BILL ANALYSIS                                                                                                                                                                                                    







                      SENATE COMMITTEE ON PUBLIC SAFETY
                             Senator Mark Leno, Chair                A
                             2009-2010 Regular Session               B

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                                                                     9
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          AB 999 (Skinner)                                            
          As Amended June 10, 2009
          Hearing date:  June 23, 2009
          Welfare and Institutions Code
          AA:br


                            DIVISION OF JUVENILE FACILITIES  


                                       HISTORY

          Source:  Books Not Bars

          Prior Legislation: SB 1373 (Romero) - 2006, vetoed by Governor  
          Schwarzenegger
                       SB 459 (Burton) - Ch. 4, Stats. 2003

          Support: California State PTA; National Center for Lesbian  
                   Rights; California State NAACP; Asian Americans for  
                   Civil Rights and Equality; California Public  
                   Defenders Association; California Catholic Conference  
                   of Bishops; Taxpayers for Improving Public Safety

          Opposition:SEIU Local 1000; California District Attorneys  
                   Association

          Assembly Floor Vote:  Ayes  45 - Noes  30


                                         KEY ISSUE
           
          SHOULD "TIME ADDS" - WHERE PAROLE DATES FOR DJJ WARDS ARE EXTENDED  




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                                                           AB 999 (Skinner)
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          AS A DISCIPLINARY SANCTION - BE PROHIBITED, AND REPLACED WITH A  
          SYSTEM WHERE DJJ WARDS CAN EARN TIME CREDITS BASED ON PROGRAMMING  
          AND GOOD BEHAVIOR, WITH THOSE CREDITS BEING SUBJECT TO FORFEITURE AS  
          A CONSEQUENCE OF DISCIPLINARY ACTION?



                                       PURPOSE

          The purpose of this bill is to revise the disciplinary system at  
          the Division of Juvenile Justice, where wards currently can be  
          disciplined with time extensions on their parole dates, by  
          prohibiting these "time adds" and instead providing a system  
          where wards can earn time credits based on programming and good  
          behavior, with those credits being subject to forfeiture as a  
          consequence of disciplinary action.

           Current law  provides that the Department of Corrections and  
          Rehabilitation, Division of Juvenile Justice ("DJJ"), has  
          jurisdiction over all educational training and treatment  
          institutions now or hereafter established and maintained in the  
          state as correctional schools for the reception of wards of the  
          juvenile court and other persons committed to the department.   
          (WIC  1000.)

           Current law  provides that the following powers and duties shall  
          be exercised and performed by the Division of Juvenile  
          Facilities:  return of persons to the court of commitment for  
          redisposition by the court, determination of offense category,  
          setting of parole consideration dates, conducting annual  
          reviews, treatment program orders, institution placements,  
          furlough placements, return of nonresident persons to the  
          jurisdiction of the state of legal residence, disciplinary  
          decisionmaking, and referrals pursuant to Section 1800.  (WIC   
          1719 (c).)

           This bill  would revise this provision to require biannual  
          (occurring twice a year) reviews.

           This bill  additionally would add "program time credits" and  




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                                                           AB 999 (Skinner)
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          "good behavior time credits" to this provision.

          Program Time Credits
          

           This bill  would require that program time credits "apply for  
          satisfactory performance in education, rehabilitation,  
          therapeutic, work, and other programs meant to prepare a ward  
          for successful reentry into society."



           This bill  would require that "(f)or every day of satisfactory  
          performance in one or more credit qualifying programs, as  
          designated by the Chief Deputy Secretary for Juvenile Justice,  
          the parole consideration date of a ward shall be advanced no  
          less than one day earlier."



           This bill  would provide that for these purposes "satisfactory  
          performance" would mean "progress in a credit-qualifying  
          program, such as any one of the following:  completion of  
          assigned work, continuing or improved participation in  
          programming or class work, continuing or improved cooperation  
          with the instructor or person in charge, substantial compliance  
          with instructions, or meeting requirements for participation in  
          assigned activity."



           This bill  would provide that "(f)ailure to work or participate  
          in program activities for reasons which are beyond the ward's  
          control shall not be cause for denial or forfeiture of  
          participation credit.  These circumstances may include, but are  
          not limited to, the following:

               (A)      The ward has not been given instructions,  
          an order, or an assignment to perform or participate in  
          educational, vocational, or program activities.




