BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                    AB 2391


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          Date of Hearing:  April 12, 2016


                           ASSEMBLY COMMITTEE ON JUDICIARY


                                  Mark Stone, Chair


          AB 2391  
          (Steinorth) - As Amended March 30, 2016


          SUBJECT:  RESIDENTIAL PROPERTY:  POSSESSION BY DECLARATION


          KEY ISSUE:  should a controversial pilot program that may impair  
          the due process rights of occupants in foreclosed homes be  
          expanded geographically and extended until 2020, despite the  
          fact that the program has only been in effect for 15 months out  
          of an intended 36 month pilot period and no evaluation has been  
          made of its effectiveness or impact?


                                      SYNOPSIS


          In 2014, the Legislature approved and the Governor signed AB  
          1513 (Fox), Ch. 666, Stats. 2014, which provided temporary  
          authority to owners of residential property in three California  
          cities to declare their property to be vacant, register it with  
          local law enforcement, and obtain a TRO against any person not  
          authorized to be on the property.  This bill seeks to extend  
          authorization for this temporary pilot program by two years,  
          until January 1, 2020, and to expand authorization for the pilot  
          program to include the County of San Bernardino and any city  
          within the County of San Bernardino that adopts an ordinance or  
          resolution to participate and comply with the pilot program.   
          Proponents of the bill, including the Realtors and the  








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          California Apartment Association, contend that, other than this  
          pilot program, the only process available today for property  
          owners to remove a squatter from residential property is the  
          formal court eviction (unlawful detainer) process, which can  
          take months to complete and does not allow the owner to take  
          immediate possession of the premises.  The bill is opposed by  
          tenant advocates who contend that the court eviction process-a  
          summary expedited proceeding-- is indeed the best way for a  
          property owner to regain possession of the property while also  
          allowing a tenant who claims a legal right to possess the  
          property to have his or her claim decided by a court on its  
          merits-thereby ensuring due process for both parties.  Opponents  
          emphasize that due process protections are particularly  
          important here, where the author seeks to expand the AB 1513  
          pilot program to areas containing so many residential properties  
          that have gone through foreclosure, because of a history of  
          post-foreclosure owners improperly treating legitimate tenants  
          as "squatters" or otherwise unauthorized occupants of the  
          property.  Opponents note that the Legislature in 2012 passed AB  
          2610, part of the Homeowners' Bill of Rights, to protect  
          innocent tenants in foreclosed homes (i.e. typically tenants who  
          paid their rent every month but whose landlord defaulted on the  
          mortgage payments) from being removed from their homes without  
          due process and judicial review.  They strongly oppose this bill  
          on the ground that it would allow property owners to undermine  
          or circumvent the very protections established by the  
          Legislature in the HBOR.  In addition to the concerns expressed  
          about this bill's impact on tenants in foreclosed homes, the  
          Committee's own analysis of the pilot program provisions, as  
          well as a review of the legislative history of the program,  
          reveal a number of other due process and workability concerns  
          about the program that have never been addressed.  For these  
          reasons, it appears that it is premature to expand and extend  
          authorization of the AB 1513 pilot program, prior to any  
          meaningful evaluation of its operation and impact.


          SUMMARY:  Expands participation of cities in a residential  
          property pilot program and renews program authorization for an  








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          additional two years, until 2020.  Specifically, this bill:   


          1)Expands authorization for the CCP Section 527.11 pilot program  
            to include the County of San Bernardino and any city within  
            the County of San Bernardino, provided that the city or county  
            has adopted an ordinance or resolution indicating the intent  
            of the city or county to participate and comply with the  
            program requirements.


          2)Provides that the County of San Bernardino or any  
            participating city within the county may withdraw its  
            participation at any time by adopting a subsequent ordinance  
            or resolution of the legislative body indicating the intent of  
            the city or county to withdraw its participation.


          3)Extends authorization for the pilot program an additional two  
            years by extending the sunset date from January 1, 2018 to  
            January 1, 2020.


