BILL ANALYSIS Ó
AB 2312
Page 1
Date of Hearing: May 3, 2016
ASSEMBLY COMMITTEE ON JUDICIARY
Mark Stone, Chair
AB 2312
(Gatto) - As Amended March 18, 2016
SUBJECT: UNLAWFUL DETAINER: PAYMENT OF RENT FUNDS
KEY ISSUES:
1)by requiring a tenant to deposit disputed rent payments in a
separate account before completion of the trial in which his
or her liability for that rent may be at issue, does this bill
effectively compel an unconstitutional deprivation of the
tenant's property without due process of law?
2)should a tenant's right to retain an attorney and defend an
unlawful detainer lawsuit be conditioned on his or her ability
to pay disputed rent payments into a separate account before
completion of the trial?
3)how would such payments procedurally be made and verified by
the court or plaintiff's attorney without creating aN
irreconciliable professional conflict of interest for the
tenant's attorney?
SYNOPSIS
AB 2312
Page 2
This bill seeks to establish a controversial pre-trial rent
deposit program that would single out defendants in unlawful
detainer cases for extra procedural requirements not placed on
defendants in any other civil proceedings. Specifically, this
bill would require a defendant in an eviction case based on
nonpayment of rent to deposit with his or her attorney an amount
of money equal to the contracted monthly rent amount when it
would have become due, until the court enters judgment in the
defendant's favor or the plaintiff regains possession of the
premises. According to the author, these extraordinary
requirements are needed to address an epidemic of eviction delay
tactics by unscrupulous tenant attorneys. Supporters of the
bill, led by apartment associations, contend that unscrupulous
tenant attorneys encourage clients to file frivolous motions and
make every available defense, whether or not meritorious,
thereby causing unnecessary delays to what is supposed to be a
summary process. They believe that requiring the defendant to
pay future rent when due, into an account maintained by their
own counsel, will help assure that actions taken by the defense
will be legitimate and not solely as a tactic to delay
litigation. Supporters point to recent media reports and their
own compelling anecdotal examples of "horror stories" of
unscrupulous defendants in unlawful detainer cases who
manipulate the legal system to stay in rental properties as long
as possible, without any intention of paying rent during the
eviction proceedings.
Opponents of the bill are rightfully concerned, however, that
the required payment scheme outlined by the bill amounts to a
deprivation of the tenant's property without due process, in
violation of the 14th Amendment. They note that despite the
author's characterization of the payments obligated by this bill
as "future contract rent," existing law makes clear that such
payments constitute part of the damages claimed by the plaintiff
in his or her cause of action which must be proven by the
plaintiff by a preponderance of the evidence. Yet under this
AB 2312
Page 3
bill, these payments must be made without allowing the defendant
any opportunity to be heard to contest why the defendant should
not have to pay that money to a fund to be held in trust for the
plaintiff at a later date. Opponents correctly point out that
in an unlawful detainer action, the tenant may negate the
landlord's claim, in whole or in part, by disputing the amount
of rent owed, and demonstrating, for example, that the landlord
may have unlawfully increased the rent or failed to maintain the
habitability of the premises. Therefore, to require pre-deposit
of the rent claimed, opponents argue, would essentially concede
the damages element to the landlord and deprive the tenant of
property without due process of law. Opponents express
additional concerns that this bill treats defendants differently
based on whether they are represented by counsel or not,
effectively penalizing the very small minority of defendants who
are fortunate enough to have secured legal representation. They
are also appropriately concerned that the bill would create a
professional conflict of interest for tenant attorneys by
requiring them to either disobey the requirements of this bill
or violate client confidentiality by disclosing to a third party
(i.e. opposing counsel) whether or not their client has complied
with the payment obligations arising under this bill. The
Committee notes a number of unresolved legal and procedural
questions about how this proposal would be implemented without
creating irreconcilable due process problems and professional
conflicts of interest. Finally, the Committee notes that
California tried a version of this bill when the Legislature
enacted SB 690 (Kopp), aka the "Pretrial Rent Deposit Pilot
Project," as a pilot project in which tenants had to deposit
unpaid rent as a condition of jury trial. The pilot ran for four
years in several courts, including Los Angeles County. The
pilot was deemed a failure and was neither renewed nor expanded.