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               (B)      The ward's work or program assignment has  
          been temporarily suspended or permanently terminated, and  
          the ward has not been admitted into another educational,  
          vocational, or rehabilitative program.

               (C)      The ward is medically excluded or  
          restricted from work or program activities, either on a  
          temporary basis because of illness or injury, or on a  
          permanent basis because of medically diagnosed physical  
          or mental inability to participate.

               (D)      The ward has failed to perform or  
          participate after demonstrating a reasonable effort in  
          the specified activity.

               (E)      The ward is restricted from reporting to or  
          participating in an assigned work or program activity by  
          an order or action of institution staff unrelated to a  
          disciplinary infraction by the ward.

               (F)      The ward's behavior is the result of mental  
          illness or its treatment."



          Good Behavior Time Credits

          

           This bill  would require that "(g)ood behavior time credits shall  
          be provided independently of program credit for substantial  
          compliance with rules of the institution, and substantial  
          compliance with instructions from staff, the instructor, or the  
          person in charge."



           This bill  would require that "(f)or every day of substantial  
          compliance with disciplinary rules and instructions, a ward  




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                                                           AB 999 (Skinner)
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          shall have his or her parole consideration date advanced no less  
          than one-half day."

           Current law  requires DJJ to:

              promulgate policies and regulations implementing a  
              departmentwide system of graduated sanctions for  
              addressing ward disciplinary matters.  The  
              disciplinary decisionmaking system shall be employed  
              as the disciplinary system in department  
              institutions, and shall provide a framework for  
              handling disciplinary matters in a manner that is  
              consistent, timely, proportionate, and ensures the  
              due process rights of wards.  The department shall  
              develop and implement a system of graduated sanctions  
              which distinguishes between minor, intermediate, and  
              serious misconduct.  The department may extend a  
              ward's parole consideration date, subject to appeal  
              pursuant to subdivision (b), from one to not more  
              than 12 months, inclusive, for a sustained serious  
              misconduct violation if all other sanctioning options  
              have been considered and determined to be unsuitable  
              in light of the ward's previous case history and the  
              circumstances of the misconduct.  In any case in  
              which a parole consideration date has been extended,  
              the disposition report shall clearly state the  
              reasons for the extension.  The length of any parole  
              consideration date extension shall be based on the  
              seriousness of the misconduct, the ward's prior  
              disciplinary history, the ward's progress toward  
              treatment objectives, the ward's earned program  
              credits, and any extenuating or mitigating  
              circumstances.  The department shall promulgate  
              regulations to implement a table of sanctions to be  
              used in determining parole consideration date  
              extensions.  The department also may promulgate  
              regulations to establish a process for granting wards  
              who have successfully responded to disciplinary  
              sanctions a reduction of up to 50 percent of any time  
              acquired for disciplinary matters."  (WIC  1719  




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              (d).)

           This bill  would revise this section as follows:
           
          This bill  would delete the requirement in this provision that  
          DJJ develop and implement a system of graduated sanctions which  
          distinguishes between minor, intermediate, and serious  
          misconduct.

           This bill  would delete the authority in this section for DJJ to  
          extend a ward's parole consideration date, as specified, and  
          instead provide that DJJ shall not extend or postpone a ward's  
          parole consideration date.

           This bill  instead would provide that sanctions for sustained  
          serious misconduct may include forfeiture of not more than six  
          months of combined program and good behavior credits established  
          by this bill, if all other sanctioning options have been  
          considered and determined to be unsuitable in light of the  
          ward's previous case history and the circumstances of the  
          misconduct.

           This bill  would provide that "(i)n any case in which a program  
          time or good behavior credit has been forfeited, the disposition  
          report shall clearly state the reasons for the forfeiture."

           This bill  would provide that the "length of any credit  
          forfeiture shall be based on the seriousness of the misconduct,  
          the ward's prior disciplinary history, the ward's progress  
          toward treatment objectives, the ward's earned program or good  
          behavior credits, and any extenuating or mitigating  
          circumstances."

           This bill  would require DJJ to "promulgate regulations to  
          implement a table of sanctions to be used in determining program  
          or good behavior time credit forfeitures," and regulations to  
          "establish a process for granting wards who have successfully  
          responded to disciplinary sanctions a reinstatement of up to 100  
          percent of any credit forfeited for disciplinary matters."





