BILL ANALYSIS
AB 1170
Page 1
Date of Hearing: April 21, 2009
Counsel: Gabriel Caswell
ASSEMBLY COMMITTEE ON PUBLIC SAFETY
Jose Solorio, Chair
AB 1170 (Calderon) - As Amended: April 15, 2009
SUMMARY : Requires the Department of Justice (DOJ) to make
available to the public a consumer information booklet providing
federal and state laws relating to sex offender registration as
it relates to the lease or rental of real property.
Specifically, this bill :
1)States that the information contained in the booklet shall
contain the following information:
a) General information concerning federal and state laws
relating to persons who are required to register pursuant
to Penal Code Section 290 as specified sex offenders.
b) Information regarding specified statutory disclose
duties contained in the Civil Code to a prospective
resident.
c) A discussion about legal access and use of information
contained in DOJ's Internet Web site.
d) Identification of the constitutional, statutory, and
decisional law applicable to this section.
2)Provides that if the consumer information booklet is delivered
to a prospective or current resident by the owner or owner's
agent in connection with the lease or rental of residential
real property, the owner or owner's agent is not required to
provide additional information on the subject.
3)Specifies that this section does not alter the duty of an
owner or owner's agent to report and otherwise act on the
existence of known illegal activity on or affecting the real
property and nothing in this section alters any existing duty
of an owner or owner's agent under any other statute or
decisional law.
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4)Stated that in the development of the consumer information
booklet, the DOJ shall consult with the Department of Consumer
Affairs and public and private organizations having a
demonstrated interest in this area of the law.
5)Creates the "Megan's Law Disclosure Booklet for Landlords and
Tenants Fund" and continuously appropriates voluntary
contributions or donations received into the fund to DOJ to
pay costs directly associated with the consumer information
booklet, and provides that DOJ need not incur any cost
associated with the provisions of this bill until sufficient
contributions to the fund have been deposited.
EXISTING LAW :
1)Establishes a three-tiered system for providing the public
with information via an Internet Web site maintained by DOJ
regarding persons required to register as sex offenders (the
"Megan's Law database"). Depending upon the severity of the
sex offense, information is available as to some sex offenders
with their specific home addresses, while others are
identified only by ZIP code and community of residence.
(Penal Code Section 290.46.)
2)Provides that DOJ shall make available to the public via the
Internet Web site the following information regarding
specified sex offenders:
a) His or her name or names and known aliases;
b) A photograph;
c) A physical description, including gender and race;
d) Date of birth;
e) Criminal history;
f) The address at which the person resides; or the person's
zip code and community of residence, as specified; and,
g) Any other information the DOJ considers relevant and is
not excluded by law.
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3)States that, except as otherwise provided, it is unlawful to
use any of the information that is disclosed pursuant to this
section for purposes related to health insurance, insurance,
loans, credit, employment, education, scholarships or
fellowships, housing or accommodations, and benefits,
privileges or services provided by any business establishment.
[Penal Code Section 290.46(j)(2).]
4)Provides that a person is authorized to use information
disclosed pursuant to the Megan's Law database may be
disclosed only to protect a person at risk. [Penal Code
Section 290.46(j)(1).]
5)Requires a person convicted of specified sex offenses to
register with law enforcement officials, as specified, within
five working days of coming into a city or county where he or
she is domiciled. Registration is for a lifetime, must be
updated annually, and must be completed on a form provided by
DOJ. (Penal Code Section 290.)
6)Establishes a system for providing the public with information
about registered persons via an Internet Web site maintained
by the DOJ (the Megan's Law database). Depending upon the
severity of the sex offense, information is available as to
some sex offenders with their specific home addresses, while
others are identified only by ZIP code and community of
residence. The following information is contained in the
database: name or names and known aliases; a photograph; a
physical description, including gender and race; date of
birth; criminal history; address at which the person resides;
or the person's ZIP code and community of residence, as
specified; and any other information the DOJ considers
relevant and not excluded by law. (Penal Code Section 290.)
7)Provides that a lease or rental agreement to a registered sex
offender contain a notice regarding the availability of
Megan's Law information from a local law enforcement agency or
on the DOJ Megan's Law Web site, and generally provides that
upon delivery of this notice to the lessee the lessor is not
required to provide any additional information other than that
regarding proximity of sex offenders. (Civil Code Section
2079.10a.)
8)Provides that it is unlawful to use any of the information
that is disclosed pursuant to [the Megan's Law registration
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requirement] for purposes related to housing or
accommodations, benefits, privileges or services provided by
any business establishment, insurance, loans, credit,
employment, education, scholarships or fellowships, except to
the extent authorized by law. [Penal Code Section
290.46(l)(2).]
