BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 2938
                                                                  Page  1

          Date of Hearing:   April 18, 2006
          Counsel:                Heather Hopkins


                         ASSEMBLY COMMITTEE ON PUBLIC SAFETY
                                  Mark Leno, Chair

                    AB 2938 (Runner) - As Amended:  April 5, 2006


           SUMMARY  :   Expands what records can be released to the public in  
          a case of child abuse or negligence that has resulted in a child  
          fatality or near fatality.  Specifically,  this bill  :  

          1)Expands what county child welfare agencies shall record in the  
            Child Welfare Services/Case Management System from all cases  
            of child death, to "all cases of child fatality or near  
            fatality."

          2)Defines "near fatality" as "a severe childhood injury  
            resulting in admission to a critical care unit for greater  
            than 24 hours following the injury."

          3)Changes existing law regarding what portions of juvenile case  
            files shall be released to the public to state:

             a)   Notwithstanding any other law, juvenile case files, any  
               juvenile court records, and any county welfare department  
               and State Department of Social Services (DSS) case files,  
               regardless of whether they are maintained electronically or  
               on paper, except those relating to matters within the  
               jurisdiction of the court pursuant to Welfare and  
               Institutions Code (WIC) Section 601 or 602, that pertain to  
               a case of child abuse or neglect that has resulted in a  
               child fatality or near fatality of a child, shall be  
               released to the public and shall not be exempt from  
               disclosure under any provision of the California Public  
               Records Act [Chapter 3.5 (commencing with Section 6250) of  
               Division 7 of Title 1 of the Government Code].

             b)   Provides that prior to releasing any record pursuant to  
               this paragraph the custodian of the records shall redact  
               the following information: 

               i)     Any information relating to another child, or that  








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                 could identify another child, except for information  
                 about the deceased child or the child who suffered a near  
                 fatality.

               ii)    The names, addresses, telephone numbers, or any  
                 other identifying information of any county or state  
                 personnel referred to in the juvenile case file.

               iii)   The names, addresses, telephone numbers, or any  
                 other identifying information of any individual reporting  
                 abuse or neglect of a child.

               iv)    Any information that would jeopardize a criminal  
                 investigation or proceeding. 

             c)   The custodian of any records required to be released  
               pursuant to this paragraph that contain redacted  
               information shall specify in a separate document the  
               specific bases.

             d)   If the custodian of a juvenile case file required to be  
               released under this paragraph believes that, despite the  
               permitted redaction, disclosure of the case file, or any  
               portion thereof, would be seriously and unavoidably  
               detrimental to the safety, protection, or physical or  
               mental and emotional well-being of another child who is  
               directly or indirectly connected to the juvenile case file  
               that is the subject of the petition, he or she may, with  
               notice to the requesting person, petition the presiding  
               judge of the juvenile court to issue an order prohibiting  
               or limiting access to the case file.  If a person who  
               requests a case file under this paragraph believes that any  
               redactions or limitations in released case files do not  
               comply with this paragraph, he or she may, with notice to  
               the custodian of the case file, petition the presiding  
               judge of the juvenile court to issue an order granting  
               access to all or a portion of the case file.

             e)   Defines "near fatality" as a severe childhood injury  
               resulting in admission to a critical care unit for greater  
               than 24 hours following the injury.  

          4)Provides that the Judicial Council shall adopt a rule of court  
            on or before January 1, 2008 to establish the procedures for  
            the release of information and redaction of court records. 








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          5)Makes legislative findings and declarations regarding  
            California's compliance with the federal Child Abuse  
            Prevention and Treatment Act (CAPTA).

          6)States that it is the intent of the Legislature to do all of  
            the following:

             a)   Ensure that California is in compliance with CAPTA and  
               not jeopardize the receipt of over $3 million in federal  
               CAPTA funds.

             b)   Allow for the public disclosure of case-specific facts  
               and information regarding child abuse or neglect that have  
               resulted in a child fatality or near fatality.

             c)   Permit the broadest disclosure of government records  
               relating to child fatalities and near fatalities as  
               possible while protecting the confidentiality of siblings,  
               half-siblings, and other children, government employees,  
               and mandatory and voluntary reporters of child abuse,  
               without jeopardizing a criminal investigation or  
               proceeding.