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           This bill  would require that a "document signed by a department  
          official shall be provided to each ward describing what defines  
          'serious misconduct.' "


           This bill  would require DJJ to "periodically review the ward's  
          program credits and good behavior credits and forfeitures, if  
          any," no less than every six months.



           This bill  would require that, at "each review, a ward's parole  
          consideration date shall be adjusted according to the net credit  
          earned since the last review."



           This bill  would require that program credits earned before  
          January 1, 2010, be honored.



           This bill  would require DJJ to "allow wards who received parole  
          consideration date extensions after January 1, 2009, and before  
          January 1, 2010, and who have successfully responded to  
          disciplinary sanctions a reinstatement of up to 100 percent of  
          the time added."



           This bill  would provide that nothing in this section would  
          "preclude the division from providing credits or other  
          incentives for other desirable behaviors or program  
          participation."
          
                    RECEIVERSHIP/OVERCROWDING CRISIS AGGRAVATION
          
          California continues to face a severe prison overcrowding  
          crisis.  The Department of Corrections and Rehabilitation (CDCR)  
          currently has about 170,000 inmates under its jurisdiction.  Due  




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          to a lack of traditional housing space available, the department  
          houses roughly 15,000 inmates in gyms and dayrooms.   
          California's prison population has increased by 125% (an average  
          of 4% annually) over the past 20 years, growing from 76,000  
          inmates to 171,000 inmates, far outpacing the state's population  
          growth rate for the age cohort with the highest risk of  
          incarceration.<1>

          In December of 2006 plaintiffs in two federal lawsuits against  
          CDCR sought a court-ordered limit on the prison population  
          pursuant to the federal Prison Litigation Reform Act.  On  
          February 9, 2009, the three-judge federal court panel issued a  
          tentative ruling that included the following conclusions with  
          respect to overcrowding:

               No party contests that California's prisons are  
               overcrowded, however measured, and whether considered  
               in comparison to prisons in other states or jails  
               within this state.  There are simply too many  
               prisoners for the existing capacity.  The Governor,  
               the principal defendant, declared a state of emergency  
               in 2006 because of the "severe overcrowding" in  
               California's prisons, which has caused "substantial  
               risk to the health and safety of the men and women who  
               work inside these prisons and the inmates housed in  
               them."  . . .  A state appellate court upheld the  
               Governor's proclamation, holding that the evidence  
               supported the existence of conditions of "extreme  
               peril to the safety of persons and property."  
               (citation omitted)  The Governor's declaration of the  
               state of emergency remains in effect to this day.

               . . .  the evidence is compelling that there is no  
               ----------------------
          <1>  "Between 1987 and 2007, California's population of ages 15  
          through 44 - the age cohort with the highest risk for  
          incarceration - grew by an average of less than 1% annually,  
          which is a pace much slower than the growth in prison  
          admissions."  (2009-2010 Budget Analysis Series, Judicial and  
          Criminal Justice, Legislative Analyst's Office (January 30,  
          2009).)



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               relief other than a prisoner release order that will  
               remedy the unconstitutional prison conditions.

               . . .

               Although the evidence may be less than perfectly  
               clear, it appears to the Court that in order to  
               alleviate the constitutional violations California's  
               inmate population must be reduced to at most 120% to  
               145% of design capacity, with some institutions or  
               clinical programs at or below 100%.  We caution the  
               parties, however, that these are not firm figures and  
               that the Court reserves the right - until its final  
               ruling - to determine that a higher or lower figure is  
               appropriate in general or in particular types of  
               facilities.

               . . .

               Under the PLRA, any prisoner release order that we  
               issue will be narrowly drawn, extend no further than  
               necessary to correct the violation of constitutional  
               rights, and be the least intrusive means necessary to  
               correct the violation of those rights.  For this  
               reason, it is our present intention to adopt an order  
               requiring the State to develop a plan to reduce the  
               prison population to 120% or 145% of the prison's  
               design capacity (or somewhere in between) within a  
               period of two or three years.<2>

          The final outcome of the panel's tentative decision, as well as  
          any appeal that may be in response to the panel's final  
          decision, is unknown at the time of this writing.

          --------------------------
          <2>  Three Judge Court Tentative Ruling, Coleman v.  
          Schwarzenegger, Plata v. Schwarzenegger, in the United States  
          District Courts for the Eastern District of California and the  
          Northern District of California United States District Court  
          composed of three judges pursuant to Section 2284, Title 28  
          United States Code (Feb. 9, 2009).



