BILL ANALYSIS Ó
SENATE COMMITTEE ON PUBLIC SAFETY
Senator Loni Hancock, Chair
2015 - 2016 Regular
Bill No: SB 420 Hearing Date: April 21, 2015
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|Author: |Huff |
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|Version: |April 6, 2015 |
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|Urgency: |No |Fiscal: |No |
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|Consultant:|JM |
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Subject: Prostitution
HISTORY
Source: Alameda County District Attorney and Los Angeles
County District Attorney
Prior Legislation:SB 1366 (Lieu) - Ch. 714, Stats. 2014
SB 982 (Huff) - Held in Senate Appropriations,
2014
AB 12 (Swanson) - Ch. 75, Stats. 2011
AB 17 (Swanson) - Ch. 211, Stats. 2009
Support: Peace Officers Research Association of California;
California Police Chiefs Association; California
District Attorneys Association
Opposition:California Public Defenders Association; California
Attorneys for Criminal Justice
PURPOSE
The purpose of this bill is to define and divide the crime of
prostitution into three separate forms: 1) the defendant agreed
to receive compensation for a lewd act; 2) the defendant
provided compensation, or agreed to provide compensation, for a
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lewd act to an adult; and 3) the defendant provided
compensation, or agreed to provide compensation, to a minor in
exchange for a lewd act, regardless of which party made the
initial solicitation.
Existing law requires the California Department of Justice to
collect data from law enforcement agencies about "the amount and
types of offenses known to the public authorities." (Pen.Code §
13000 and 13002.) DOJ must:
Prepare and distribute forms and electronic means for
reporting crime data.
Recommend the form and content of records to "ensure the
correct reporting of data?" and instruct agencies in the
collecting, keeping and reporting of crime data.
Process, interpret and analyze crime data.
Existing law requires law enforcement agencies, as specified,
district attorneys, the Department of Correction and other
entities to do the following:
Install and maintain records for reporting statistical
data.
Report data to DOJ "in the manner [DOJ] prescribes."
(Pen. Code § 13020.)
Existing law provides that prostitution involves any lewd act
between persons for money or other consideration. (Pen. Code §
647, subd. (b); CALCRIM 1154)
Existing decisional law defines a lewd act as "touching the
genitals, buttocks, or female breast of either the prostitute or
customer with some part of the other person's body for the
purpose of sexual arousal or gratification." (CALCRIM 1154,
citing Pryor v. Municipal Court (1979) 25 Cal.3d 238, 256; See,
Wooten v. Superior Court (2001) 93 Cal.App.4th 422, pp.
431-433.)
Existing law provides that any person who solicits, agrees to
engage in, or engages in an act of prostitution is guilty of a
misdemeanor. The crime includes an element that the defendant
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specifically intended to engage in an act of prostitution and
some act was done in furtherance of the agreed upon act. (Pen.
Code § 647, subd. (b).)
Existing law provides that where any person is convicted for a
second prostitution offense, the person shall serve a sentence
of at least 45 days, no part of which can be suspended or
reduced by the court regardless of whether or not the court
grants probation. (Pen. Code § 647, subd. (k).)
Existing law provides that where any person is convicted for a
third prostitution offense, the person shall serve a sentence of
at least 90 days, no part of which can be suspended or reduced
by the court regardless of whether or not the court grants
probation. (Pen. Code § 647, subd. (k).)
Existing law provides that where a defendant is convicted of a
prostitution offense in which the defendant sought to procure or
procured the "sexual services of a prostitute who was a minor,
the following shall apply:
The defendant shall, in addition to any other fine or
penalty, be ordered to pay up to$25,000; and
Upon appropriation by the Legislature, the proceeds of
the fine shall "be available to fund programs and services
for commercially sexually exploited minors in the counties"
of conviction. (Pen. Code §§ 261.9 and 647, subd. (b).
This bill divides prostitution into three separate crimes. Each
crime includes an element that the defendant takes some act
beyond manifestation of an agreement to engage in an act of
prostitution.
One crime is committed by the person who agreed to pay
another person to engage in a lewd act.
A separate crime is committed by the person who agreed
to receive compensation for a lewd act.
