BILL ANALYSIS Ó SB 124 Page 1 Date of Hearing: June 30, 2015 Counsel: Stella Choe ASSEMBLY COMMITTEE ON PUBLIC SAFETY Bill Quirk, Chair SB 124 (Leno) - As Amended June 1, 2015 As Proposed to be Amended in Commitee SUMMARY: Establishes standards and protocols for the placement of juvenile offenders in solitary confinement. Specifically, this bill: SB 124 Page 2 1)Prohibits the use of solitary confinement on a person confined in a juvenile facility who is an imminent danger to himself, herself, or others as a result of a mental disorder or who is gravely disabled. 2)Provides that a person confined in any secure state or local juvenile facility, and who is not an imminent danger to himself, herself, or others as a result of a mental disorder or who is gravely disabled, shall be subject to solitary confinement only if all of the following are true: a) The person poses an immediate and substantial risk of harm to the security of the facility, to himself or herself, or to others that is not the result of a mental disorder; b) All other less-restrictive options to address the risk have been attempted and exhausted; c) The performance of solitary confinement is done in accordance with the following principles: i) The person may be held in solitary confinement only for the minimum time required to address the risk, and for a period of time that does not compromise the mental and physical health of the minor or ward, but not to exceed four hours. The person shall be returned to regular programming or placed in individualized programming that does not involve solitary confinement; SB 124 Page 3 ii) If a person who is released from solitary confinement and is returned to regular or individualized programming poses an immediate and substantial risk of harm to himself or herself, or others, he or she may be placed back into solitary confinement only under the standards and protocols in this bill; iii) If a person in solitary confinement poses a risk of harm to himself or herself that is not the result of a mental disorder, the condition shall be monitored closely by custody staff of the juvenile facility; and, iv) Consecutive periods of solitary confinement in excess of four hours shall be prohibited. 3)Prohibits the use of solitary confinement for the purposes of discipline, punishment, coercion, or retaliation by staff. 4)Requires each local and state juvenile facility to document the usage of solitary confinement for each incident when solitary confinement is used, including all of the following: a) The name, age, gender and race of the person subject to solitary confinement; b) The date and time the person was placed in solitary confinement; c) The date and time the person was released from solitary SB 124 Page 4 confinement; d) The name and position of the person authorizing the placement of the person in solitary confinement; e) The names of staff involved in the incident leading to the use of solitary confinement; f) A description of circumstances leading to use of solitary confinement; g) A description of alternative actions and sanctions attempted and found unsuccessful; and, h) The dates and times when staff checked in on the person when he or she was in solitary confinement, and the person's behavior during the check. 5)States that the records created as documentation of each solitary confinement incident and voluntary time outs shall be available for public inspection pursuant to the California Public Records Act. 6)Provides that if a state or local juvenile facility currently documents the usage of solitary confinement consistent with the requirement in this bill, then duplicative documentation shall not be required. SB 124 Page 5 7)Allows a person confined in a juvenile facility to request a voluntary time out, as defined, for no longer than two hours. During any voluntary time out, the person must participate in all programming and meals. The person may end his or her voluntary time out at any point upon notifying a staff member. Voluntary time outs must be documented and include the name of the person requesting the time out, his or her signature, when the voluntary time out began and when it ended. 8)Clarifies that this bill's provisions are not intended to limit the use of single-person rooms or cells for the housing of persons in juvenile facilities. 9)Defines the following terms: a) "Juvenile facility" includes any of the following: i) A juvenile hall; ii) A juvenile camp or ranch; iii) A facility of the Department of Corrections and Rehabilitation (CDCR), Division of Juvenile Facilities (DJJ); iv) A regional youth educational facility; SB 124 Page 6 v) A youth correctional center; or, vi) Any other local or state facility used for the confinement of minors or wards. b) "Minor" means a person who is any of the following: i) A person under 18 years of age; ii) A person under the maximum age of juvenile court jurisdiction who is confined in a juvenile facility; or, iii) A person under the jurisdiction of CDCR, DJJ. c) "Solitary confinement" means the placement of an incarcerated person in a locked sleep room or cell alone with minimal or no contact with persons other than guards, correctional facility staff, and attorneys. Solitary confinement does not include confinement of a person in a single-person room or cell for brief periods of locked-room confinement necessary for required institutional operations, including, but not limited to, shift changes, showering, unit movements, or protection against communicable diseases. SB 124 Page 7 d) "Ward" means a person who has been declared a ward of the court as provided. e) "Voluntary time out" means a brief period of time in a sleep room or cell at the written and signed request of the person confined in a juvenile facility. 