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           This bill  does not aggravate the prison overcrowding crisis  
          outlined above.

                                      COMMENTS

          1.  Stated Need for This Bill
           
          The author states in part:

              The state Division of Juvenile Justice does not have  
              clear statutory authority to provide program credits  
              to wards for participation in education and  
              rehabilitation programs.  There is in imbalance in  
              the use of credits and disciplinary delays in parole  
              consideration that results in wards . . . serving  
              disproportionately long terms in state youth prisons,  
              when compared to youth in other states incarcerated  
              for similar offenses.  As there is no aggregate  
              correlation between longer DJJ prison terms and  
              improved public safety, or improved outcomes for  
              wards or their families, it is necessary to address  
              these ineffective and costly sentencing and parole  
              policies.

              Youth held in (DJJ) do not have the same rights as  
              adult prisoners in California to earn program credits  
              for satisfactory participation in programs of  
              education, job training and rehabilitation.  This  
              bill would create a discipline and incentive system  
              that would allow wards to earn credit - not toward  
              early release per se - but to an earlier parole  
              consideration hearing.  The bill also provides that  
              earned programs credits may be forfeited for serious  
              misconduct.

              Research demonstrates that punishment models are  
              ineffective at changing youths' behavior, both inside  
              and out of prison settings.   In contrast, positive  
              behavior incentives have been shown to have a  
              dramatic impact in reducing problem behaviors.




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              Youth in California's youth prison system serve the  
              longest sentences in the nation.  . . .  Based on an  
              indeterminate sentencing scheme, youth are imprisoned  
              in (DJJ) an average of nearly 3 years.  More than a  
              third of that time is due to "time adds."  Time adds  
              are disciplinary sanctions that may delay parole  
              consideration dates by up to one year, for each  
              sanction. . . .

              DJJ spends approximately $234,000 per youth, per year  
              to hold a youth behind bars.  According to data from  
              the Department of Corrections and Rehabilitation,  
              time adds tack on an additional net average of 12.7  
              months to each ward's period of incarceration.  That  
              amounts to $247,650 in additional expenses for each  
              youth at DJJ.  For the entire population of youth  
              currently at DJJ, time-adds cost the taxpayers over  
              $418,528,500.  As there is no relationship between  
              longer terms and better outcomes for wards or  
              communities, this is money wasted. . . .  (citations  
              omitted.)

          2.  What This Bill Would Do
           
          This bill addresses the use of "time adds" - disciplinary  
          sanctions which extend a ward's parole date - as a disciplinary  
          sanction for wards in DJJ institutions.  This bill would limit  
          time sanctions to program or good behavior time credits which  
          have been earned by wards.  In this way, under this bill a  
          ward's Projected Board Date ("PBD") - essentially his or her  
          parole date - would be the ward's maximum term, with the  
          possibility of a shorter term based upon program and behavior  
          credits earned and not forfeited through disciplinary action.   
          In this way, this bill would limit time-based discipline  
          sanctions to the forfeiture of time-reduction credits.

          Current law authorizes the extension of a ward's PBD as a  






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          disciplinary sanction.<3>  These extensions are known as "time  
          adds."  Current law also authorizes DJJ to establish a process  
          for granting wards credits based on their progress in meeting  
          specified programming objectives.  Wards also can gain time  
          credits for successfully responding to disciplinary sanctions -  
          that is, credits that reduce time adds.



          This bill would change this framework and  prohibit time adds  .   
          The bill instead would employ new program and good behavior time  
          credits as potential disciplinary sanctions through forfeiture.   
          In other words, instead of the current system, which disciplines  
          wards with time adds and allows them to "earn back" disciplinary  
          time adds, this bill would provide a system where wards could  
          earn time credits based on programming and good behavior,  with  
          those credits being subject to forfeiture as a consequence of a  
          disciplinary action  .  This bill would repeal DJJ's authority to  
          extend a ward's parole consideration date.<4>  Instead, the bill  
          provides a statutory framework under which disciplinary  
          sanctions would include forfeiture of credits.  This bill would  
          provide for day-for-day program credits and not less than  
          1-for-2 days "good behavior time credits," as specified.

          DJJ would be required to implement a table of sanctions for time  
          credit forfeitures, and a process for restoring forfeited  
          credits based on ward conduct, as specified.  The bill would  
          require that the length of credit forfeiture be based on the  
          seriousness of the misconduct, the ward's prior disciplinary  
          history, the ward's progress toward treatment objectives, the  
          ward's earned program or good behavior credits, and any  
                                                                      extenuating or mitigating circumstances.