SUMMARY: Requires a defendant in an eviction case based on
nonpayment of rent to deposit with his attorney an amount of
money equal to the contracted monthly rent amount when it would
have become due, until the court enters judgment in his favor or
AB 2312
Page 4
the plaintiff regains possession of the premises. Specifically,
this bill:
1)Provides that if a defendant is represented by an attorney in
an action for unlawful detainer brought for nonpayment of rent
in which the plaintiff is seeking past due rent from a
defendant who is in possession, then the defendant shall
deliver an amount equal to the monthly rent to his or her
attorney each month after the filing of the summons and
complaint as the rent would otherwise become due and payable
under the lease or rental agreement until one of the following
conditions is satisfied:
a) The plaintiff regains possession of the property.
b) The court enters judgment in favor of the defendant in
the unlawful detainer action.
2)Requires an attorney who receives rent pursuant to the above
provision to do all of the following:
a) Deposit all rent received from the defendant pursuant to
Item 1) into a trust account separate from the attorney's
own funds.
b) Within four days of receipt of the rent, send a letter
to the plaintiff, or his or her counsel, confirming receipt
of the rent.
c) Release the rent as directed by the court or pursuant to
a written agreement between the parties.
AB 2312
Page 5
EXISTING LAW:
1)Provides that a tenant is guilty of unlawful detainer when he
or she continues in possession of rental property after three
days' written notice to quit for non-payment of rent, as
specified. (Code of Civil Procedure Section 1161, paragraph
2. All further references are to this code unless otherwise
stated.)
2)Provides that the jury or the court, if the proceedings be
tried without a jury, shall assess the damages occasioned to
the plaintiff by any forcible entry, or by any forcible or
unlawful detainer, alleged in the complaint and proved on the
trial, and find the amount of any rent due, if the alleged
unlawful detainer be after default in the payment of rent.
(Section 1174 (b).)
3)Allows the plaintiff to be awarded statutory damages of up to
six hundred dollars ($600), in addition to actual damages,
including rent found due, if the defendant is found guilty of
forcible entry, or forcible or unlawful detainer, and malice
is shown. Further requires the trier of fact to determine
whether actual damages, statutory damages, or both, shall be
awarded, and to have judgment be entered accordingly.
(Section 1174 (b).)
4)Provides that the breach of any warranty of habitability
(implied or express) is a defense to an unlawful detainer
action filed to recover possession of residential premises
based on nonpayment of rent. (Green v. Superior Court (1974)
10 Cal. 3d 616.)
5)Provides that in an unlawful detainer proceeding in which the
tenant has raised as an affirmative defense a breach of the
landlord's obligations under Civil Code Section 1941 or of any
AB 2312
Page 6
warranty of habitability, the court shall determine whether a
substantial breach of these obligations has occurred.
(Section 1174.2.)
6)Provides that, if the defendant has filed an answer to the
complaint, trial of the proceeding shall be held not later
than the 20th day following the date that the request to set
the time of the trial is made. (Section 1170.5 (a).)
7)If trial is not held within the 20th day, as specified,
requires the court, upon finding that there is a reasonable
probability that the plaintiff will prevail in the action, to
determine the amount of damages, if any, to be suffered by the
plaintiff by reason of the extension, and then issue an order
requiring the defendant to pay that amount into court as the
rent would have otherwise become due and payable or into an
escrow designated by the court for so long as the defendant
remains in possession pending the termination of the action.
(Section 1170.5 (c).)
8)Provides the determination of the amount of the payment shall
be based on the plaintiff's verified statement of the contract
rent for rental payment, any verified objection thereto filed
by the defendant, and the oral or demonstrative evidence
presented at the hearing. Requires the court's determination
of the amount of damages to include consideration of any
evidence, presented by the parties, embracing the issue of
diminution of value or any set off permitted by law. (Section
1170.5 (c).)
9)Requires the court, after trial of the action, to determine
the distribution of the payment made into court or the escrow
designated by the court. (Section 1170.5 (f).)
AB 2312
Page 7
FISCAL EFFECT: As currently in print this bill is keyed
non-fiscal.