10)Changes to the composition of local juvenile justice commissions to require two or more of the members to be parents or guardians of previously incarcerated youth and one member to be a licensed psychiatrist, licensed psychologist, or licensed clinical social worker with expertise in adolescent development. 11)Adds two members to the regional juvenile justice commissions and requires two or more of the members to be parents or guardians of previously incarcerated youth and one member to be a licensed psychiatrist, licensed psychologist, or licensed clinical social worker with expertise in adolescent development. 12)Requires a juvenile justice commission, as a part of its inspection of jails, lock ups and facilities used for confinement, to review records relating to the use of solitary confinement, as defined. 13)Requires a juvenile justice commission to report the results of its inspection and its recommendations to the county board of supervisors, in addition to the juvenile court and the Board of State and Community Corrections. SB 124 Page 8 14)States that the report shall be presented annually as part of a regularly scheduled public meeting of the county board of supervisors, and may be published on the county government's Internet Web site. 15)States the Legislative finding that in order to protect the privacy and medical information of persons confined in secure state and local juvenile facilities and held in solitary confinement, it is necessary that identifying information about those persons be kept confidential, thus justifying exemption of this information from disclosure under the California Public Records Act. EXISTING LAW: 1)States that the purpose of the juvenile court system is to provide for the protection and safety of the public and each minor under the jurisdiction of the juvenile court and to preserve and strengthen the minor's family ties whenever possible, removing the minor from the custody of his or her parents only when necessary for his or her welfare or for the safety and protection of the public. (Welf. & Inst. Code, § 202, subd. (a).) 2)Provides that minors under the jurisdiction of the juvenile court as a consequence of delinquent conduct shall, in SB 124 Page 9 conformity with the interests of public safety and protection, receive care, treatment, and guidance that is consistent with their best interest, that holds them accountable for their behavior, and that is appropriate for their circumstances. (Welf. & Inst. Code, § 202, subd. (b).) 3)Authorizes minors under the age of 18 years to be adjudged to be a ward of the court for violating any law of this state or of the United States or any ordinance of any city or county of this state defining crime, as specified. (Welf. & Inst. Code, § 602.) 4)Provides that when a minor is adjudged a ward of the court on the ground that he or she is delinquent, the court may make any and all reasonable orders for the care, supervision, custody, conduct, maintenance, and support of the minor, including medical treatment, subject to further order of the court, as specified. (Welf. & Inst. Code, § 727, subd. (a).) 5)Existing law authorizes the court to place a ward of the court in a juvenile hall, ranch, camp, forestry camp, secure juvenile home, or the Division of Juvenile Facilities, as specified. (Welf. & Inst. Code, § 726.) 6)Requires the Board of State and Community Corrections (BSCC) to adopt minimum standards for the operation and maintenance of juvenile halls for the confinement of minors. (Welf. & Inst. Code, §210.) 7)Provides that in each county there shall be a juvenile justice commission consisting of not less than seven and no more than 15 citizens. Two or more of the members shall be persons who are between 14 and 21 years of age, provided there are SB 124 Page 10 available persons between 14 and 21 years of age who are able to carry out the duties of a commission member in a manner satisfactory to the appointing authority. (Welf. & Inst. Code, § 225) 8)Authorizes, in lieu of a county juvenile justice commission, the boards of supervisors of two or more adjacent counties to agree to establish a regional juvenile justice commission consisting of at least 8 citizens, two of whom to be between 14 and 21 years of age if available, and having a sufficient number of members so that their appointment may be equally apportioned between the participating counties. (Welf. & Inst. Code, § 226.) 