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A third crime is committed by a person who solicits a
minor for a lewd act in exchange for compensation, or who
accepts an offer by a minor to engage in a lewd act in
exchange for compensation paid to the minor.
RECEIVERSHIP/OVERCROWDING CRISIS AGGRAVATION
For the past eight years, this Committee has scrutinized
legislation referred to its jurisdiction for any potential
impact on prison overcrowding. Mindful of the United States
Supreme Court ruling and federal court orders relating to the
state's ability to provide a constitutional level of health care
to its inmate population and the related issue of prison
overcrowding, this Committee has applied its "ROCA" policy as a
content-neutral, provisional measure necessary to ensure that
the Legislature does not erode progress in reducing prison
overcrowding.
On February 10, 2014, the federal court ordered California to
reduce its in-state adult institution population to 137.5% of
design capacity by February 28, 2016, as follows:
143% of design bed capacity by June 30, 2014;
141.5% of design bed capacity by February 28, 2015; and,
137.5% of design bed capacity by February 28, 2016.
In February of this year the administration reported that as "of
February 11, 2015, 112,993 inmates were housed in the State's 34
adult institutions, which amounts to 136.6% of design bed
capacity, and 8,828 inmates were housed in out-of-state
facilities. This current population is now below the
court-ordered reduction to 137.5% of design bed capacity."(
Defendants' February 2015 Status Report In Response To February
10, 2014 Order, 2:90-cv-00520 KJM DAD PC, 3-Judge Court, Coleman
v. Brown, Plata v. Brown (fn. omitted).
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While significant gains have been made in reducing the prison
population, the state now must stabilize these advances and
demonstrate to the federal court that California has in place
the "durable solution" to prison overcrowding "consistently
demanded" by the court. (Opinion Re: Order Granting in Part and
Denying in Part Defendants' Request For Extension of December
31, 2013 Deadline, NO. 2:90-cv-0520 LKK DAD (PC), 3-Judge Court,
Coleman v. Brown, Plata v. Brown (2-10-14). The Committee's
consideration of bills that may impact the prison population
therefore will be informed by the following questions:
Whether a proposal erodes a measure which has contributed
to reducing the prison population;
Whether a proposal addresses a major area of public safety
or criminal activity for which there is no other
reasonable, appropriate remedy;
Whether a proposal addresses a crime which is directly
dangerous to the physical safety of others for which there
is no other reasonably appropriate sanction;
Whether a proposal corrects a constitutional problem or
legislative drafting error; and
Whether a proposal proposes penalties which are
proportionate, and cannot be achieved through any other
reasonably appropriate remedy.
COMMENTS
1.Need for this Bill
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According to the author:
Research proves that demand for sex acts drives the
market for exploitation, especially among children.
Under current law, any person who offers to engage in
or engages in any act of prostitution is guilty of
disorderly conduct. It's time we call purchasing of
sex acts what it is and separate out the buyers from
the sellers, who more often than not - are victims of
sex trafficking.
Currently there is no distinction in law between an
adult who is selling sexual acts, from the adult who
is purchasing sexual acts, or from an adult who is
purchasing sex from a minor. SB 420 focuses on the
demand side of human trafficking, by amending Penal
Code Section 647, to separate the buyers and sellers
of human trafficking and prostitution.
SB 420 is a necessary first step in addressing the
demand side of human trafficking. By making a
distinct separation in the Penal Code, between the
individuals involved in prostitution, we can see real
numbers that will tell us how many children and adults
are being purchased for sex. By US Department of
State estimates, sex trafficking is a $32 billion
industry in this country and 50 percent of trafficking
victims are minors.
Easy access to the Internet enables human beings to
become ensnared and sold across state lines. The FBI
has determined that three of the nations' thirteen
High Intensity Child Prostitution areas are located
here in California. Data generated by SB 420 is
essential for crafting solutions to a disturbing
public safety enemy in our communities, especially
among at-risk youth.
2.Sponsor and Author Seek to Focus Prosecution Efforts on The
Demand Side of Prostitution
The background provided by the author and sponsor notes that the
narrow or current purpose of
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this bill is to collect data on the comparative numbers of
arrests in prostitution cases for 1) buyers of sex acts from
adults, 2) buyers of sex acts from minors, and 3) sellers of sex
acts. The author's background states that the broader goal in
this bill is to "focus on the demand side of human
trafficking?." These efforts are premised on the understanding
that prostitution is integral to and inextricably tied to human
trafficking.
