BILL ANALYSIS                                                                                                                                                                                                    Ó



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

          Bill No:    AB 1505       Hearing Date:    June 14, 2016    
          
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          |Author:    |Roger Hernández                                      |
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          |Version:   |May 27, 2016                                         |
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          |Urgency:   |No                     |Fiscal:    |No               |
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          |Consultant:|MK                                                   |
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                 Subject:  Statute of Limitations:  Public Contracts



          HISTORY
          Source:   Author

          Prior Legislation:None applicable

          Support:  Betty Yee, California's State Controller

          Opposition:None known

          Assembly Floor Vote:                 No longer relevant
          
          PURPOSE
          
          The purpose of this bill is to extend from one to three years  
          the statute of limitations for specified Public Contract Code  
          misdemeanors relating to competitive bidding.
          
          Existing law provides that a school district must put contracts  
          out to bid for specified contracts involving equipment or  
          services for more than $50,000 or construction contracts for  
          more than $15,000. (Public Contract Code § 20111)

          Existing law provides public projects by a local agency of more  
          than $175,000 shall be let to contract by a formal bidding  
          contract, projects of less than $175,000 may be bid by informal  








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          procedures. (Public Contract Code § 22032)

          Existing law provides that all contracts for any improvement in  
          excess of $25,000 by a reclamation district shall be let to the  
          lowest responsible bidder. (Public Contract Code § 20921)

          Existing law provides that a community college may make repairs,  
          alterations etc. without bidding when the job does not exceed  
          350 hours if the districts number of full-time students is less  
          than 15,000 and the job does not exceed 750 hours or $21,000 if  
          the number of students exceeds 15,000. (Public Contract Code §  
          2065)

          Existing law provides that when the expenditure for a public  
          project by a local agency exceeds $5,000 it shall be contracted  
          for and let to the lowest bidder after notice. (Public Contract  
          Code § 20162)

          Existing law provides that in counties of 500,000 or less,  
          public projects between $4,000 and $10,000 shall be let to  
          contract by informal bidding procedures and public projects of  
          $10,000 or more shall be let by formal bidding procedures.  
          (Public Contract Code § 20150.4)

          Existing law provides that in counties with a population of  
          2,000,000 or more must use a formal bidding process for public  
          buildings if the cost is more than $4,000 but they do not have  
          to do work by bid if the cost estimate is less than $6,500 and  
          the requirements do not apply to repair work on county owned  
          buildings if the cost is under $50,000. (Public Contract Code §§  
          20121; 20122; 20123)

          Existing law provides that it shall be unlawful for a school  
          district, community college district, reclamation agency or  
          local agency to split or separate into smaller work orders or  
          projects any work, project, service or purchase for the purpose  
          of evading the provisions requiring contracting after  
          competitive bidding. (Public Contract Code §§ 20116; 20657;  
          20922; 22033)

          Existing law provides that when the expenditure required for a  
          public project exceeds $5,000, it shall be contracted for and  
          let go to the lowest responsible bidder after notice. (Public  
          Contract Code § 20162)









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          Existing law provides that in any county, it is unlawful to  
          split or separate into small work orders or projects any public  
          work project for the purpose of evading the provisions requiring  
          public work to be done by contract after competitive bidding.  
          The penalty for a violation of these sections is a misdemeanor.  
          (Public Contract Code §§ 20123.5; 20150.11; 20163)

          Existing law provides that in general the prosecution for a  
          misdemeanor shall be commenced within one year after the  
          commission of the offense.

          This bill provides instead that a the prosecution for a  
          violation of the Public Contracts Code prohibiting the splitting  
          of jobs into smaller jobs to avoid competitive bidding shall be  
          commenced within three years of the commission of the offense.

                    RECEIVERSHIP/OVERCROWDING CRISIS AGGRAVATION

          For the past several 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 December of 2015 the administration reported that as "of  
          December 9, 2015, 112,510 inmates were housed in the State's 34  
          adult institutions, which amounts to 136.0% of design bed  
          capacity, and 5,264 inmates were housed in out-of-state  
          facilities.  The current population is 1,212 inmates below the  
          final court-ordered population benchmark of 137.5% of design bed  









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          capacity, and has been under that benchmark since February  
          2015."  (Defendants' December 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).)  One  
          year ago, 115,826 inmates were housed in the State's 34 adult  
          institutions, which amounted to 140.0% of design bed capacity,  
          and 8,864 inmates were housed in out-of-state facilities.   
          (Defendants' December 2014 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).)  
           
          While significant gains have been made in reducing the prison  
          population, the state 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:

               In April of 2014, Assemblymember Hernández formally  
               requested that the Controller's Office conduct an audit  









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               of West Covina's finances in response to several  
               complaints of misuse of public funds. 

               On June 9th 2015, State Controller Betty T. Yee  
               announced the results of a detailed review of the City  
               of West Covina's administrative and internal accounting  
               controls, finding serious and pervasive deficiencies.   
               Of the79 control components evaluated, West Covina was  
               found to be adequate in seven.  