          ---------------------------
          <3>  This sanction is described in the division's "Disciplinary  
          Decision Making System" policy (the "DDMS"), most recently  
          revised in January of this year.
          <4>  The term "parole consideration date" has been replaced with  
          the term "Projected Board Date."  This is the date set for a  
          ward's parole.  The author may wish to consider amending this  
          bill to reflect this new term.



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          The bill contains additional, related provisions.


          3.  General Background - DJJ
           
          For the past several years, the Division of Juvenile Justice  
          ("DJJ"; formerly the California Youth Authority) has been under  
          intense scrutiny and criticism because of violence in its  
          institutions, ward suicides, and the failure to provide mandated  
          education and treatment to wards, most of whom have significant  
          mental health problems.  The DJJ currently is under a  
          court-ordered consent decree to improve its conditions pursuant  
          to a class action lawsuit brought by the Prison Law Office  
          (Farrell v. Warner).

          In the mid-1990's, the DJJ population exceeded 10,000; now,  
          there are about 1,650 wards in DJJ institutions, and another  
          1,970 on parole.  Current DJJ spending is about $380 million for  
          operations, with about $35 million for parole.

          The significant decline in the DJJ population is due largely to  
          the following circumstances:

                  Recent Realignment Restricted DJJ to only  
               serious/violent offenders  :  In SB 81 (2007),  
               lower-level juvenile offenders were excluded from  
               eligibility for DJJ commitment.  As a result, DJJ  
               population has dropped from 2,500 in fall of 2007 to  
               1,650 today.



                  Decline in Juvenile Crime  .  California has  
               experienced a remarkable decline in serious juvenile  
               crime.  For example, between 1991 and 2000 juvenile  
               arrests for homicide fell from 969 to 160.  Between  
               1990 and 2001, the rate of juveniles committing felony  
               offenses dropped 47 percent (far outpacing the 25  
               percent decline for adults during the same period).





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                  Transfer of "M" Cases  .  In June of 1994, the law  
               was changed to prohibit convicted young adults - those  
               under 21 - from being committed to CYA; as a result,  
               824 young inmates were transferred from CYA to the  
               Department of Corrections ("CDC").

                  Introduction of "Sliding Scale"  .  Prior to 1995,  
               counties paid only $25 per month for wards committed  
               to CYA.  The Legislative Analyst's Office and others  
               found that this low rate allowed some counties to send  
               very low-level offenders to CYA, even though CYA was  
               (and remains) an extremely expensive placement option.  
                In 1995, legislation was enacted to establish a new  
               fee structure that charged counties an increasing  
               share of CYA's actual costs depending upon the nature  
               of the committing offense.  This has provided a fiscal  
               incentive to keep youthful offenders in local  
               placements when appropriate.

                  Development of Local Prevention Programs and  
               Detention Alternatives .  Beginning in the mid-1990's,  
               as the state was tightening commitments to CYA through  
               fiscal incentives, it simultaneously was increasing  
               state funding for local juvenile justice programs,  
               which handle the great majority of California's  
               delinquency population.

          4.  Time Adds
           
          Three years ago, this Committee considered and passed SB 1373  
          (Romero), which attempted to address time adds.<5>  Observations  
          made by juvenile justice expert David Steinhart in support of  
          that measure equally apply to this bill:

              Currently, wards committed to DJJ serve an  
              indeterminate sentence, subject to specific legal  
              maximums (top juvenile court jurisdictional age, top  
              DJJ jurisdictional age and maximum confinement time  
              in relation to adult determinate sentence laws).   


              ----------------------
          <5>  That measure was vetoed by Governor Schwarzenegger.



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              Upon commitment, each ward is given a Parole  
              Consideration Date (PCD) by DJJ.  This date is  
              considered to be the earliest date within the  
              indeterminate sentence framework that the ward will  
              be eligible for release on parole.  The PCD is  
              determined using sentencing guidelines promulgated by  
              the now-repealed Youthful Offender Parole Board  
              (YOPB).  