9)States that it shall be the duty of a juvenile justice commission to inquire into the administration of the juvenile court law in the county or region in which the commission serves. For this purpose the commission shall have access to all publicly administered institutions authorized or whose use is authorized by this chapter situated in the county or region, shall inspect such institutions no less frequently than once a year, and may hold hearings. A judge of the juvenile court shall have the power to issue subpoenas requiring attendance and testimony of witnesses and production of papers at hearings of the commission. A juvenile justice commission shall annually inspect any jail or lockup within the county that was used to confine a minor for more than 24 hours in the preceding calendar year and issue a written report of the results of such inspection together with its recommendations to the juvenile court and to the Board of Corrections. (Welf. & Inst. Code, § 229.) SB 124 Page 11 FISCAL EFFECT: Unknown. COMMENTS: 1)Author's Statement: According to the author, "Solitary confinement is an extremely harmful measure, widely condemned as torture, but unfortunately it is one that continues to be used in the California juvenile justice system under various programmatic titles. Solitary confinement has not been shown to have any rehabilitative or treatment value, and the United Nations has called upon all member countries to ban its use completely on minors. It is a practice that endangers mental health and increases risk of suicide, and is often used as a method to control a correctional environment, and not for any rehabilitative purpose. It does not properly address disciplinary issues and more often, it increases these behaviors in youth, especially those with mental health conditions. In 1999, the Office of Juvenile Justice and Delinquency Prevention (OJJDP) released a study of juvenile facilities across the country which found that 50% of youth who committed suicide where in solitary confinement at the time of their suicide. Further, 62% of the suicide victims had a history of isolation. "SB 124 does not ban the use of solitary confinement completely as many other jurisdictions in the world have done, it merely limits the use of solitary to instances where there is an actual threat to the safety of staff, other youth, or the general security of the facility. This bill sets a reasonable statewide baseline to protect youth, and it is long overdue. California is now behind 20 other states in banning punitive solitary confinement for youth, it is time that we SB 124 Page 12 create a statewide policy governing this practice in order to provide a safer environment for youth and staff, better rehabilitative outcomes for youth, and protection for our counties against costly and damaging lawsuits stemming from the overuse of solitary confinement." 2)Background: According to the background materials provided by the author, "Title 15 regulations fail to provide specific guidelines around the use of solitary confinement, oftentimes used interchangeably with terms like 'separation.' Title 15 charges facility administrators to develop written policies and procedures regarding the use of separation, but does not provide additional guidance or limitations except that 'separated youth shall not be denied normal privileges at the facility, except when necessary to accomplish the objectives of separation.' Some juvenile corrections officials have denied that they use solitary confinement because the practice of isolating youth from 21-23 hours a day, for weeks and months at a time, exists under different definitions and programmatic titles in California's juvenile facilities. "The use of solitary confinement is clearly documented in both state and local juvenile facilities. Despite a longstanding consent decree in effect since 2004, an internal CDCR audit found continuing abuses in the Division of Juvenile Facilities as late as 2011, including youth locked up in their cells for more than 23 hours a day. Additionally, in a recent 2014 report released by Barry Krisberg of the Warren Institute at UC Berkeley, youth in the most restrictive current program at DJJ known as the "Behavior Treatment Program," were required to receive only 3 hours outside of their cell, and were typically there for approximately 60 days. Despite some improvements in state conditions since the 2011 audit, California cannot rely solely on a temporary consent decree, and it is critical that statutory definitions and parameters on the use of isolation be established going forward. At the local level, the abuse of solitary confinement has been alarming. A federal class-action lawsuit has been filed against Contra Costa's juvenile hall for youth with SB 124 Page 13 disabilities who were placed in solitary confinement and denied education as a punishment. That case was recently settled by the county, and the conditions of the settlement are nearly identical to the provisions of SB 124, clearly demonstrating that the parameters established in the bill can be implemented at the county level. [Footnotes omitted.]" 3)Consent-Decree: Farrell v. Cate: Historically, the use of solitary confinement in DJJ, formerly the California Youth Authority (CYA), has posed significant issues and concerns. In 2003 two mental-health experts conducted a study and reported on the CYA's programs and services. (See Eric Trubin & Raymond Patterson, Report of Findings of Mental Health and Substance Abuse Treatment Services to Youth in California Youth Authority Facilities (Dec. 2003).) According to the report, "[w]ards . . . spend vast amounts of time alone in their cells, a practice that extends not just to those being punished in lockup, but also to those on suicide watch. Isolating individuals with mental-health issues can exacerbate their problems. When wards do attempt suicide, their punishment is often isolation and restriction to cells for days at a time. Once isolated, these wards are monitored via camera while sequestered in rooms that are often dirty and sometimes contain fixtures that can be used to commit suicide. In four facilities, the minimal medical attention provided occurs while such wards are locked in cages. In one particularly unsettling account at the Chaderjian facility, a ward on suicide watch who had been diagnosed with severe depression, schizophrenia, and a personality disorder only received a five-minute visit with a psychiatrist each day." (Benvenue, Turning Troubled Teens Into Career Criminals: Can California Reform the System to Rehabilitate Its Youth Offenders? 