           EXISTING LAW  :

          1)Provides that, except as specified, a case file may be  
            inspected only by the following:

             a)   Court personnel.

             b)   The district attorney, a city attorney, or city  
               prosecutor authorized to prosecute criminal or juvenile  
               cases under state law.

             c)   The minor who is the subject of the proceeding.

             d)   His or her parents or guardian.

             e)   The attorneys for the parties, judges, referees, other  
               hearing officers, probation officers, and law enforcement  
               officers who are actively participating in criminal or  
               juvenile proceedings involving the minor.

             f)   The superintendent or designee of the school district  








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               where the minor is enrolled or attending school.

             g)   Members of the child protective agencies, as specified.

             h)   The State Department of Social Services to carry out its  
               duties, as specified, to oversee and monitor county child  
               welfare agencies, children in foster care or receiving  
               foster care assistance, and out-of-state placements.

             i)   Authorized legal staff or special investigators who are  
               peace officers who are employed by, or who are authorized  
               representatives of, the DSS, as necessary to the  
               performance of their duties to inspect, license, and  
               investigate community care facilities, and to ensure that  
               the standards of care and services provided in those  
               facilities are adequate and appropriate and to ascertain  
               compliance with the rules and regulations to which the  
               facilities are subject.  The confidential information shall  
               remain confidential except for purposes of inspection,  
               licensing, or investigation, as specified, or a criminal,  
               civil, or administrative proceeding in relation thereto.   
               The confidential information may be used by the DSS in a  
               criminal, civil, or administrative proceeding.  The  
               confidential information shall be available only to the  
               judge or hearing officer and to the parties to the case.   
               Names that are confidential shall be listed in attachments  
               separate to the general pleadings.  The confidential  
               information shall be sealed after the conclusion of the  
               criminal, civil, or administrative hearings, and may not  
               subsequently be released except in accordance with this  
               subdivision.  If the confidential information does not  
               result in a criminal, civil, or administrative proceeding,  
               it shall be sealed after the DSS decides that no further  
               action will be taken in the matter of suspected licensing  
               violations.  Except as otherwise provided in this  
               subdivision, confidential information in the possession of  
               the DSS may not contain the name of the minor.

             j)   Members of children's multidisciplinary teams, persons,  
               or agencies providing treatment or supervision of the  
               minor.

             aa)  A judge, commissioner, or other hearing officer assigned  
               to a family law case with issues concerning custody or  
               visitation, or both, involving the minor, and the following  








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               persons, if actively participating in the family law case:  
               a family court mediator assigned to a case involving the  
               minor, a court-appointed evaluator or a person conducting a  
               court-connected child custody evaluation, investigation, or  
               assessment, and counsel appointed for the minor in the  
               family law case.  Prior to allowing counsel appointed for  
               the minor in the family law case to inspect the file, the  
               court clerk may require counsel to provide a certified copy  
               of the court order appointing him or her as the minor's  
               counsel. 

             bb)  A court-appointed investigator who is actively  
               participating in a guardianship case involving a minor and  
               acting within the scope of his or her duties in that case.

             cc)  A local child support agency for the purpose of  
               establishing paternity and establishing and enforcing child  
               support orders.

             dd)  Juvenile justice commissions.  

             ee)  Any other person who may be designated by court order of  
               the judge of the juvenile court upon filing a petition.   
               [WIC Section 827(a)(1).]

          2)Provides that notwithstanding any other law juvenile case  
            files, except those relating to matters within the  
            jurisdiction of the court, that pertain to a deceased child  
            who was within the jurisdiction of the juvenile court, shall  
            be released to the public pursuant to an order by the juvenile  
            court after a petition has been filed and interested parties  
            have been afforded an opportunity to file an objection.   
            [Penal Code Section 827(a)(2).] 

          3)Provides that any information relating to another child or  
            which could identify another child, except for information  
            about the deceased, shall be redacted from the juvenile case  
            file prior to release, unless a specific order is made by the  
            juvenile court to the contrary.  [Penal Code Section  
            827(a)(2).]