          EXISTING LAW:   


          1)Provides the statutory requirements for unlawful detainer, a  
            summary proceeding the primary purpose of which is to  
            determine right to possession of real property.  (Code of  
            Civil Procedure Section 1161 et seq.  All further references  
            are to this code unless otherwise stated.)
          2)Provides that a former owner of a foreclosed property who  
            holds over and remains in the property after it has been sold  
            through foreclosure may be removed after a three-day notice to  
            quit has been served.  (Section 1161a.) 


          3)Requires a tenant or subtenant in possession of a rental  
            housing unit under a month-to-month lease or periodic tenancy  








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            at the time the property is sold in foreclosure to be given 90  
            days' written notice to quit before the tenant or subtenant  
            may be removed from the property as prescribed.  (Section  
            1161b, subd. (a).)


          4)Provides that the purchaser or successor in interest shall  
            bear the burden of proof in establishing that tenants or  
            subtenants holding possession of a rental housing unit under a  
            fixed-term residential lease entered into before transfer of  
            title at the foreclosure sale do not have the right to  
            possession until the end of the lease term.  (Section 1161b,  
            (b)-(c).)


          5)Provides that every person other than a public officer or  
            employee acting within the course and scope of his or her  
            employment in performance of a duty imposed by law, who enters  
            or remains in any noncommercial dwelling house, apartment, or  
            other residential place without consent of the owner, his or  
            her agent, or the person in lawful possession thereof, is  
            guilty of a misdemeanor.  (Penal Code Section 602.5 (a).)


          6)Establishes, until January 1, 2018, a pilot program to  
            facilitate removal of persons unlawfully occupying residential  
            property that, pursuant to the program, has been registered  
            with and verified by local law enforcement to be vacant.  This  
            program:


             a)   Authorizes the owner of vacant real property, or his or  
               her agent, to register vacant property with the local  
               police agency using a specified form, signed under penalty  
               of perjury, and attesting that the property is vacant and  
               is not authorized to be occupied by any person.  (Section  
               527.11 (a).)










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             b)   Authorizes the owner or his or her agent to execute a  
               "Declaration of Ownership," worded as specified or in  
               substantially similar language, and file it with the  
               appropriate local law enforcement agency where the property  
               is located.  (Section 527.12.)


             c)   Requires a licensed private security services company or  
               police agency retained by the owner or owner's agent  
               pursuant to the pilot program to inspect the vacant  
               property not less than once every three days, and  
               immediately notify the police agency where the property is  
               registered if any unauthorized person is found on the  
               property.  (Section 527.11 (e).) 


             d)   Requires the police agency where the property is  
               registered to respond to the property as soon as  
               practicable after being notified by the licensed security  
               business that an unauthorized person is found on the  
               property, and requires the responding officer to take  
               action, as specified.  (Section 527.11 (f).)


             e)   Authorizes the owner to file an action for a temporary  
               restraining order (TRO) and injunctive relief against any  
               person found on the vacant property not less than 48 hours  
               after that person has been notified by local law  
               enforcement to produce written authorization to be on the  
               property or other evidence demonstrating right to  
               possession, or face arrest. Allows the court to order a  
               hearing on a TRO within three days following service of the  
               summons and complaint, and to grant a TRO including an  
               order directing that the property be vacated in not less  
               than 48 hours.  (Section 527.11 (g).)


             f)   Limits application of these provisions to residential  
               property consisting of one to four units, located in the  








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               cities of Palmdale and Lancaster, in Los Angeles County,  
               and the city of Ukiah, in Mendocino County.  (Section  
               527.11 (k).)


          FISCAL EFFECT:  As currently in print this bill is keyed fiscal.


          COMMENTS:  In 2014, the Legislature approved and the Governor  
          signed AB 1513 (Fox), Ch. 666, Stats. 2014, which provided  
          temporary authority to owners of residential property in three  
          California cities to declare their property to be vacant,  
          register it with local law enforcement, and obtain a TRO against  
          any person not authorized to be on the property.  This bill  
          seeks to extend the operation of this temporary pilot program by  
          two years, until January 1, 2020, and expand authorization for  
          the pilot program to include the County of San Bernardino and  
          any city within the County of San Bernardino, provided that the  
          city or county has adopted an ordinance or resolution indicating  
          its intent to participate in and comply with program  
          requirements.  According to the author, expansion of the program  
          is needed because:


               Cities and counties across the state are grappling with  
               the ongoing issue of how to deal with unauthorized  
               tenants occupying vacant properties. There have been  
               numerous stories from around the state in recent years  
               detailing the vandalism and even burning down of vacant  
               property occupied by "squatters." Existing law does not  
               provide a direct method for evicting squatters, making it  
               very difficult and time-consuming to quickly control the  
               issue. 


