v. Eldridge  
               (1976) 424 U.S. 319, provides guidance in this regard.  
               The Mathews analysis requires us to consider the  
               private interest affected by the official action; the  
               risk of an erroneous deprivation of that interest  
               through the procedures used, as well as the probable  
               value of additional safeguards; and the Government's  
               interest, including the administrative burden that  
               additional procedural requirements would impose. (Id.,  
               at 335.) 

               ?[In] Calero-Toledo ? the Government's interest in  
               immediate seizure of a yacht subject to civil  
               forfeiture justified dispensing with the usual  
               requirement of prior notice and hearing.  Two  
               essential considerations informed our ruling in that  
               case:  First, immediate seizure was necessary to  
               establish the court's jurisdiction over the property,  
               416 U.S. at 679, and second, the yacht might have  
               disappeared had the  Government given advance warning  
               of the forfeiture action, ibid.  See also United  
               States v. Von Neumann, 474 U.S. 242, 251, 88 L. Ed. 2d  
               587, 106 S. Ct. 610 (1986) (no pre-seizure hearing is  
               required when customs officials seize an automobile at  
               the border).  Neither of these factors is present when  
               the target of forfeiture is real property.  Because  
               real property cannot abscond, the court's jurisdiction  
               can be preserved without prior seizure. United States  








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               v. Good (1993) 510 U.S. 43, 53, 57, italics added.)

          The sponsor - the Attorney General - argues that an ex parte  
          proceeding is necessary to prevent the property owner from  
          hiding or moving assets.  Members may wish to consider whether a  
          specific determination, based on the facts of each case, would  
          be necessary to conclude that an ex-parte proceeding is  
          justified, and whether United States Supreme Court decisions  
          require the court hearing the ex-parte seizure motion to use the  
          balancing test in Matthews v. Eldridge noted above.  

          The ACLU, which opposes this bill, argues that this bill  
          "permits the government to seize property without sufficient  
          evidence to bring charges.  It also appears to permit the  
          government to seize property without an adequate opportunity to  
          be heard.  Both issues raise significant Due Process concerns."   
          The bill does provide for an opportunity for a person claiming  
          interest in the property to make a motion for return of the  
          property during the 60 day period prior to the filing of  
          criminal charges.  While this does not provide for a hearing  
          prior to the seizure of the property, it does provide a remedy  
          which allows an interest holder in the seized property to move  
          for return of the property on the basis of the prosecution not  
          meeting their burden in the ex parte proceeding.  

          WOULD THE BLANKET EX PARTE PROCEEDING PROPOSED BY THIS BILL  
          SATISFY CONSTITUTIONAL DUE PROCESS REQUIREMENTS?

          The bill also provides that the prosecution must allege to a  
          magistrate that there is a "substantial probability" that the  
          agency will file a criminal complaint or seek a criminal grand  
          jury indictment.  Additionally, the prosecutor must allege that  
          there is a "substantial probability" that the prosecuting agency  
          will prevail on the issue of forfeiture.  

          According to the sponsor, the standard of substantial  
          probability is intended to be at least as demanding as probable  
          cause.  California courts have found the term to be synonymous  
          with "strong probability" or "strong likelihood."  (Walbrook  
          Ins. Co. v. Liberty Mut. Ins. Co. (1992) 5 Cal.App.4th 1445,  
          1460-1461.)  In the search warrant context, the term is also  
          synonymous with "probable cause."  (See Fenwick & W. v. Superior  
          Court (1996) 43 Cal.App.4th 1272, 1278-1279.  "Substantial  
          probability" also appears several times in the U.S. Code,  
          including in the asset forfeiture context (21 U.S.C. §  








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          853(e)(1)(B)(i)). Courts addressing the use of the term in  
          federal statutes have uniformly held that substantial  
          probability actually affords defendants greater protection than  
          the probable cause standard.  (See United States v. Gotti (2d  
          Cir. 1986) 794 F.2d 773, 777.)

          5.  Potential Loss of Value if Property is Returned to the Owner
          
          The bill would allow for seizing property for up to 60 days  
          prior to the filing of criminal proceedings against the property  
          owner or asset holder.  The bill does provide however that the  
          property may not be forfeited if the agency fails to file  
          criminal charges within the prescribed 60-day window.  However,  
          the bill does not address compensation to the property owner for  
          the interim value of the property.  For instance, if a business  
          owner must shut down his or her business, there is no provision  
          for that owner to receive remuneration for their economic losses  
          during that period.    
          
          6.  Background; 2014 DOJ Report

          As noted by the author, in March of 2014 the California  
          Department of Justice released a report entitled, Gangs Beyond  
          Borders California and the Fight Against Transnational Organized  
          Crime.  That report states in part:

               California is a global leader on a number of fronts  
               and, unfortunately, transnational criminal activity is  
               one of them . . . . In 2012 alone, 305 drug-related  
               transnational criminal organizations were found  
               operating in the state, including Mexico-based drug  
               cartels in at least 22 cities from Northern California  
               to the southern border.  Based in part on its  
               population and network of interstate highways  
               connecting the western U.S., California is a major  
               portal through which drugs flow to other U.S. states  
               and cities, as well as Canada. California is also the  
               top state in the U.S. for human trafficking, due in  
               part to its proximity to the U.S. southwest border,  
               robust economy, and large immigrant population.   
               Finally, with a gross domestic product of $2 trillion  
               and substantial international trade activity,  
               California's economic and financial infrastructure is  
               often targeted for transnational criminal money  
               laundering schemes.








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               . . .   

               The seizure of laundered money is essential to  
               disrupting and dismantling transnational criminal  
               operations. Currently, two provisions in California  
               law enable state authorities to seize laundered money:  


                           Criminal Asset Forfeiture Provision:  
                    Money, monetary instruments, and property derived  
                    from criminal profiteering are subject to  
                    forfeiture under the California Control of  
                    Profits of Organized Crime Act. (Penal Code, §§  
                    186-186.8.)
                           Civil Narcotics-Related Asset Forfeiture  
                    Provision: Money or other things of value  
                    (including real property) used to procure  
                    controlled substances or to facilitate specified  
                    narcotics offenses are subject to civil asset  
                    forfeiture. (Health & Safety Code, § 11470.)

               Significantly, both of these provisions permit the  
               seizure of criminal proceeds and assets only after the  
               commencement of formal legal proceedings, such as the  
               filing of a criminal complaint or indictment. This  
               loophole allows transnational criminal organizations  
               to safely remove assets that have been discovered by  
               law enforcement, so long as formal legal proceedings  
               have not yet begun. . . . (T)his loophole must be  
               closed. New legislation should amend California law to  
               permit law enforcement to temporarily freeze an  
               organization's illicit proceeds or property even if no  
               formal prosecution has commenced yet.<2>
                                          


                                      -- END -





          


          ---------------------------
          <2>   http://oag.ca.gov/transnational-organized-crime/ch2.







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