          4)Provides that except as specified, the presiding judge of the  
            juvenile court may issue an order prohibiting or limiting  
            access to the juvenile case file, or any portion thereof, of a  
            deceased child only upon a showing that release of the  








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            juvenile case file or any portion thereof is detrimental to  
            the safety, protection, or physical or emotional well-being of  
            another child who is directly or indirectly connected to the  
            juvenile case that is the subject of the petition.  [Penal  
            Code Section 827(a)(2).]

          5)Access to juvenile case files pertaining to matters within the  
            jurisdiction of the juvenile court shall be limited as  
            follows:

             a)   If a juvenile case file, or any portion thereof, is  
               privileged or confidential pursuant to any other state law  
               or federal law or regulation, the requirements of that  
               state law or federal law or regulation prohibiting or  
               limiting release of the juvenile case file or any portions  
               thereof shall prevail.  Unless a person is listed in WIC  
               Section 827(a)(1) and is entitled to access under the other  
               state law or federal law or regulation without a court  
               order, all those seeking access, pursuant to other  
               authorization, to portions of, or information relating to  
               the contents of, juvenile case files protected under  
               another state law or federal law or regulation, shall  
               petition the juvenile court.  The juvenile court may only  
               release the portion of, or information relating to the  
               contents of, juvenile case files protected by another state  
               law or federal law or regulation if disclosure is not  
               detrimental to the safety, protection, or physical or  
               emotional well-being of a child who is directly or  
               indirectly connected to the juvenile case that is the  
               subject of the petition.  This paragraph shall not be  
               construed to limit the ability of the juvenile court to  
               carry out its duties in conducting juvenile court  
               proceedings.

             b)   Prior to the release of the juvenile case file or any  
               portion thereof, the court shall afford due process,  
               including a notice of and an opportunity to file an  
               objection to the release of the record or report to all  
               interested parties.  [Penal Code Section 827(a)(3).]

          6)A juvenile case file, any portion thereof, and information  
            relating to the content of the juvenile case file, may not be  
            disseminated by the receiving agencies to any persons or  
            agencies, other than those persons or agencies authorized to  
            receive documents pursuant to this section. Further, a  








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            juvenile case file, any portion thereof, and information  
            relating to the content of the juvenile case file, may not be  
            made as an attachment to any other documents without the prior  
            approval of the presiding judge of the juvenile court, unless  
            it is used in connection with and in the course of a criminal  
            investigation or a proceeding brought to declare a person a  
            dependent child or ward of the juvenile court.  [Penal Code  
            Section 827(a)(4).]

          7)While the Legislature reaffirms its belief that juvenile court  
            records, in general, should be confidential, it is the intent  
            of the Legislature in enacting this subdivision to provide for  
            a limited exception to juvenile court record confidentiality  
            to promote more effective communication among juvenile courts,  
            family courts, law enforcement agencies, and schools to ensure  
            the rehabilitation of juvenile criminal offenders as well as  
            to lessen the potential for drug use, violence, other forms of  
            delinquency, and child abuse.  [WIC Section 827(b)(1).]

          8)Written notice that a minor enrolled in a public school,  
            kindergarten to Grade 12, inclusive, has been found by a court  
            of competent jurisdiction to have committed any felony or any  
            misdemeanor involving curfew, gambling, alcohol, drugs,  
            tobacco products, carrying of weapons, a sex offense listed in  
            Penal Code Section 290, assault or battery, larceny,  
            vandalism, or graffiti shall be provided by the court, within  
            seven days, to the superintendent of the school district of  
            attendance.  Written notice shall include only the offense  
            found to have been committed by the minor and the disposition  
            of the minor's case.  This notice shall be expeditiously  
            transmitted by the district superintendent to the principal at  
            the school of attendance.  The principal shall expeditiously  
            disseminate the information to those counselors directly  
            supervising or reporting on the behavior or progress of the  
            minor.  In addition, the principal shall disseminate the  
            information to any teacher or administrator directly  
            supervising or reporting on the behavior or progress of the  
            minor whom the principal believes needs the information to  
            work with the pupil in an appropriate fashion, to avoid being  
            needlessly vulnerable or to protect other persons from  
            needless vulnerability.  [WIC Section 827(b)(2).]