               In response, California enacted AB 1513 (Fox) in 2014 to  
               create a pilot program that allowed the cities of  
               Palmdale, Lancaster, and Ukiah to utilize an expedited  
               process for inspecting for and removing squatters from  








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               vacant property. The program is set to expire after next  
               year, and is very restrictive geographically, leaving  
               many communities' safety at risk.


          Background on AB 1513 pilot program.  According to the intent  
          language of AB 1513, the pilot program was intended to provide a  
          means to prevent squatting in vacant residential property and to  
          provide a timely and orderly procedure for squatters to vacate  
          the premises in lieu of arrest, and is not intended to be an  
          abridgment of other statutes relating to trespass or civil  
          eviction proceedings.  


          As enacted under CCP Section 527.11, the property owner  
          registering the property under the pilot program must provide a  
          phone number where he or she can be reached within a 24-hour  
          period, which is intended to enable law enforcement to quickly  
          contact the owner should unauthorized occupants ever be  
          discovered on the property during one of the regular inspections  
          required under the program.  In addition, the owner must retain  
          either law enforcement or a private security service to  
          regularly inspect the vacant property, and provide a copy of the  
          contract or agreement to perform those services at the time of  
          registration.  The security company or law enforcement agent  
          must then inspect the vacant property at least every three days  
          to ensure that it is vacant.


          Under the program, law enforcement is required to respond in a  
          timely manner after being notified that an unauthorized person  
          is found on the property.  Law enforcement personnel responding  
          to a first call shall not arrest the person for trespass, but  
          must instead advise the person that he or she is required to  
          produce written authorization from the owner to be on the  
          property or other evidence demonstrating his or her right to  
          possession, or the owner may seek to obtain a TRO and the person  
          may be subject to arrest for trespass if subsequently found on  
          the property in violation of the order.  








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          An owner of vacant real property may file an action for a  
          temporary restraining order and injunctive relief against any  
          person who is found on the property 48 hours or more after that  
          person has been notified by local law enforcement to produce  
          written authorization from the owner to be on the property or  
          other evidence demonstrating right to possession.  Without  
          either being produced, that person subsequently may face arrest  
          for trespass, pursuant to Penal Code Section 602.5, for failing  
          to vacate the property pursuant to the TRO, and may therefore be  
          subject to a criminal penalty of imprisonment in the county jail  
          for up to one year and a fine of up to $1,000, or both.


          Numerous due process concerns remain with the provisions  
          expanded by this bill, particularly with respect to tenants in  
          foreclosed homes.   According to the author of AB 1513, the  
          reason for the bill is to address a district-wide epidemic of  
          "squatting" (i.e. people occupying vacant residential properties  
          without permission of the owner).  The author asserted that the  
          primary reason for the high number of vacant properties ripe for  
          squatting is the foreclosure crisis of the past ten years has  
          resulted in a large number of bank-owned foreclosure properties  
          in the district.  According to the author of this bill, local  
          governments in his district are interested in expanding this  
          pilot program to San Bernardino County, where not coincidentally  
          there are a large number of vacant homes due to the foreclosure  
          crisis. (According to figures compiled by RealtyTrac, for  
          example, in May 2012 the Riverside-San Bernardino metropolitan  
          area posted the highest foreclosure rate among the country's 20  
          largest metropolitan areas-more than 3.5 times the national  
          average.)


          The bill is supported by the District Attorney from San  
          Bernardino County, the California Association of Realtors, and  
          the California Apartment Association (CAA), among others.  In  
          support of the bill, CAA states:








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               The current statute extended and expanded by AB 2391 is  
               a fair and equitable process for the removal of  
               squatters from property.  The law gives property owners  
               the ability to execute a written form and file that  
               with the district attorney, therein declaring that the  
               property owner has authorized no one to occupy the  
               property.  Law enforcement is required to enforce the  
               declaration as an order for immediate possession of the  
               premises.  Unfortunately, the only process available  
               today for property owners to remove a squatter is the  
               formal court eviction process.  That process can take  
               months to complete, all the while the squatter is  
               living illegally at the property and in many cases  
               damaging the premises.