COMMENTS: This bill seeks to establish a controversial program
for pre-trial rent deposit that would single out defendants in
unlawful detainer cases for extra procedural requirements not
placed on defendants in any other civil proceedings. According
to the author, these extraordinary requirements are justified in
order to address a growing epidemic of eviction delay tactics by
unscrupulous tenant attorneys. According to the author:
California has seen an emergence of eviction defense mills,
which market themselves to tenants as a means of staying on
their rental property rent-free for months using a variety
of defense tactics. One of the most popular tactics to
lengthen the unlawful detainer (UD) process is by
requesting a jury trial. Knowing the high cost, time delay
and lost rent to a property owner that a jury trial brings,
eviction mills, on behalf of the tenants (defendants),
often offer to waive the request for a jury trial if the
owner agrees to forgive back rent, allow the tenant to stay
additional months rent-free, pay the defendant's attorney's
fees, and seal the future court record so that future
landlords are unable to access faulty rent histories.
Other defense tactics include filing claims that the tenant
wasn't given sufficient notice of the UD lawsuit, which
requires the landlord to re-serve the complaint (thus
restarting the 5-day response clocks and 20-day court
hearing clocks), requesting a period of time for discovery
of additional information, claiming habitability issues,
and filing demurrers challenging the premises of the
unlawful detainer.
The bill seeks to fix delays and abuses in the unlawful
detainer process, whereby some tenants are frivolously
using a jury trial to delay proceedings. The measure
AB 2312
Page 8
requires defendants who request a jury trial and retain
counsel to pay to their attorneys the rent as would
otherwise be due during the duration of the trial to the
landlord. The attorneys would hold the rent in their trust
accounts, and upon a ruling by the court as to how the rent
is to be disbursed, would pay the funds in the manner
prescribed by the court.
Opponents of the bill, including tenant advocates and legal aid
organizations, are concerned that the bill is aimed not at
fixing delays in the system, but at stifling legal
representation of tenants. Among these opponents is Eviction
Defense Network, who writes:
The purpose of this bill is to fix a perceived 'imbalance'
that has arisen in unlawful detainer litigation through the
emergence of what the author terms 'eviction defense
mills.' This terminology is coded language for eviction
defense attorneys, and the imbalance that is suggested
refers to the aforementioned expansion of legal
representation for tenants facing eviction. The many ills
listed in the bill correlate to the basics of legal
representation for tenants: that is, the tenant's
assertion of a constitutional right to a jury trial;
discovery requests or the tenant's right to know the
evidence against them, and the tenant raising basic
defenses to the action such as habitability. The
unavoidable inference is that the implicit aim of AB 2312
is to stifle legal representation of tenants.
To the extent that tenant attorneys file motions or plead
affirmative defenses solely to delay UD proceedings, it should
be noted the law already provides strong potential remedies
against unscrupulous attorneys. First, California lawyers are
bound by the California Rules of Professional Conduct and
relevant portions of the Business & Professions Code. These
AB 2312
Page 9
rules generally prohibit an attorney from filing actions that
the attorney knows to be without merit solely to delay the
proceedings. (See e.g. California Rules of Professional Conduct
Rule 3-200 and Business & Professions Code Section 6068 (c).)
Existing rules of civil procedure permit the court to impose
sanctions against any attorney who uses actions or tactics that
"are frivolous or solely intended to cause unnecessary delay."
(Sections 128.5 (a) and 128.6 (a).)
Requiring deposit of rent as specified by this bill may amount
to an unconstitutional deprivation of property without due
process of law. Under this bill, if a landlord files an
eviction against a tenant for nonpayment of rent, the tenant
would be obligated, if represented by an attorney, to begin
paying an amount of money equal to the monthly rent into a trust
account maintained by the attorney. The bill requires this sum
of money to be paid into the account on each date or occasion
when the rent would have otherwise become due under the rental
agreement, and the tenant's obligation lasts as long as the UD
proceeding is pending, more specifically until either the
landlord regains possession of the property, or the court enters
judgment in favor of the tenant. For example, if T rents an
apartment from L for $1000 per month, due on the 1st of each
month and T fails to pay rent for two months, triggering L's
right to file an eviction against T on the 24th of the month,
under this bill, T would not be required to pay the past unpaid
rent total of $2000. Instead, in order to make the payment
obligation resemble the normal rent-paying obligation as much as
possible, T would be required to pay $1000 into the special
trust account seven days later, on the first of the month
(assuming the UD proceedings are still pending and assuming that
T were represented by an attorney). Should the case remain
unresolved another 30 days later (and T were still represented
by an attorney), T would again be obligated to pay $1000 into
the account.