          9)Any information received by a teacher, counselor, or  
            administrator under this subdivision shall be received in  
            confidence for the limited purpose of rehabilitating the minor  








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            and protecting students and staff, and shall not be further  
            disseminated by the teacher, counselor, or administrator,  
            except insofar as communication with the juvenile, his or her  
            parents or guardians, law enforcement personnel, and the  
            juvenile's probation officer is necessary to effectuate the  
            juvenile's rehabilitation or to protect students and staff.   
            [WIC Section 827(b)(2).]

          10)An intentional violation of the confidentiality provisions of  
            this paragraph is a misdemeanor punishable by a fine not to  
            exceed $500.  [WIC Section 827(b)(2).]

          11)Provides that if a minor is removed from public school as a  
            result of the court's finding, the superintendent shall  
            maintain the information in a confidential file and shall  
            defer transmittal of the information received from the court  
            until the minor is returned to public school.  If the minor is  
            returned to a school district other than the one from which  
            the minor came, the parole or probation officer having  
            jurisdiction over the minor shall so notify the superintendent  
            of the last district of attendance, who shall transmit the  
            notice received from the court to the superintendent of the  
            new district of attendance.  [WIC Section 827(b)(3).]

          12)Provides that each probation report filed with the court  
            concerning a minor whose record is subject to dissemination  
            shall include on the face sheet the school at which the minor  
            is currently enrolled.  The county superintendent shall  
            provide the court with a listing of all of the schools within  
            each school district, within the county, along with the name  
            and mailing address of each district superintendent.  [WIC  
            Section 827(c).]

          13)Provides that each notice sent by the court shall be stamped  
            with the instruction:  "Unlawful Dissemination Of This  
            Information Is A Misdemeanor."  Any information received from  
            the court shall be kept in a separate confidential file at the  
            school of attendance and shall be transferred to the minor's  
            subsequent schools of attendance and maintained until the  
            minor graduates from high school, is released from juvenile  
            court jurisdiction, or reaches the age of 18 years, whichever  
            occurs first.  After that time the confidential record shall  
            be destroyed.  At any time after the date by which a record  
            required to be destroyed by this section should have been  
            destroyed, the minor or his or her parent or guardian shall  








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            have the right to make a written request to the principal of  
            the school that the minor's school records be reviewed to  
            ensure that the record has been destroyed.  Upon completion of  
            any requested review and no later than 30 days after the  
            request for the review was received, the principal or his or  
            her designee shall respond in writing to the written request  
            and either shall confirm that the record has been destroyed  
            or, if the record has not been destroyed, shall explain why  
            destruction has not yet occurred.  [WIC Section 827(d).]

          14)Provides that for purposes of this section, a "juvenile case  
            file" means a petition filed in any juvenile court proceeding,  
            reports of the probation officer, and all other documents  
            filed in that case or made available to the probation officer  
            in making his or her report, or to the judge, referee, or  
            other hearing officer, and thereafter retained by the  
            probation officer, judge, referee, or other hearing officer.   
            [WIC Section 827(e).]

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   

           1)Author's Statement  :  According to the author, "When the State  
            protects children by removing them from the care of their  
            parents, then state government, and by extension every  
            Californian, assumes the role as parent to those children.   
            Public information about child fatalities and near fatalities  
            is fundamental in assuring the public that every effort is  
            being done to protect and safeguard all children who are in  
            protective custody.  This bill will provide the public with  
            insight into the circumstances that led to a child fatality or  
            near fatality, so that other children will not suffer a  
            similar fate.  

          "According to the United States Department of Health and Human  
            Services (DHHS), existing California law requiring the public  
            to petition the juvenile court for the release of records in  
            child fatality cases does not comply with federal law.  DHHS  
            has notified California that it is out of compliance with  
            CAPTA, and that the State risks losing over $3 million in  
            federal CAPTA funds for failure to comply.  This bill will  
            amend state law to ensure compliance, thus allowing the state  
            to receive over $3 million in federal funding.  The CAPTA  
            disclosure requirements are an exception to general  








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            confidentiality laws, and are intended to ensure that the  
            public has access to information in order to prevent tragedies  
            from recurring.  