38 Golden Gate U. L. Rev. (2007) pp. 48-49.) As part of comprehensive litigation involving conditions at CYA that commenced in 2003, Farrell v. Cate, CYA, now DJJ, is required to adopt reformed methods for dealing with containment or isolation of wards. (See Consent Decree, Farrell v. Allen (Super. Ct. Alameda County, 2004, No. RG SB 124 Page 14 03079344) < http://www.prisonlaw.com/pdfs/farrellcd2.pdf >; Defendant's Notice of Filing DJJ's Safety and Welfare Remedial Plan, Farrell v. Hickman (Super. Ct. Alameda County, 2006, No. RG 03079344) < http://www.prisonlaw.com/pdfs/SafetyPlanFinal.pdf >.) The consent decree requires the DJJ to provide wards with adequate and effective care, treatment and rehabilitation services, including reducing violence and the use of force, improving medical and mental health care, reducing the use of lock-ups and providing better education programs. The on-going case is overseen by a Special Master who issues quarterly reports. The most recent report, dated March 2015, is promising, showing that DJJ is making significant progress in reducing lengthy lock-ups of juveniles. This bill would enact minimum standards and protocol statewide for the use of solitary confinement of juveniles which would provide additional protections once the consent decree is lifted. 4)Regulations Pertaining to Juvenile Detention Facilities: The California Code of Regulations Title 15, Minimum Standards for Juvenile Facilities, provides guidelines on the isolation or separation of juveniles from the general population. "Separation" is defined in the regulations as limiting a youth's participation in regular programming for a specific purpose. Section 1354 of Title 15 requires the facility administrator to develop and implement written policies and procedures addressing the separation of youth for reasons that include, but are not be limited to, medical and mental health conditions, assaultive behavior, disciplinary consequences and protective custody. This section prohibits the denial of normal privileges available at the facility, except when necessary to accomplish the objective of separation. The policies and procedures shall ensure a daily review of separated youth to determine if separation remains necessary. SB 124 Page 15 Section 1359 of Title 15 requires the facility administrator, in cooperation with the responsible physician, to develop and implement written policies and procedures governing the use of "safety rooms." The section provides that the safety room shall be used to hold only those youth who present an immediate danger to themselves or others, who exhibit behavior which results in the destruction of property, or reveals the intent to cause self-inflicted physical harm. A safety room shall not be used for punishment or discipline, or as a substitute for treatment. This section specifies that the policies and procedures shall: (a) Include provisions for administration of necessary nutrition and fluids, access to a toilet, and suitable clothing to provide for privacy; (b) Provide for approval of the facility manager, or designee, before a youth is placed into a safety room; (c) Provide for continuous direct visual supervision and documentation of the youth's behavior and any staff interventions every 15 minutes, with actual time recorded; (d) Provide that the youth shall be evaluated by the facility manager, or designee, every four hours; (e) Provide for immediate medical assessment, where appropriate, or an assessment at the next daily sick call; (f) Provide that a youth shall be medically cleared for continued retention every 24 hours; (g) Provide that a mental health opinion is secured within 24 hours; and, (h) Provide a process for documenting the reason for placement, including attempts to use less restrictive means of control, and decisions to continue and end placement. SB 124 Page 16 Section 1390 provides, when separating the youth for disciplinary reasons, discipline shall be imposed at the least restrictive level which promotes the desired behavior and shall not include corporal punishment, group punishment, physical or psychological degradation. While the regulations provide some guidance on the use of solitary confinement on juveniles, there is no specified limit on how long a juvenile may be placed in isolation. This bill provides that juveniles may be placed in solitary confinement for four hours at a time as long as certain procedures and policies are met. 5)Contra Costa County Juvenile Hall Law Suit: Recently, Contra Costa County settled a pending lawsuit concerning its use of solitary confinement on juveniles. The lawsuit accused the county's Probation Department, which oversees the juvenile hall, of holding youth with disabilities in solitary confinement for weeks or months at a time, depriving them of education and allowing them to deteriorate mentally. (Lee, Contra Costa ending solitary confinement at juvenile hall, SF Gate (May 19, 2014).) According to the settlement documents, Probation will adopt standards which include prohibiting the use room confinement for discipline, punishment, or