According to the author, the tenant's attorney will hold and
AB 2312
Page 10
protect the payments in the trust account until termination of
the UD proceedings at which time the court will direct
distribution of the trust funds. The duties of the tenant's
attorney are to retain control of the acceptance of the future
payments when they become due; account for the rental payments
to the court; and use and maintain the trust fund account as he
or she would customarily do for other legal matters. The author
further states:
In many cases, there is no legitimate defense, and the
tactics are being used solely to delay the inevitable
eviction. These procedures are costly to landlords, and it
leads to an abuse of the already overburdened court system.
By requiring tenants to pay the rent as would otherwise be
due to the landlord to their attorneys, tenants would be
discouraged from using the system solely to delay the UD
proceeding, while allowing those cases in which tenants
have legitimate claims against their landlords to move
continue to move forward. If the court rules in favor of a
tenant, wholly or partially, the tenant will receive that
amount of money back as prescribed by the court.
Opponents of the bill are concerned, however, that the required
payment scheme outlined by the bill deprives the tenant of his
property without due process, in violation of the 14th
Amendment. They note that despite the author's characterization
of the payments as "future contract rent," agreed at the time
the lease was made, existing law makes clear that those payments
constitute part of the damages claimed by the plaintiff in his
cause of action. (See Code of Civil Procedure Section 1174 (b),
allowing the court to award only those damages caused by the
unlawful detainer itself, i.e. the reasonable rental value,
calculated daily from the date of expiration of the termination
notice and until the date of the judgment. (See, e.g. Roberts v.
Redlich (1952) 111 CA.2d. 566.).) As part of the damages, the
amount of rent owed must be proven by the plaintiff by a
preponderance of the evidence; yet under this bill, these
AB 2312
Page 11
payments must be made without allowing the defendant any
opportunity to contest why he should not have to pay that amount
into the trust fund established by this bill, to be held in
trust for the plaintiff at a later date. According to the
National Housing Law Project:
AB 2312 raises significant constitutional concerns. In no
other form of civil action in California is a defendant's
right to retain an attorney and defend a lawsuit
conditioned on his or her ability to pay claimed damages.
Damages are an element of the plaintiff's cause of action,
to be proven by a preponderance of the evidence by the
plaintiff. In an unlawful detainer action, the tenant may
negate the landlord's claim, in whole or in part, by
disputing the amount of rent owed. For example, the
landlord may have lost or disregarded a payment, unlawfully
increased the rent, or failed to maintain the habitability
of the premises. To require pre-deposit of the rent claimed
would essentially concede the damages element to the
landlord and deprive the tenant of property without due
process of law. The due process concerns are even more
compelling for low-income tenants with rental subsidies,
who lack the financial means to post the entire
unsubsidized rent in order to assert a meritorious defense.
The question of whether the defendant owes all, some, or none of
the claimed rent amount is a matter for the court to consider at
trial based on evidence other than the amount of rent specified
in the lease agreement. As the Legal Aid Foundation of Los
Angeles (LAFLA) explains:
AB 2312 incorrectly presumes that tenants who are accused
of non-payment of rent always owe the amount of monthly
rent that the landlord is demanding. In an unlawful
detainer action, the tenant may negate the landlord's
claim, in whole or in part, by disputing the amount of rent
AB 2312
Page 12
owed. For example, the landlord may have lost or
disregarded a payment, unlawfully increased the rent, or
failed to maintain the habitability of the premises. In a
recent non-payment case that was tried to a jury in Los
Angeles, LAFLA's staff attorneys obtained a jury verdict
for the defendant and the jury found that, due to the
extreme slum conditions of the apartment, zero rent was
owed. Certainly, requiring that tenant to pre-deposit the
rent in the amount claimed by that landlord would have been
unfair and inappropriate.
Central California Legal Services (CCLS) succinctly
articulates the objection raised by multiple opponents of
the bill, as follows: "The bill violates tenants' right to
due process by eliminating a plaintiff's duty to first prove
alleged rental damages before a defendant becomes obligated
to set aside such monies for plaintiff's benefit."