          "This bill is consistent with a California constitutional  
            amendment which indicates that the people have the right of  
            access to information concerning the conduct of the people's  
            business, thereby all meetings of public bodies and writings  
            of public officials and agencies shall be open to public  
            scrutiny.  

          "Since this bill focuses on the conditions that led to a child  
            fatality or near fatality in foster care, all information  
            relating to another child, a county employee or state  
            employee, or an individual who reports abuse or neglect of a  
            child will be redacted prior to releasing the records.  In  
            addition, any information that would jeopardize a criminal  
            investigation or proceeding will be withheld from release."  

           2)California Is In Compliance With CAPTA  :  In a series of  
            letters between the United States DHHS and DSS written between  
            September 2005 and February of this year, California's  
            compliance with CAPTA was discussed.  While initially the  
            United States DHHS stated that California "may not be in  
                                              compliance with CAPTA" they agreed to California's correction  
            action plan submitted on January 31, 2006 to address the  
            compliance issue and released California's CAPTA Basic State  
            Grant award.  Staff has spoken with the United States DHHS and  
            verified that California is in compliance with CAPTA.     

           3)Procedures are Already in Place to Allow Access to Records of  
            a Deceased Minor  :  WIC Section 827(2) provides that "juvenile  
            case files . . . that pertain to a deceased child who was  
            within the jurisdiction of the juvenile court . . . shall be  
            released to the public pursuant to an order by the juvenile  
            court after a petition has been filed and interested parties  
            have been afforded an opportunity to file an objection.  Any  
            information relating to another child or which could identify  
            another child, except for information about the deceased,  
            shall be redacted from the juvenile case file prior to  
            release, unless a specific order is made by the juvenile court  
            to the contrary . . . the presiding judge of the juvenile  
            court may issue an order prohibiting or limiting access to the  
            juvenile case file, or any portion thereof, of a deceased  
            child only upon a showing that release of the juvenile case  








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            file or any portion thereof is detrimental to the safety,  
            protection, or physical or emotional well-being of another  
            child who is directly or indirectly connected to the juvenile  
            case that is the subject of the petition."  The author has  
            presented no evidence that these procedures have barred or  
            hindered suits against the state in the case of a child who  
            has died while in foster care.

           4)Public Policy Concerns Regarding Unfettered Access to Juvenile  
            Records  :  WIC Section 827, governing juvenile case file  
            inspection, along with the California Court Rule governing the  
            confidentiality of juvenile court records, reflect the  
            legislative determination that the juvenile court has both the  
            sensitive and expertise to make decisions about access to  
            juvenile records.  [  People v. Superior Court  (2003) 132  
            Cal.Rptr 2d 144.]  The court went on to say that WIC Section  
            827 represents a legislative decisions to give some but not  
            all persons free entry into juvenile records manifests an  
            intent that those not expressly enumerated must show  
            legitimate need for juvenile records.  (Id.)  As the author is  
            most concerned with access to records in the case of a death  
            of a child, the court has noted that in considering a petition  
            for obtaining access to juvenile case records of a child who  
            has died, no weighing or balancing of interest is required;  
            the files must be released unless there is a showing that  
            release of the file or any portion thereof is detrimental to  
            the safety, protection, or physical, or emotional well=-being  
            of another child who is directly or indirectly connected to  
            the juvenile case that is the subject of the petition.  [  In re  
            Elijah S.  (2005) 24 Cal.Reptr.3d 16.]

           5)Suggested Amendments  :  The County Welfare Directors  
            Association of California suggested two amendments:

             a)   On Page 10, delete Lines 26-29, insert, "(i) Any  
               information relating to another individual, including but  
               not limited to dependent or non-dependent siblings,  
               step-siblings, half siblings; faster parents; relative  
               caretakers; relatives; and prospective adoptive parents  
               that could identify another individual, except for  
               information germane to ascertaining the cause or manner of  
               death or near fatality of the deceased child or the child  
               who suffered a near fatality.

             b)   On Page 10, Line 34, insert:  "(v) Any information that  








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               is prohibited from disclosure under state or federal law."   


           6)Arguments in Support  :  According to Children's Advocacy  
            Institute, "When the state uses its power to intervene in a  
            family and remove a child from the care of their parents  
            because the child is in peril, state government - and by  
            extension, every Californian - assumes a tremendous and deeply  
            personal responsibility for the life and well-being of the  
            child.  The assumption for removing a child from the care of  
            their parents is that the child will be safer under the care  
            of the state.