          The legislative history of AB 1513 reveals many concerns  
          expressed about whether the pilot program affords sufficient due  
          process to persons who are alleged by a property owners to be  
          unauthorized occupants of the property.  (See, e.g. Assembly  
          Judiciary Committee analysis (April 29, 2014) and Senate Public  
          Safety Committee analysis (June 24, 2014)).  Opponents of this  
          bill continue to be concerned that the pilot program, sought to  
          be expanded by AB 2391 without any additional protections, does  
          not provide sufficient due process, especially with respect to  
          the occupants of foreclosed homes.  As the Western Center on Law  
          and Poverty explains:


               The problem with the policy in AB 2391 is that it puts  
               innocent tenants at risk of being summarily removed  
               from property, despite a legitimate claim to  
               possession. In the foreclosure crisis that followed  
               the collapse of the nation's housing market, legal  
               services attorneys represented thousands of lawful  
               tenants of landlords that had lost properties in  
               foreclosure.  The foreclosing entity or its agents  








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               commonly regarded anyone in the property  
               post-foreclosure as trespassers, despite the tenants'  
               statutory and contractual rights to remain on the  
               premises. Tenants' rights to a termination notice and  
               a hearing in court through the normal unlawful  
               detainer process were routinely ignored. 


               The policy in AB 2391 reinforces this erroneous notion  
               that a person inhabiting a foreclosed home must be  
               there unlawfully, and we fear that it will be abused  
               as an end-run around the unlawful detainer process.  
               Stripping tenants of legal protections is unwise  
               policy, particularly in light of California's housing  
               crisis


          Tenants Together, a statewide organization for renters' rights,  
          contends that the current pilot program should not be expanded  
          or extended because it runs contrary to the recently enacted  
          Homeowners' Bill of Rights (HBOR), which included reforms  
          intended to protect tenants in foreclosed properties.  They  
          state:


               Tenants Together operates a renters' rights hotline  
               through which we have counseled over 8,000 tenant  
               households since 2009.  We regularly receive calls from  
               legitimate tenants being falsely accused of being  
               unauthorized occupants.  Whether because of ignorance or  
               bad faith, many owners, particularly after foreclosure,  
               treat tenants as if they are trespassers despite the fact  
               that rental agreements run with the land and verbal  
               rental agreements are fully enforceable and legitimate in  
               California.  These new owners threaten to call, and in  
               some cases call, the police or sheriff to have tenants  
               arrested or otherwise removed as trespassers.  Giving  
               these owners an additional tool for summary removal would  
               be extremely harmful.








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               For years, post-foreclosure owners blatantly violated  
               tenants' rights by improperly treating tenants as  
               "unknown occupants," utilizing a loophole in state law  
               that was recently addressed by the tenant protections  
               in the Homeowner Bill of Rights (HBOR). HBOR allows any  
               tenant in the property unnamed in an unlawful detainer  
               action to file a claim of right to possession at any  
               time to get a hearing to determine whether the tenant  
               can become a party to the eviction action. CCP  
               415.46(e)(2). By allowing owners to circumvent the  
               entire court eviction process when the right to occupy  
               is disputed, the current proposal would undermine the  
               very protections the legislature just adopted in HBOR.


          With respect to due process concerns expressed by opponents, the  
          author contends that the pilot program sought to be expanded by  
          this bill "has a thorough set of requirements in order to  
          accomplish (due process)" and further states that:


               This concern is mitigated by the fact that the property  
               owner (or their agent) and the law enforcement agency  
               or security service must follow a rigorous process to  
               assure that the property is supposed to be vacant. The  
               owner (or their agent) must declare and demonstrate  
               that the property is vacant, under penalty of perjury.  
               Law enforcement must follow a regular inspection  
               protocol. Upon discovery, law enforcement must provide  
               notification to anyone they discover on the property  
               that they are subject to arrest for trespassing or  
               removal after 48 hours if they cannot provide evidence  
               that they have a right to be on the property. Finally,  
               the court has the discretion to not grant the owner's  
               request for a temporary restraining order or injunctive  
               relief if they do not believe it is merited. 