Existing law that allows deposit of rent before entry of
judgment, by contrast, provides due process protections not in
this bill. Opponents contend that this bill may not be needed
because existing law already allows a procedure that protects
against unnecessary delay and extension of the trial. They
point to this statute, CCP Section 1170.5, as an example of the
type of due process protections that are needed if the tenant is
to be made to pay an element of rent damages in advance of any
entry of judgment in the case. Section 1170.5 pertains to
situations where the defendant in a UD seeks extension of the
trial, and guards against abuse of the statute by defendants
seeking an extension to merely delay the proceedings. Section
1170.5 (c) provides that if the trial is not held within 20
days, the court, upon finding that there is a reasonable
probability that the plaintiff will prevail in the action, shall
determine the amount of damages, if any, to be suffered by the
plaintiff by reason of the extension, and then issue an order
requiring the defendant to pay the amount of the rent that would
have otherwise become due and payable or into an escrow
AB 2312
Page 13
designated by the court pending the termination of the action.
Importantly, the statute provides due process to the parties.
It allows the court to hold a hearing on the matter to ensure
that if the plaintiff is to be entitled to damages because of
the extension, then at least the defendant has an opportunity to
be heard on the matter. At such a hearing, the plaintiff must
show a reasonable probability that he will prevail and thus
suffer damages. Opponents note that these elements are lacking
from the rent deposit program described in this bill.
Proponents contend that Section 1170.5 is insufficient to
address delay tactics other than motions for trial extension,
and that the Section 1170.5 process itself is too time consuming
because an additional hearing is required. The Committee notes
that a hearing is necessary to ensure due process.
The deposit of rent program described by this bill raises (and
leaves unanswered) many important legal and procedural
questions. A quick reading of the bill leads to one basic
question: what rules apply when the tenant has no attorney?
According to the author, the bill simply does not apply when the
tenant is unrepresented.
In addition, there remain a number of basic, unanswered
questions about procedural aspects of the bill, including the
following:
1)What happens when the tenant is represented by counsel,
but at some point in time becomes unwilling or unable to
pay for the attorney, or pay the required funds into the
trust account? What would become of deposits into the
trust account at the end of the attorney's representation
of the tenants? What sanctions or defenses, if any, are
there for nonpayment by the tenant?
2)How does the bill apply to Section 8 tenants in default,
AB 2312
Page 14
where for example the monthly rent is $1000 per month and
the tenant is responsible for paying $400 per month in
rent, while the government pays the remaining $600 in the
form of a rental voucher?
3)How does the bill address what happens when there are four
tenants being evicted, each jointly and severally liable
for the rent, but only two tenants are represented by
attorneys? What amount of rent would each tenant be
obligated to pay into the trust account?
4)What happens if the tenant's attorney decides his duty of
confidentiality to his client prevents him from disclosing
to the plaintiff's attorney whether or not his client has
complied with the requirements of this bill?
5)What duties does the tenant attorney have should their
client, the defendant, stop making payments as required by
this bill?
6)What consequence face an attorney should he or she
continue to represent a tenant who stops making payments
as required by this bill and the attorney either notifies
the court of that fact, or fails to make such
notification?
Potential disincentive to seek representation; Professional
conflict of interest for tenant's attorney. Opponents of the
bill express additional concerns that this bill treats
defendants differently based on whether or not they are
represented by counsel. Because the author states that the bill
simply does not apply to unrepresented clients, it appears that
the bill effectively penalizes the very small minority of
defendants who are fortunate enough to have legal representation
AB 2312
Page 15
in unlawful detainer proceedings.
This disparate treatment of tenants depending on whether or not
they have attorneys raises equal protection concerns by enacting
a penalty that only applies to one class of tenants (those with
attorneys), even though all tenants in UD proceedings are
similarly situated. At the very least, the bill creates a
disincentive for tenants to secure legal representation to which
they are constitutionally entitled, possibly interfering with
their 6th Amendment right to counsel. Even though it is not the
stated intent of the bill's author to discourage tenants from
obtaining legal representation in UD proceedings, the bill's
disparate treatment of tenants with attorneys and those without
attorneys would certainly have that effect.
The financial penalty on tenants with attorneys may also force
tenants to choose between the benefit of having an attorney
(which necessitates paying damages into the attorney trust
account) and holding on to their limited funds for immediate
everyday needs because they can't afford to pay for both the
attorney penalty and those necessities.