          "Thus, when a child dies or nearly dies under the care of the  
            state, the tragedy - if possible - is compounded.  DSS has  
            stated that in the year 1999-2000 sixty-six California  
            children died due to physical trauma while in foster care.   
            Yet, little is known about how these children died, and hence,  
            the California public - in a very real sense, the parents of  
            the foster care child - are let out of the discussion about  
            how to prevent more children from dying in the future.

          " . . . this bill will require that any juvenile court and state  
            and county agency records that pertain to a case of child  
            abuse or neglect that has resulted in a child dying or nearly  
            dying be released to a requesting person without prior court  
            order and subject to the redaction of any identifying  
            information concerning other children, county or state  
            personnel, mandatory voluntary reports of abuse or any  
            information that would jeopardize a criminal prosecution.   
            This bill permits the custodian of any records sought to be  
            released, despite the redaction, to petition the juvenile  
            court to prohibit the release if the release would be  
            seriously and unavoidable detrimental to the safety,  
            protection, or physical or emotional well-being of another  
            child."

           7)Arguments in Opposition  :

             a)   According to the  California Public Defenders  
               Association  , "California already has an explicit statutory  
               scheme which balances the dual interests of confidentiality  
               and public disclosure.  (WIC Section 827, California Rules  
               of Court Rule 1423).  Historically, juvenile court records  
               have been confidential in order to prevent stigma, to  








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               further the purposes of family unity and preservation, and  
               to further rehabilitation in delinquency.  Confidentiality  
               also furthers the purpose of fostering open communication  
               in sensitive areas.  However, state law allows for this  
               'veil' of confidentiality to be pierced - where  
               appropriate.

             " . . . In cases of fatal child abuse or neglect, there is a  
               presumption for disclosure of pertinent records.  In such  
               cases, the records 'shall be released' unless there is a  
               showing that release of the file is detrimental to the  
               safety, protection or physical or emotional well-being of  
               another child who is directly or indirectly connected to  
               the case."  [WIC Section 827(a)(2);  In re Elijah S.  (2005)  
               125 Cal.App.4th 1532.]  In fact, records shall be released  
               even if the child victim was not a formal dependent of the  
               court, but suffered serious abuse or neglect.  [  In re  
               Elijah S.  , 125 Cal.App.4th at 1534, 1544 (upholding  
               juvenile's court's order releasing child welfare and social  
               services records in cases of two abused deceased minors,  
               despite no formal dependence petition).]"

             b)   According to the  County Welfare Directors Association of  
               California  (CWDA), "The public's access to understanding  
               the workings of the child welfare system is clearly an  
               important societal goal.  So too, however, is the goal of  
               protecting the privacy and confidentiality of innocent  
               parties whose very personal and sensitive information is  
               often included in juvenile case records.  As drafted, this  
               bill unnecessarily and inappropriately compromises the  
               privacy and confidentiality of persons included in case  
               records in favor of public access to child welfare case  
               records.  Moreover, this bill goes far beyond what is  
               required for federal compliance and much further than  
               almost any other state's disclosure policies.  Thus, the  
               compromise of privacy is not required by federal law.

             "This bill would provide for the redaction of information  
               relating to another child or that could identify another  
               child, except for the child who suffered the fatality or  
               near fatality.  With respect to other individuals whose  
               personal  information is often included in case records,  
               the bill provides only for the redaction of names and  
               contact information for state and county personnel; names  
               and contact information for persons reporting the abuse or  








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               neglect; and any information that would jeopardize a  
               criminal investigation or proceeding.