               According to the Controller's Office, West Covina  
               violated California Public Contract Code section 20163,  
               which would constitute a misdemeanor had the statute of  
               limitations not expired. "It makes no sense that the  
               statute of limitations for violating state and local  
               contracting laws is one year from when the money is  
               spent," said Controller Yee. The Controller urged the  
               legislature to, "consider a statutory change if we  
               expect to ferret out fraud and prevent willful abuses  
               of state law and taxpayer dollars." 

               The detailed review of the City of West Covina's  
               administrative and internal accounting controls by  
               Controller Yee confirms troubling practices that harm  
               our community and brings into question government waste  
               and corruption. Over the years several cities have  
               violated the public's trust, including the city of  
               Industry, Maywood, Beaumont, Bell, Irwindale, Richmond,  
               Cudahy, and Montebello. 

               AB 1505 expands the statute of limitations by three  
               years for violating state and local public contracting  
               laws beyond the current one-year statute. Through AB  
               1505, we will be able to hold all of our elected  
               officials to greater accountability when they are  
               appropriating taxpayer dollars.

          2.  The Statute of Limitations Generally; Law Revision  
          Commission Report 
          
          The statute of limitations requires commencement of a  
          prosecution within a certain period of time after the commission  
          of a crime. A prosecution is initiated by filing an indictment  
          or information, filing a complaint, certifying a case to  









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          superior court, or issuing an arrest or bench warrant. (Penal  
          Code § 804.) The failure of a prosecution to be commenced within  
          the applicable period of limitation is a complete defense to the  
          charge. The statute of limitations is jurisdictional and may be  
          raised as a defense at any time, before or after judgment.  
          People v. Morris (1988) 46 Cal.3d 1, 13. The defense may only be  
          waived under limited circumstances. (See Cowan v. Superior Court  
          (1996) 14 Cal.4th 367.) 

          The Legislature enacted the current statutory scheme regarding  
          statutes of limitations for crimes in 1984 in response to a  
          report of the California Law Revision Commission: 

               The Commission identified various factors to be  
               considered in drafting a limitations statute. These  
               factors include: (a) The staleness factor. A person  
               accused of crime should be protected from having to  
               face charges based on possibly unreliable evidence and  
               from losing access to the evidentiary means to defend.  
               (b) The repose factor. This reflects society's lack of  
               a desire to prosecute for crimes committed in the  
               distant past. (c) The motivation factor. This aspect of  
               the statute imposes a priority among crimes for  
               investigation and prosecution. (d) The seriousness  
               factor. The statute of limitations is a grant of  
               amnesty to a defendant; the more serious the crime, the  
               less willing society is to grant that amnesty. (e) The  
               concealment factor. Detection of certain concealed  
               crimes may be quite difficult and may require long  
               investigations to identify and prosecute the  
               perpetrators. 

               The Commission concluded that a felony limitations  
               statute generally should be based on the seriousness of  
               the crime. Seriousness is easily determined based on  
               classification of a crime as felony or misdemeanor and  
               the punishment specified, and a scheme based on  
               seriousness generally will accommodate the other  
               factors as well. Also, the simplicity of a limitations  
               period based on seriousness provides predictability and  
               promotes uniformity of treatment.<1>
          


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          <1> 1 Witkin Cal. Crim. Law Defenses, Section 214 (3rd Ed.  
          2004), citing 17 Cal. Law Rev. Com. Reports, pp.308-314.






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          3.  Expansion of the Statute of Limitations for Violating Local  
          Contracting Laws

          Existing law, with some exceptions, provides that the statute of  
          limitations for a misdemeanor is one year.  This bill would make  
          the statute of limitations for misdemeanor evading provisions  
          requiring work projects to be done by contract after competitive  
          bidding three years.

          In support State Controller Betty Yee States:

               As part of my July 2016 review of the City of West  
               Covina's administrative and internal controls, my  
               auditors discovered the city violated PCC 20163, which  
               precludes cities from splitting work orders on public  
               work projects into smaller pieces in order to avoid the  
               state's competitive bidding requirements.  Violation of  
               this law is a misdemeanor, but prosecution of any  
               alleged violation must take place within a year of the  
               violation occurring.

               Unfortunately in the case of West Covina, the  
               violations were not discovered during that one-year  
               period.  By extending the period of time from one year  
               to three years in which charges must be filed, AB 1505  
               will give prosecutors more time to discover violations  
               of the Public Contract Code and hold local government  
               administrators accountable.
           
          While a three year statute of limitations may be appropriate for  
          these offenses, it is not clear that the sections that this bill  
          extends the statute of limitations for will actually deals with  
          the issue.   Depending on the section, competitive bidding is  
          required at contract amounts as low as $5,000.  Is the issue  
          that entities are breaking contracts in to such small  
          increments?  Will this bill deal with the issue the Controller  
          found?
                                          













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