              Those guidelines (at 15 CCR Sections 4951-57)  
              establish presumptive sentence lengths for seven  
              offense categories, from the most severe and violent  
              offenses (Category I) to the least severe (Category  
              VII).  For each category there is a baseline sentence  
              or PCD, in years, with allowance for assigning a  
              longer initial sentence that is within an "upward  
              deviation" range allowed for each category.  For  
              example, for a Category 4 offense such as arson or  
              drug sales, the juvenile will get a baseline PCD of  
              two institutional years with an upward deviation of  
              six months assignable at the initial hearing.  These  
              initial sentences can be extended for other reasons,  
              including disciplinary incidents, at subsequent  
              review hearings.

              . . .

              Time adds have been a chronic problem at CYA and DJJ  
              for decades.  Commonweal's 1988 book, Reforming the  
              CYA, described the "vicious circle" of time adds and  
              institutional violence as follows:  "In crowded  
              dormitories, fights break out causing youth to have  
              their confinement time extended.  The time adds  
              create more crowding which in turn sparks more  
              violence" (at page 24).  Time adds, according to this  
              1988 book, averaged 7.9 months for each youth  
              discharged in 1986-87 - hauntingly similar to today's  
              figures.  The book cited case examples, such as the  




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              16 year old Hispanic youth committed for the crime of  
              glue sniffing who had 15 months added to his original  
              sentence.

              Time adds have other effects, besides population and  
              cost effects, in the present DJJ system.  A widely  
              recognized problem related to ward behavior and  
              violence in DJJ institutions is "maxing out" of  
              available confinement time.  Wards who reach their  
              statutory maximum confinement time, or nearly so, may  
              lack incentive to cooperate with institutional  
              requirements.  Time adds push wards toward max time  
              and toward the tipping point at which custodial  
              sanctions (such as extended PCDs) may no longer be  
              effective.





























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          The following chart depicts time adds and cuts at DJJ by month  
          for November 2007 through November 2008.<6>  As demonstrated by  
          this chart, time adds greatly outweigh time cuts.


          ARE "TIME ADDS" AN APPROPRIATE SANCTION FOR WARDS WHO HAVE  
          COMMITTED SERIOUS CONDUCT VIOLATIONS?



          WOULD THE SYSTEM OF CREDITS AND CREDIT FORFEITURES PROPOSED BY  
          THIS BILL BE A BETTER SANCTION THAN TIME ADDS?


          5.  Opposition

           SEIU, Local 1000, which represents the non-custodial staff such  
          as teachers, nurses, cooks and clerks at DJJ facilities, opposes  
          this bill, argues this bill "may inadvertently lead to less  
          effective control of juveniles who would no longer be concerned  
          about their parole date being extended as a result of their  
          behavior.  While this may not be the best tool to use, we are  
          concerned that the possible closing of juvenile facilities will  
          lead to larger classroom sizes and commensurate problems with  
          control of the ward's behavior."

          The California District Attorneys Association, which also  
          opposes this bill, argue that features of a determinate  
          sentencing system - credits - should not be applied to minors  
          who have been given indeterminate commitments.

              The purpose of youth incarceration has more  
              traditionally been focused on rehabilitation and  
              therefore (credit-earning programs) should be a part  
              of their programming on the natural, not an extra  
              incentive to have their sentence reduced.  . . .  Time  
              adds . . . are a meaningful sanction and we are not  

              ----------------------
          <6>  CDCR Division of Juvenile Justice, Monthly Population  
          Trends, November 2008.



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              convinced that sufficient reason has been provided to  
              abolish their use.  Over the last 13 years, the DJF  
              population has shrunk from approximately 10,000 wards  
              to fewer than 1,700.  Those who are left in the system  
              are, for the most part, hardcore juvenile offenders  
              and we should not hamstring DJF in its oversight of  
              those wards.

          WOULD THIS BILL RESULT IN LESS EFFECTIVE CONTROL OF YOUTHFUL  
          OFFENDERS IN DJJ FACILITIES?  OR, WOULD ITS CREDIT FORFEITURE  
          PROVISIONS BE AT LEAST AS EFFECTIVE AS THE CURRENT "TIME ADD"  
          SYSTEM?

          ARE TIME ADDS AN APPROPRIATE AND EFFECTIVE SANCTION FOR WARD  
          DISCIPLINE?  WOULD THE CREDIT FORFEITURE APPROACH PROPOSED BY  
          THIS BILL PROVIDE A BETTER SANCTION FOR WARD DISCIPLINE?

          ARE PROGRAM TIME CREDITS APPROPRIATE FOR YOUTH WHO HAVE BEEN  
          COMMITTED TO DJJ?



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