It thus appears that the data from this bill will be used to
eventually support higher penalties for prostitution purchasers.
As the bill separates prostitution into separately defined and
charged offenses, different procedures, penalties and other
outcomes and goals can easily be amended into the law. It
remains to be seen whether treating purchasers and buyers of
sexual acts differently can reduce human trafficking and provide
needed services to sellers.
3.Sexual Acts with Minors - Regardless of the Payment of
Compensation - Constitutes a Sex Crime
This bill would separately define prostitution in which the
person who provides, agreed to provide, sexual services is a
minor. Sexual conduct with a minor constitutes a felony in most
instances, regardless of whether anything of value was offered
or exchanged for the sexual acts. If the minor involved in
commercial sex of was under the age of 14, the defendant has
committed the felony of lewd conduct, with a prison term of
three, six or eight years, or five, eight or 10 years if
coercion is involved (Pen. Code § 288, subds. (a)-(b).)
Soliciting an act of prostitution from a minor under the age of
14 could likely be prosecuted as attempted lewd conduct. The
prison or jail term for an attempt is generally one-half the
punishment for the completed crime. Where the defendant
solicited or employed a minor who was14 or 15 years old, and the
defendant was at least 10 years older than the minor, the
defendant has committed an alternate felony-misdemeanor.
Any defined sex act - sodomy, sexual penetration, oral
copulation or sexual intercourse - with a minor is a crime. The
penalties depend on the relative ages of the defendant and the
minor and whether the crime involved some form of force,
coercion or improper advantage. A defendant charged with a
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prostitution-related offense involving a minor could also be
charged and convicted of a sex crime in the same case.
Generally, because the defined sex crime and the sexual commerce
offense would involve a single transaction or act, the defendant
could only be punished for one offense - the offense carrying
the greatest penalty. (Pen. Code § 654.)
DO MOST PROSTITUTION INCIDENTS IN WHICH AN ADULT SOUGHT TO
PURCHASE SEX FROM A MINOR CONSTITUTE ATTEMPTED OR COMPLETED SEX
CRIMES?
4.Accurate and Full Data Collection on Individually Defined
Forms of Prosecution
The narrow or initial purpose of this bill is to collect data to
determine how many adults are arrested for and convicted of
paying for sexual acts, how many adults are arrested for and
convicted of selling sexual acts and how many adults are
arrested for and convicted of paying for sexual services from
minors. The bill divides the prosecution statute - Penal Code
Section 647, subdivision (b) - into three paragraphs reflecting
each form of the crime. In order for the data to be valuable
and accurate, reporting agencies will need to specifically note
the paragraph under which a defendant was arrested and
convicted. Representatives from DOJ explained: "The way [crime
reports] appears in the system is entirely dependent on the law
enforcement agency or court that enters the offense into the
system. One agency may enter PC 647(b)(2) while another may
only enter PC 647(b)."
Prosecutors will likely record the specific paragraph under
which the defendant is convicted - PC 647 (b)(2) for example.
However, police officers and sheriff's deputies might not
specifically record the paragraph of arrest unless instructed to
do so. Further, it may not be apparent to officers and deputies
what specific form of prostitution would be charged by the
prosecutor in any particular case. That could cause some
confusion and inaccuracy in the data.
Another impediment to full and accurate data collection is the
fact, as discussed in Comment #3, that sex with a minor is a
crime. If a minor and an adult are involved in a prostitution
incident, numerous outcomes involving sex crimes and
prostitution could occur. For example, the police could arrest
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both parties for prostitution, but the prosecutor could charge
the adult with a sex crime, or prostitution, or both. The
prosecutor could charge the minor with no crime, or file a
prostitution charge. The adult could be initially charged with
a sex crime but plead guilty to a prostitution offense, perhaps
if the minor appeared to be an adult. In sum, it may be
difficult to determine the extent of prostitution involving
minors from arrest and conviction data.