             "Child welfare case files are large and contain information  
               about many parties, far beyond those contemplated in the  
               current version of the bill including mental health and  
               substance abuse histories and diagnoses pertaining to both  
               children and adults, information regarding the child's  
               caregivers and information about siblings and non-custodial  
               parents. Given this, we have the following concerns about  
               the current bill language:

               i)     " . . . various federal laws also require the  
                 maintenance of confidentiality for children, parents and  
                 guardians. For example, the Health Information  
                 Portability and Accountability Act (HIPAA) governs  
                 confidentiality of behavioral health and physical health  
                 record contained in the case files of which this would  
                 require disclosure.

               ii)    "There are a number of situations we can conceive of  
                 in which the redactions in this bill would not go far  
                 enough.  These redactions apply only to identifying  
                 information about other children, state and county staff  
                 and mandated reporters.  In contrast, case files contain  
                 information about any number of adults. In particular,  
                 providing sensitive information about a non-custodial  
                 parent, other adults in the family or the child's  
                 caregiver would be unnecessary and inappropriate if they  
                 had nothing to do with the child's death or injury or if  
                 the information that would be released had no connection  
                 to the fatality or near fatality. For example, case files  
                 include very detailed and thorough information about  
                 prospective adoptive parents, such as their marital  
                 history, their financial status, their medical and  
                 psycho-social information, and often information  
                 regarding their extended family.  We also believe that  
                 identifying information about the child who suffered the  
                 fatality or near fatality should not automatically be  
                 released. Even in death, we believe that abused children  
                 have a right to privacy. 

               iii)   "The provision of the bill which allows the  
                 custodian of the record to petition the court to provide  
                 for further redaction is an inadequate remedy for several  








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                 reasons.  First, it is an unreasonable and costly burden  
                 for under funded child welfare agencies and courts to  
                 petition for further redaction when it is almost certain  
                 that in each case there will be private and confidential  
                 information that is not relevant to the circumstances of  
                 the death or near death.  Second, the bill only allows  
                 for this petition in cases where the disclosure would be  
                 "seriously and unavoidably detrimental to the safety,  
                 protection, and physical or mental and emotional well  
                 being of another child," not if disclosure would be  
                 detrimental to other adults such as caregivers and adult  
                 relatives or the dead or injured child him- or herself,  
                 even if the information has no bearing on the  
                 circumstances of the death or near death.  

               "The CAPTA law specifically requires that states have in  
               place 'provisions which allow for public disclosure of the  
               findings or information about the case of child abuse or  
               neglect which has resulted in a child fatality or near  
               fatality.'  This does not require the release of entire  
               case records or court files.  . . .  The various approaches  
               that states have taken to comply with the CAPTA  
               requirements suggests that California could choose one of a  
               number of routes, each with its own implications for child  
               well-being and future child fatality prevention.  . . .  We  
               do not believe that the approach taken in this bill is the  
               most appropriate for the state, especially given our  
               concerns regarding the provision of sensitive, potentially  
               identifying information that may not be germane to a child  
               fatality or near fatality. 

               "Balancing the public's access to information about the  
               child welfare system with the privacy and confidentiality  
               of many individuals - often victims and those who step up  
               to help care for abused and neglected children - is a very  
               difficult and important endeavor.  Given the concerns that  
               we outline above, CWDA urges the inclusion of certain  
               amendments to remove our opposition to the approach  
               outlined in the bill.  Specifically, we request amendments  
               that would allow for the custodian of the record to redact  
               information relating to any individual whose information is  
               included in the case file, except for information germane  
               to ascertaining the cause or manner of the death or near  
               death.  We would also request a clarifying amendment that  
               allows for redaction of information that is prohibited from  








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               disclosure by other state or federal law.  Attached are  
               draft amendments related to these two requests. Finally, we  
               are happy to continue to work with the authors as the bill  
               moves to refine the definition of 'near fatality.'"

           8)Prior Legislation  :  SB 199 (Polanco) Chapter 984, Statutes of  
            1999, required juvenile courts, if petitioned, to release the  
            juvenile case file of a deceased child after interested  
            parties have had an opportunity to file an objection to the  
            release.  The court may prohibit or limit access to these case  
            files upon a showing that the release would be detrimental to  
            the well-being of another child connected to the case.  SB 199  
            allows any person to file a petition in juvenile court to open  
            the case file of a child, and requires that notice of the  
            petition be provided to interested parties who may file an  
            objection to the petition.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California District Attorneys Association
          Children's Advocacy Institute

           Opposition 
           
          California Public Defenders Association
          County Welfare Directors Association of California
           

          Analysis Prepared by  :    Heather Hopkins / PUB. S. / (916)  
          319-3744