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          Despite the requirements cited by the author as examples of due  
          process protections built into operation of the AB 1513 pilot  
          program, it appears that the pilot program still provides less  
          due process to a tenant in a foreclosed property who may have a  
          legitimate right to possession under the HBOR, than is afforded  
          under the existing unlawful detainer proceeding that has  
          traditionally allowed property owners to regain possession of  
          property from trespassers or unauthorized occupants.  As the  
          Senate Public Safety committee analysis (June 24, 2014)  
          explains, there is some reason to question whether the program  
          requirements cited by the author are sufficient to ensure  
          adequate due process:


               The foreclosure crisis has created circumstances where  
               ownership and rental tenancy of property may be  
                        difficult to determine.  A person in possession of  
               property - perhaps a person who believes that he or she  
               still owns the property - might even have difficulty  
               determining the person or entity to contact for  
               questions about the status of the property.  A person  
               subject to ejectment and a misdemeanor conviction for  
               failure to leave property within 48 hours after notice  
               could be a legitimate tenant or reasonably believe that  
               he or she is validly in possession of the property.   
               While the bill provides that a person in possession of  
               property shall not be arrested for trespass if he or she  
               presents written authorization from the owner, the bill  
               does not provide a method for the police or the courts  
               to resolve conflicting claims of ownership or  
               authorization.  The person in possession could have a  
               lease from a former owner.  The new owner of a  
               foreclosed residence might have no knowledge of a lease  
               between the former owner and the tenant.  Further, the  
               person in possession may have been a victim of a sham  
               rental from a person pretending to be the owner of the  
               property.  This has occurred often enough on foreclosed  
               properties that former Assembly Member Fiona Ma authored  








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               a bill that raised penalties for sham rentals. (citing  
               AB 1800 (Ma), Ch. 531, Stats. 2010.)


               [. . . ]  


               The lack of a clearly defined defense to trespass  
               through later establishing the right to be on the  
               property could be particularly problematic where the  
               owner of the property is a large bank or mortgage  
               company and the alleged trespasser is the former owner  
               of the house.  The person may have received oral  
               authority to temporarily remain in the house from one  
               department or person at a company, but this authority or  
               permission was not conveyed to another department that  
               prepares foreclosure properties for sale.  It could take  
               a person some time to document his or her authority.   


          For these reasons, the Committee may wish to consider whether it  
          is appropriate to expand the AB 1513 pilot program to San  
          Bernardino or other areas where its application would appear to  
          impair the due process rights of tenants in foreclosed  
          properties, including those established recently through passage  
          of the Homeowners' Bill of Rights.


          This bill seeks to expand and renew the pilot program  
          prematurely, prior to any real evaluation of its operation and  
          impact.  In part because of due process concerns with the  
          original legislation, it should be noted that the Legislature  
          only approved AB 1513 for a three year period, establishing a  
          January 1, 2018 sunset date, and further limited its application  
          to residential property of one to four units, in the Cities of  
          Palmdale, Lancaster, and Ukiah.  


          In response to concerns that it may be premature to expand the  








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          AB 1513 program at this time, the author states that "the  
          program has been in law for over a year, and will have been in  
          effect for two years by the time this bill would become  
          effective."  The author also contends there have been no known  
          issues with it in that time, and states that the Ukiah Police  
          Department indicated that they would like to retain the  
          authority to use the program going forward. 


          The Committee notes that the AB 1513 program became effective on  
          January 1, 2015, and is set to sunset 36 months later, on  
          January 1, 2018.  At the time this Committee is being asked to  
          vote to approve expansion and reauthorization of the program,  
          the program has only been in effect for 15 months out of the 36  
          months during which it was intended by the Legislature to  
          operate.  When AB 205 (Wood), a bill that similarly sought to  
          expand this pilot program, was in this Committee in March 2015,  
          the Committee's preliminary outreach to officials in Lancaster  
          and Palmdale revealed that the program was still largely unknown  
          to the public, and local implementation of the registration and  
          other requirements was still in progress.  (AB 205 was not  
          pursued by its author in April 2015 at its first hearing, nor in  
          January 2016, when it was eligible to be moved forward as a  
          two-year bill.)