If committee members approve the bill, they may wish to inquire
as to whether DOJ should be directed to instruct agencies on the
reporting of prostitution offenses. Committee members may also
wish to inquire whether it could be assured that prostitution
involving minors could be accurately reported and tracked.
5.Seattle Law Enforcement Assisted Diversion Program for
Prostitution and Drug Offenders
The Seattle Police Department and other agencies and entities
have implemented a program of Law Enforcement Assisted Diversion
(LEAD). LEAD officers take drug offenders and sellers of
prostitution services - categories of offenders that may often
overlap - directly to services and treatment. The process
bypasses the court system, saving court resources and time.
The second evaluation of the program was recently released by
the University of Washington. Short and long term recidivism is
significantly lower for LEAD participants than for offenders in
the court system<1>, with better results over the long term.
LEAD programs could be one of the programs or efforts in helping
street-level sex workers transition out of their plight.
Without services to assist sex workers with underlying problems
of drug abuse, lack of housing and exploitation, focusing
prosecution efforts on sex purchasers will not likely produce
optimum results.
6.Recidivism Studies on Persons Convicted of Purchasing Sex -
Effects of Special Programs
A study<2> in 2002 in the Western Criminology Review of a now
defunct first-offender program in Portland (SEEP) found very low
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<1> http://leadkingcounty.org/lead-evaluation/
<2> http://wcr.sonoma.edu/v3n2/monto.html.
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recidivism rates for all prostitution arrestees regardless of
whether they were referred to SEEP and participated, were
referred to SEEP but did not attend, or were not referred to the
program. The study considered only a two-year period and a
relatively small number of offenders. The researchers inferred
that an arrest, per se, could have deterred offenders, as the
crime involves significant shame. The authors also questioned
if the offenders continued to solicit prostitutes but simply
learned how to avoid arrest. They could not say whether the
education from the SEEP program would have led the participants
to a avoid prostitution for a substantial time in the future.
A number of cities around the country have adopted special
first-offender prostitution diversion programs that educate men
arrested for soliciting an act of prostitution about the harms
caused by or attendant to the commercial sex trade. Initial
reports of the effectiveness of the programs have been sharply
criticized in peer-reviewed studies.<3> The study from the
Western Criminology Review (noted above) found that recidivism
rates attributable to FOPP programs are difficult to measure, as
johns arrested for prostitution offenses can easily learn how to
avoid arrest. Further, the increasing shift of prostitution to
the Internet makes it difficult to measure recidivism.
DOES RESEARCH INDICATE THAT AN ARREST, PER SE, MAY BE A
SUBSTANTIAL DETERRENT FOR MEN WHO SOLICIT PROSTITUTES?
7. Limited Studies of the Demographics of Prostitution
Customers
According to a John Jay College study of commercially, sexually
exploited homeless youth in New York often sought out customers,
rather than being solicited by adults. Particularly in
Manhattan, or through the Internet, CSEC (commercially sexually
exploited children) sought older white customers who were
perceived to have more money. (See Comment # 8) However, the
range of customers was relatively wide.
A draft University of Chicago study by Steven Levitt and Sudhir
Alladi Venkatesh (Freakonomics) considered of street-level
prostitution in certain Chicago neighborhoods known for
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<3>
http://rightswork.org/wp-content/uploads/2012/09/John-Schools.Lov
ell.Jordan.7.12.pdf.
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prostitution, including a neighborhood where prostitution was
controlled by pimps and a neighborhood where prostitutes were
independent.<4> Levitt estimated that there were 1,200 acts of
prostitution per arrest, indicating that even street-level
prostitution customers generally need not fear arrest. The
Chicago study noted that more upscale prostitution occurred over
the Internet and through escort services, where the likelihood
of arrest was low.
Levitt found "many men making a few visits and a small number of
men making very frequent visits." He found 25 johns arrested
twice and 2,969 johns who were arrested once. As in the Western
Criminology Review study, Leavitt speculated that some men may
have learned from one arrest how to avoid another. However,
some johns may have been arrested multiple times because they
were not good at distinguishing between an actual prostitute and
a police decoy.
A 2008 review in the Electronic Journal of Human Sexuality<5> of
studies from cities across the country found wide variance in
education, income and ethnicity among prostitution customers.