9)Provides that a person is authorized to use information
disclosed pursuant to the Megan's Law database only to protect
a person at risk. [Penal Code Section 290.46(l)(1).]
10)Provides that everyone is responsible, not only for the
result of his or her willful acts, but also for an injury
occasioned to another by his or her want of ordinary care or
skill in the management of his or her property or person,
except so far as the latter has, willfully or by want of
ordinary care, brought the injury upon himself or herself.
(Civil Code section 1714.)
FISCAL EFFECT : Unknown
COMMENTS :
1)Author's Statement : According to the author, "[t]here is a
pervasive misunderstanding as to Megan's Law. The DOJ
maintains the website and disclosure of the existence of the
Web site is required in all rental and lease contracts yet,
there is no additional information about what that means, what
a consumer may do with that information and what a consumer
may do if he or she has actual knowledge of the location of a
registered sex offender. The maxim of knowledge is power
would be particularly helpful to consumers if that information
is presented in a consumer friendly manner. Further, there
are a number of people offering different opinions as to
current law and it would be particularly helpful IF the DOJ
were to development a booklet as to the status of the law.
Some people claim that there are certain aspects to Megan's
Law that are not clear, and if that is the case, we are asking
the DOJ to so simply state that fact. We submit that a better
understanding will assist all involved in this issue. The
bill does not require the DOJ to write a consumer oriented
booklet and the DOJ is authorized to delay incurring any costs
associated with the implementation of the bill until
sufficient voluntary private contributions have been deposited
in the state General Fund, therefore there would be no direct
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fiscal affect upon the state. Further, the state is not
required to publish the booklet, which is an archaic method of
distributing helpful information to consumers. The DOJ would
distribute the booklet electronically and could post it on the
DOJ Web site such as it does for all of the other DOJ consumer
booklets. Finally, we have successfully worked with the
consumer attorneys association to address their concerns about
liability issues. When the bill is amended on or about April
14, the consumer attorneys will be neutral on the bill."
2)Megan's Law Background : California law requires individuals
to register as sex offenders upon conviction of certain
enumerated crimes. Convictions that require registration as a
sex offender include rape, sexual battery, transporting a
child for lewd or lascivious acts, sexual assault of a child,
incest, sodomy and indecent exposure. Since 1996, under the
law commonly known as "Megan's Law," the identity and
residence (by ZIP code) of registered, "high-risk" sex
offenders are subject to public disclosure by law enforcement
upon telephone request or by viewing of the publicly available
information distributed to, and made publicly available by,
local law enforcement, as specified.
In 2004, AB 488 (Parra), Chapter 745, Statutes of 2004,
effective September 24, 2004, requires DOJ to implement an
Internet web site (the "Megan's Law Web site") listing the
convicted sex offenders and, in some cases, their specific
home addresses. The Megan's Law Web site became available to
the public in July 2005.
The effects of making specific home addresses of sex offenders
available on the Internet are not yet fully known, although
some groups have speculated about potential economic damages
and civil liability of apartment house owners and nursing
homes that rent to or house sex offenders. In response, AB
2712 (Leno), of the 2005-06 Legislative Session, was
introduced to clarify the non-liability of a residential
property owner when he or she rents to a sex offender and when
he or she notifies other tenants of the existence of the
Megan's Law Web site. AB 2712 was vetoed.
3)This Bill Requires DOJ to Issue and Publish Legal Opinions as
to Federal and State Law that Is Constantly Changing and
Untenable : This bill requires that the DOJ publish a booklet
that can be distributed to tenants in California which
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contains identifies "the constitutional, statutory, and
decisional law applicable to this section." This will require
the DOJ to render a legal opinion affecting the liability of
landlord/tenant relationship in a novel, developing, and ever
changing area of the law.
Questions will arise as to whether landlords or tenants act in
good faith upon the information opined by the DOJ. This
provision could shift liability for violations of the law
between parties and potentially upon the DOJ.
Additionally, the requirement that the DOJ provide this
booklet will add costs to DOJ's budget. Office resources and
attorney time will have to constantly be expanded to track,
maintain, research, and publish a vast number of booklets for
distribution. Finally, DOJ's Office of Victim Services, which
would have been responsible for the publication of this
booklet, was eliminated in the most recent budget and DOJ is
unclear where the resources for providing this information
will come from.