          With respect to the existence of "no known issues" with the  
          bill, that may simply reflect the difficulty in ascertaining any  
          reliable, empirical information about program implementation to  
          date.  When AB 1513 was in this Committee, the author declined  
          to take amendments that would have greatly aided the Legislature  
          in conducting evaluation and oversight of the program--namely,  
          amendments specifying key reporting requirements by cities  
          participating in the program, similar to those that apply to  
          cities participating in the ongoing weapon and drug nuisance  
          eviction pilot program.  (See Civil Code Sections 3485(g) and  
          3486.5(b).)  Because AB 1513 was considered primarily to be a  
          stopgap measure to address a crisis associated with vacant  
          properties in the author's district, the bill was allowed to  








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          proceed with a three-year sunset date with the understanding  
          that it would not be expanded beyond the initial set of  
          participating cities, particularly because the bill did not help  
          facilitate the Legislature's evaluation of its operation or its  
          impact upon residents who might be adversely affected.


          At the time of this analysis, the Committee had received no  
          information about how many property owners have elected to  
          register their properties with local law enforcement under the  
          program, so it is not even known what the universe of cases is  
          where the program can be said to have worked properly or  
          improperly.  Furthermore, the definition of what constitutes an  
          "issue" with the program is subjective, as is what constitutes  
          "success".  Proponents indicate that they would consider it a  
          success if the program helped expedite the removal of  
          "squatters" from vacant property.  However, opponents point out  
          that without being able to evaluate whether the person removed  
          actually had a legal right to occupy the property, the simple  
          fact that the person in question is no longer occupying the  
          property cannot be considered a measure of success.  What if the  
          person did not receive the due process that he or she was  
          entitled to under the circumstances, but the person elected to  
          vacate the property rather than face possible arrest or  
          retaliation?  What if, for the sake of argument, no homeowners  
          in an entire city elected to register their properties through  
          the program?  Would the lack of "issues" somehow make that a  
          program worth expanding and extending to other cities?  Or would  
          it indicate that perhaps property owners themselves do not find  
          the pilot program worthy of participation?


          Additional due process and workability questions remain  
          unanswered.  The Senate Public Safety committee analysis (June  
          24, 2014) raised additional due process and workability  
          questions about the current pilot program that were not  
          addressed by subsequent amendments to AB 1513, but remain  
          concerning to the present day.  Among these questions are:









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          1)What constitutes "inspection" of the property - to verify that  
            the property is vacant, such that any persons later found on  
            the property are trespassers?


          2)What happens in cases where ownership - perhaps by a large  
            bank or mortgage company - is unclear?


          3)Is a person still guilty of a misdemeanor for failure to leave  
            property within 48 hours, if the person later establishes that  
            he or she owns or leases the property, or has permission to be  
            on the property?


          4)In the misdemeanor defined by this bill for failure to vacate  
            residential property, should the prosecution have to prove as  
            an element of the offense that a defendant did not have the  
            right to occupy the property?


          5)Should a defendant have the right to an affirmative defense  
            that he or she had a reasonable belief in his or her right to  
            occupy the property?


          6)Would prosecutors have difficulty obtaining perjury  
            convictions for fraudulent or questionable claims of  
            ownership?


          Until these questions are answered, the Committee may conclude  
          that it does not have enough information about the program to  
          judge its merit as it was originally conceived to operate for a  
          limited period in a limited area and certainly not enough  
          information to consider expanding it to operate for a longer  
          period of time in a larger area. 









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          REGISTERED SUPPORT / OPPOSITION:




          Support


          California Apartment Association


          California Association of Realtors


          California Police Chiefs Association


          San Bernardino County, Office of the District Attorney




          Opposition


          California Rural Legal Assistance Foundation


          Tenants Together


          Western Center on Law and Poverty




          Analysis Prepared by:Anthony Lew / JUD. / (916) 319-2334









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