8. Sex Trafficking of Minors - Estimated Prevalence and
Available Data
General Trafficking Prevalence Estimates and Data; 2007
California Data
There appears to be general agreement that sex trafficking of
children is increasing and profitable. However, the 2007 Final
Report of the California Alliance to Combat Trafficking and
Slavery Task Force<6> noted that California lacked comprehensive
statistics on human trafficking. Thus, many statistics on human
trafficking in general, and sex trafficking of children in
particular, are estimates. The 2007 report did cite statistics
from various sources, including a study finding that 80% of
documented cases in California occurred in urban areas and the
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<4>
http://economics.uchicago.edu/pdf/Prostitution%205.pdf?q=venkates
h. Levitt noted that the data was preliminary and cautioned
those who would cite the report, the study has been widely read
and cited.
<5> http://www.ejhs.org/volume11/brewer.htm.
<6> The task force was administered by the California Attorney
General's Office.
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majority of victims were non-citizens. A U.S. State Department
report of global trafficking estimated that minors constituted
50% of trafficking victims. (2007 Alliance to Combat
Trafficking. Final Report, pp. 33-39.<7>) The State Department
also noted that 14,500 to 17,500 persons are trafficked into the
United States from other countries.<8>
The Federal Bureau of Investigation (FBI) conducts 24 Innocence
Lost child sexual exploitation task forces and working groups
across the country. Through 2007, 365 cases were opened and 281
child victims were located. The Shared Hope International
non-profit organization has reported that approximately 100,000
domestic minors are sexually trafficked each year.<9> Numerous
examples of trafficking cases were summarized in the California
Alliance Report. In 2001, a Berkeley man was prosecuted for
smuggling 15 girls from India for labor and sexual exploitation.
In 2000, a man was prosecuted for bringing women and girls from
Mexico and forcing them to work as prostitutes in Long Beach.
(2007 Alliance to Combat Trafficking, Final Report, p. 18.)
2012 Report of the California Attorney General on Human
Trafficking
The California Attorney General's Human Trafficking in
California 2012<10> report stated that human trafficking
investigations and prosecutions have become more comprehensive
and organized. There are nine human trafficking task forces in
California, composed of local, state and federal law enforcement
and prosecutors.
Data on human trafficking has improved, although the data still
does not reflect the actual extent and range of human
trafficking. <11>Data from 2010 through 2012 collected by the
California task forces are set out in the following chart:
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<7>
http://ag.ca.gov/publications/Human_Trafficking_Final_Report.pdf.
The report includes citations to the each of the studies
quoted in the report.
<8> http://oag.ca.gov/human-trafficking/2012, Ch. 3 p. 48.
<9>
http://www.sharedhope.org/Portals/0/Documents/SHI_National_Report
_on_DMST_2009.pdf.
<10> http://oag.ca.gov/human-trafficking/2012.
<11> http://oag.ca.gov/human-trafficking/2012, Ch. 3, pp. 47-53.
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California Human Trafficking Task Forces Data 2010-2012
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|Investigations |2,552 |
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|Victims Identified |1,277 |
|--------------------------------+--------------------------------|
|Arrests Made |1,798 |
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Trafficking by Category
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|Sex Trafficking |56% |
|--------------------------------+--------------------------------|
|Labor Trafficking |23% |
|--------------------------------+--------------------------------|
|Unclassified or Insufficient |21% |
|Information | |
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9.John Jay College of Criminal Justice Study on Commercially
Exploited Children (CSEC) found that most CSEC were introduced
to Commercial Sex by Peers
Recent years have seen a great increase in awareness of and
concerns about minors - most often girls - engaged in commercial
sex activities. Organized, coerced trafficking has received the
most attention. Sex trafficking of has been described as sexual
slavery. Trafficked minors are isolated, controlled by and made
dependent on their exploiters, and can even be perversely loyal
because of the manufactured dependency.<12>
However, a detailed 2008 study by the Center for Court
Innovation and John Jay College of Criminal Justice found that
most of the minors engaging in commercial sex in New York City
are homeless or runaway minors who engage in "survival sex" to
obtain small amounts of money for food and other necessities. A
significant number of these CSEC - commercially sexually
exploited children - are gay, lesbian and transgender youth who
left unsupportive families and communities. The study authors
were surprised to find that most CSEC were recruited or
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<12> Rachel Lloyd, Girls Like Us, pp.153-159 Harper Collins,
2011.