retaliation, and developing individualized programming for individuals with persistent behavior problems that threaten the safety of the youth or staff or the security of the facility. The settlement provides that a juvenile may be segregated in his or her room for no more than four hours and only if the juvenile's behavior threatens immediate harm to themselves or others. After the four hours, the juvenile must be removed from confinement and the staff must develop specialized individualized programming for the individual in coordination with the office of education, or assess whether the youth should be transported to a mental health facility. (Romney, Contra Costa County to End Solitary Confinement for Juveniles, Los Angeles Times (May SB 124 Page 17 19, 2014).) Similar to the settlement terms reached in the Contra Costa County case, this bill generally provides that solitary confinement shall not be used on juveniles unless the juvenile poses an immediate and substantial risk of harm to the security of the facility, to himself or herself, or to others that is not the result of a mental disorder. This bill provides that the person may be held in solitary confinement for the minimum time required to address the risk, and for a period of time that does not compromise the mental and physical health of the minor or ward. The period of time that the person is in solitary confinement shall not exceed four hours, and at release the person must be returned to regular programming or placed in individualized programming. Due to concerns by the opposition that four hours may be insufficient in some cases to deal with a person who continues to pose a threat to others, the author amended this bill to allow a juvenile to be placed back into solitary confinement if the staff determines that the person poses an immediate and substantial risk of harm to himself or others. 6)Proposed Amendments to be Adopted in Committee: This bill will be heard as proposed to be amended. The amendments clarify that the bill's provisions to allow for the separation of a juvenile for medical conditions and to allow a juvenile to ask for a "voluntary time out" with specified limitations. 7)Argument in Support: According to the Children's Defense Fund - California, a co-sponsor of this bill, "For over a decade, Los Angeles County has been plagued by litigation and a recently concluded Department of Justice oversight for abuse and problems inside its juvenile facilities. This has cost the county millions of dollars in legal fees and reform efforts. Throughout California, we have faced continuous litigation due to the unchecked use of solitary confinement: the 2004 Division of Juvenile Facilities consent decree ('Farrell lawsuit'); the 2008 San Joaquin County lawsuit where SB 124 Page 18 youth were in their cells 23 hours or more a day for as much as months on end; the 2009 Sacramento County consent decree for a serious of abuses including the illegal use of extreme isolation; the 2014 San Diego County suicide while in isolation lawsuit; and most recently, a federal class action lawsuit in Contra Costa County which ended in a settlement agreement to curb the widespread practice of solitary on youth with disabilities. "SB 124, if enacted, would create a uniform definition of solitary confinement consistent with national best practices and limit the use of solitary confinement to 4 hours. It would also create a uniform practice of documenting its use. "Already, states have enacted far-reaching measures to curb the use of solitary confinement. Several states, including Connecticut, Arizona, Maine, Oklahoma, West Virginia, Missouri, Alaska, New York and Texas, have outright prohibited solitary confinement for juveniles. In 2011, Colorado passed legislation limiting the use of isolation for its adult prisoners and required mental health assessments immediately prior to placement in solitary confinement, resulting in more than $25 million in annual savings. In 2012, Mississippi finalized a consent decree to prohibit minors tried as adults from being placed in solitary confinement. The time has come to limit the use of solitary confinement for juveniles in California." 8)Argument in Opposition: According to the Chief Probation Officers of California, "While we appreciate the amendments taken to this point, they do not go far enough in ensuring that the Chiefs will have the necessary tools available to them to discharge their duty and mission of protecting all the wards in their care. The bill fails to take into account a myriad of issues that are present in a facility on any given day that require probation to take action. Fundamentally, in some situations the provisions of this bill are either impossible to implement or implementation may cause harm to the very youth this bill is designed to protect. Chiefs stand SB 124 Page 19 behind ensuring best practices are put in place to operate our facilities in the safest manner for all those detained. "Ultimately, the broad definition that remains in the bill does not take into account all the types of situations we face daily. Placing a definition in statute instead of relying on a regulatory scheme that can account for a variety of circumstances creates operational hurdles that significantly limits probations ability to put into place best practices in response to the specific situation presented. For example, the definition does not account for cases in which the minor requests the