The bill also creates a professional conflict of interest for
tenant attorneys. Attorneys are obligated to advocate for the
interests of their clients and also to keep client communication
confidential. This bill interferes with both obligations by
requiring attorneys to disclose to a third party whether or not
their clients have complied with the obligations arising under
this bill, possibly jeopardizing the client's legal interest and
breaching the duty of confidentiality. If an attorney had
confidential information that a tenant client had not paid rent
damages into the holding account, the attorney would be faced
with the ethically untenable choice of complying with the
requirements of this bill and betraying client confidence and
best interests. The only alternative could be for the attorney
to withdraw from the case, leaving the client without
AB 2312
Page 16
representation.
Central California Legal Services, Inc. (CCLS) contends that:
This bill will reduce the total number of defendants able
to secure representation by counsel in UD cases. . . . AB
2312 places a new obligation on tenant attorneys to collect
and hold additional client monies in trust for the
opposition, creating additional administrative burdens for
UD defense attorneys. By requiring defense counsel to
report to the other side whether or not they have received
moneys from their clients, this bill also creates the
likelihood that defense counsel would be turned into fact
witnesses adverse to their clients. We anticipate that
should this bill become law, many attorneys will avoid
unlawful detainer defense so as to avoid the problematic
burdens created by this bill.
This bill appears to resurrect a failed pilot program from
1994. According to Western Center:
California tried a version of this before and it failed.
In 1994, the Legislature enacted SB 690 (Kopp), aka the
"Pretrial Rent Deposit Pilot Project," as a pilot project
in which tenants had to deposit unpaid rent as a condition
of jury trial. The pilot ran for four years in several
courts, including Los Angeles County. Notably, SB 690
provided far greater procedural protections for tenants
than AB 2312, including affirmance by the landlord that the
rental unit at issue did not have any health, safety, fire,
rent control, or other local agency citations outstanding,
and a pretrial hearing in which the court, before requiring
deposit of unpaid rent as a condition of trial, had to
determine whether the landlord had made out a prima facie
case. The pilot was deemed a failure and was neither
AB 2312
Page 17
renewed nor expanded. Yet AB 2312 would essentially
re-enact statewide the worst aspects of a failed pilot.
In response, proponents of the bill, including the Apartment
Association, California Southern Cities, states:
That measure was heavily burdened with unnecessary
requirements and resulted in significant court costs. AB
2312 avoids those administrative costs, fees, oversight,
structure and design. It also mitigates abusive litigation
tactics from both sides. It is balanced: additional
judicial involvement is minimal, if any. Tenants will pay
future rent when due to their own counsel. Defendant's
counsel must keep the money in his or her trust account,
thereby assuring money will be accounted for and
distributed as directed by the court. Property owners will
be assured that the reasons proffered by the defense are
not to be construed as a delaying litigation tactic.
In response, WCLP contends that the "unnecessary requirements"
and court costs that are bemoaned by the proponents of this bill
are in fact part of the necessary due process protections that
lawmakers insisted on back in 1994 in order to give SB 690
initial trial approval. Opponents accurately point out that the
Legislature declined to extend authority for the SB 690 pilot
program, despite the additional systemic protections adopted for
that program, because there were still many outstanding concerns
about due process that were experienced during the four-year
trial period.
REGISTERED SUPPORT / OPPOSITION:
AB 2312
Page 18
Support
California Apartment Association (CAA)
California Association of Realtors
Apartment Association, California Southern Cities
Apartment Association of Greater Los Angeles
Apartment Association of Orange County
East Bay Rental Housing Association
North Valley Property Owners Association
San Diego County Apartment Association
Santa Barbara Rental Property Association
Western Manufactured Housing Communities Association
Opposition
AIDS Legal Referral Panel (ALRP)
AB 2312
Page 19
California Rural Legal Assistance Foundation
Central California Legal Services, Inc. (CCLS)
Centro Legal de la Raza
City of Santa Monica
Clergy and Laity United for Economic Justice (CLUE)
Community Legal Services in East Palo Alto
Disability Rights California
East Bay Community Law Center
Eviction Defense Network
Impact Fund
Law Foundation of Silicon Valley
Legal Aid Foundation of Los Angeles (LAFLA)
Legal Aid Society of San Diego
AB 2312
Page 20
Legal Services of Northern California
National Housing Law Project
Tenants Together
Western Center on Law & Poverty (WCLP)
Women Organizing Resources, Knowledge, and Services (WORKS)
Analysis Prepared by:Anthony Lew / JUD. / (916) 319-2334