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initiated into survival sex by their peers, with no involvement
by adult pimps. The John Jay study also reported that many CSEC
were simply approached on the street by would-be customers,
without any solicitation by the CSEC. <13> Also surprising,
there were as many male CSEC as female in New York City.
Rachel Aviv's December 2012<14> profile of homeless young people
in the New Yorker magazine noted the results of the John Jay
study and then carefully documented the daily lives of a number
of homeless young people on the New York City streets. They
often formed informal communities or families for support. They
sometimes shared repeat customers and money earned from
commercial sex, technically acting as pimps for each other.
Adults who purchase sex from CSEC are certainly aware that they
are taking advantage of these children. Some men use violence
against the homeless young people.
Aviv's profile documented that living on the streets and
engaging in survival sex is perilous. The rate of HIV among
homeless youth is triple that of the general population.
Hunger, physical illness and psychiatric disorders are common.
10. Girls Collaborative Court Programs for Minors Engaged in
Prostitution
Special Court Process
The New Yorker profile described a patchwork of services that
are not coordinated or comprehensive. As the CSEC understood,
they are constantly in danger of becoming lifers on the street,
with the attendant harms of that life. The John Jay study may
not reflect the populations of CSEC in cities and areas other
than New York. However, the study does indicate that approaches
that rely mostly on enforcement of criminal laws against human
trafficking and pimping will not likely solve many of the
problems of young people who are exploited for commercial sex.
There has been a growing awareness of the value of special
juvenile courts for the girls found to be involved in commercial
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<13> https://www.ncjrs.gov/pdffiles1/nij/grants/225083.pdf, pp
48-49,. 32-102.
<14>
http://www.newyorker.com/reporting/2012/12/10/121210fa_fact_aviv?
currentPage=all&pink=HhM7xT.
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sex. It has been argued that treating juvenile prostitution as
a crime problem does little or nothing to address the underlying
circumstances that bring minors to engage in commercial sex.
Special collaborative courts can organize and monitor
supervision and treatment of CSEC girls. Special STAR
(Succeeding through Achievement and Resilience) courts have been
implemented in Los Angeles as a pilot project that is reportedly
being expanded.<15> Alameda County has an established an
extensive Girls Court, with the participation of the sponsor of
this bill. New York has created a network of 11 Human
Trafficking Intervention Courts for juveniles who are at least
16 years old.<16>
It appears that collaborative courts for minors caught up in
sexual commerce have focused almost exclusively on girls.
However, the John Jay study and the New Yorker investigative
article indicate that there are a substantial number of boys and
transgender youth who are CSEC. In New York, the John Jay study
found that as many boys as girls were involved in sexual
commerce. Arguably, collaborative courts should be organized or
designed to handle whatever populations of CSEC are present in
the community of the court or courts. Collaborative girls courts
have only been implemented on a limited basis, likely because
the court system and probation departments have limited funds.
11. Amendment to Correctly Define the Elements of Prostitution
As currently drafted on April 6, 2015, the bill can be
interpreted as defining prostitution solely in terms of a
solicitation of another to engage in an exchange of compensation
for a lewd act. However traditionally and under existing law,
prostitution can also be committed by agreeing to engage in an
exchanging compensation for a lewd act, or by engaging in an
exchange of compensation for a lewd act.
The author, sponsor and the Los Angeles County District Attorney
have agreed that the bill should be amended to include all the
ways in which prostitution can be committed.
SHOULD THE BILL BE AMENDED TO CORRECTLY DESCRIBE PROSTITUTION AS
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<15> http://file.lacounty.gov/bos/supdocs/70403.pdf.
<16>
http://www.nytimes.com/2014/01/29/us/a-courts-all-hands-approach-
aids-girls-most-at-risk.html?_r=0.
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INCLUDING AGREEING TO ENGAGING IN AN ACT OF PROSTITUTION OR
ENGAGING IN AN ACT OF PROSTITUTION, NOT SOLELY SOLICITING AN ACT
OF PROSTITUTION?
-- END -