time in their room alone or minors who are sick and prefer to rest in their room during the day. Further, there are instances where two youth get into a fight that results in both persons being a danger to themselves and others and, under the provisions of the bill as currently written, we are prohibited from temporarily confining one of the wards if they should have a mental health disorder, yet can do so with the other ward." 9)Prior Legislation: a) SB 61 (Yee), of the 2013-2014 Legislative Session, would have established standards and protocols for the use of solitary confinement of minors and wards in state and local juvenile facilities. SB 61 was ordered to the inactive file. b) SB 970 (Yee), of the 2013-2014 Legislative Session, would have generally prohibited a minor or ward who is detained in, or sentenced to, any juvenile facility or other secure state or local facility from being subject to solitary confinement, as defined, unless the minor or ward poses an immediate and substantial risk of harm to others or to the security of the facility, and all other less-restrictive options have been exhausted, and only in accordance with specified guidelines. SB 970 was never heard. SB 124 Page 20 c) SB 1363 (Yee), of the 2011-12 Legislative Session, would have established standards and protocols for the use of solitary confinement in state and local juvenile facilities for the confinement of delinquent minors. SB 1363 failed passage in the Senate Committee on Public Safety. REGISTERED SUPPORT / OPPOSITION: Support California Public Defenders Association (Sponsor) Ella Baker Center for Human Rights (Sponsor) Children's Defense Fund - California (Co-Sponsor) Youth Justice Coalition (Co-Sponsor) A New Way of Life Reentry Project Alameda County Board of Supervisors American Civil Liberties Union of California SB 124 Page 21 American Friends Service Committee Anti-Recidivism Coalition Asian Americans Advancing Justice - Sacramento Aspiranet Association of Black Psychologists AWARE-LA Bend of the Arc: a Jewish Partnership for Justice California Alliance for Youth and Community Justice California Attorneys for Criminal Justice California Catholic Conference of Bishops California Civil Liberties Union California Coalition for Youth California Council of Churches Impact SB 124 Page 22 California Immigrant Policy Center California Psychological Association California State University Northridge Social Worker Society California Teachers Association California Youth Empowerment Network Californians United for a Responsible Budget Center for Educational Excellence in Alternative Settings Center on Juvenile and Criminal Justice Children Now Children's Law Center of California Citizens for Criminal Justice Reform - California Coalition for Engaged Education Communities United for Restorative Justice Community Asset Development Redefining Education Conference of California Bar Associations SB 124 Page 23 Congregation Rodef Sholom Dignity in Schools Drug Policy Alliance East Bay Children's Law Offices Equality California Fair Chance Project Forward Together Free Indeed Reentry Project, Inc. Friends Committee on Legislation of California Gay-Straight Alliance Network of California Human Rights Watch Inland Empire Immigrant Youth Coalition InnerCity Struggle SB 124 Page 24 Justice Not Jails Labor/Community Strategy Center's Community Rights Campaign Latino Coalition for a Healthy California Legal Services for Children Legal Services for Prisoners with Children Life After Uncivil Ruthless Acts Los Angeles Community Action Network Los Angeles County Board of Supervisors Los Angeles Unified School District Manifest Works Mental Health America of California MutliFaith Voices for Peace and Justice National Alliance on Mental Illness California SB 124 Page 25 National Association of Black Social Workers, Inc. National Association of Blacks in Criminal Justice National Association of Social Workers - California Chapter National Center for Youth Law National Religious Campaign Against Torture Nollie Jenkins Family Center Office of Restorative Justice of the Archdiocese of Los Angeles Peace Over Violence Policy Link Prison Activist Resource Center Prisoner Hunger Strike Solidarity Coalition Public Counsel Resurrection Catholic Community SB 124 Page 26 Riverside Temple Beth El Sacred Harmony San Francisco Counsel for Families and Children Social Justice Learning Institute Starting Over Inc. Temple Beth El The Children's Initiative University of California, Berkeley, the Underground Scholars Initiative Urban Peace Movement Violence Prevention Coalition W. Haywood Burns Institute Wilks Law Women in Non Traditional Employment Roles, YouthBuild Youth Law Center SB 124 Page 27 #FREEAMERICA 172 private individuals Opposition California Correctional Peace Officers Association Chief Probation Officers of California Fraternal Order of Police, N. California Probation Lodge 19 Kern County Probation Officers Association L.A. County Probation Officers Union Monterey County Probation Association Probation Peace Officers Association Contra Costa Riverside Sheriffs' Association SB 124 Page 28 Sacramento County Probation Association San Francisco Deputy Probation Officers' Association San Joaquin County Probation Officers Association Santa Clara County Probation Peace Officers' Union State Coalition of Probation Organizations Ventura County Professional Peace Officers' Association Analysis Prepared by:Stella Choe / PUB. S. / (916) 319-3744