4)Purpose of Public Access to the Megan's Law Information via
the Internet : According to the author of AB 1184 (Spitzer),
of the 2003-04 Legislative Session, "The purpose of Megan's
Law is to provide the public with information that will allow
them to protect themselves and their families from convicted
sex offenders. It can only be successful when the public
knows that information. [O]ur system does not treat
dissemination of truthful information in furtherance of a
legitimate governmental objective as punishment. The Court
rejected the argument that dissemination of this information
on the Internet was overbroad and that this constituted
punishment."
Many other bills dealing with Megan's Law repeated similar
statements about the importance of providing the public with
information that will allow them to protect themselves and
their families. Megan's Law was placed on the Internet as an
instrument that would provide parents with knowledge in order
to take whatever protective action deemed necessary. Since
2005, Megan's Law has been on the Internet and all of this
knowledge has been in a more accessible public realm. If the
arguments of 2003 and 2004 were to be believed, the necessary
knowledge is now being provided in the most accessible manner
possible.
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5)The Governor's High Risk Sex Offender Task Force : This Task
Force, after many months of meetings and deliberation,
reported the following: "The critical issue of housing for
High Risk Sex Offenders was one of the main factors leading to
the formation of the task force . . . No viable long-term
solutions were identified in the 90 days available prior to
the dissolution of the task force . . . . Therefore, the task
force recommends that this committee continue to convene to
further address this issue.
" . . . The lack of a stable residence for an HRSO places the
community at risk. Homeless sex offenders cannot be
effectively tracked and monitored by parole agents and local
law enforcement. Communities and victims are unaware of their
location and presence, which adds to the uncertainty that
offenders are being supervised."
Thus, the Governor's Task Force recommended that the issue of
housing continue to be studied as it recognized that the lack
of a stable residence places the entire community at risk.
The need for a definitive study is underscored not only by the
Task Force recommendations but by the cited legal authorities
which have held, in as many ways as possible, that
presumptions are to be based on common experience that, if a
fact exists in one case, it exists in most cases. There exist
no widely held beliefs or common experiences regarding the
risk posed by sex offenders other than those cited above which
indicate that sex offenders pose less risk of re-offending
than do other persons convicted of crimes. If a logical
presumption were to be based upon common experience (and
scientific study), that presumption would be the polar
opposite of that created by this bill. All of the scientific
literature proves that sex offenders pose less risk of
recidivism than almost every other ex-felon tracked by the
United States DOJ.
6)Affirmative Restraint : In determining that sex offender
registration statutes are, in general, constitutional, the
United States Supreme Court identified a number of factors to
be considered in determining whether the sex offender
requirements were punitive in nature, or merely a civil
regulatory scheme. [Smith v. Doe, 538 U.S. 84 (2003).] The
factors are whether the regulatory scheme: (a) has
historically been regarded as punishment; (b) imposes an
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affirmative disability or restraint; (c) promotes the
traditional aims of punishment; (d) has a rational connection
to a non-punitive purpose; or, (e) is excessive with respect
to this purpose.
In analyzing Alaska's sex offender registration requirements,
the United States Supreme Court found that "our system does
not treat dissemination of truthful information in furtherance
of a legitimate governmental objective as punishment. In
contrast to the colonial shaming punishments, the State does
not make the publicity and the resulting stigma an integral
part of the objective of the regulatory scheme. . . . The
purpose and principle effect of notification are to inform the
public for its own safety . . . . " (Id. at page 99.)
The Supreme Court noted that the act does not restrain
activities sex offenders may pursue but leaves them free to
change jobs or residences, stating "the record in this case
contains no evidence that the [sex offender registration laws]
have led to substantial occupational or housing disadvantages
for former sex offenders that would not otherwise have
occurred through the use of routine background checks . . . .
" (Id. at page 100.)
The clear implication from this discussion is that to the extent
the sex offender registration and public notification laws
impose substantial housing disadvantages on former sex
offenders, the effect of such laws might more easily be
determined to be punitive rather than regulatory. To the
extent use of the Megan's Law database information imposes an
affirmative duty or restraint on registrants which is greater
than minor or indirect, the effect is more likely to be
determined punitive. If the law is determined to be punitive
in nature, constitutional validity under the ex post facto
provisions is called into question. [Id. at page 99, citing
Kennedy v. Mendoza-Martinez, 372 U.S. 144, 168 (1963).]
The Smith Court concluded that "whether other constitutional
objections can be raised to a mandatory reporting requirement,
and how those questions might be resolved, are concerns beyond
the scope of this opinion. It suffices to say the
registration requirements make a valid regulatory program
effective and do not impose punitive restraints in violation
of the Ex Post Facto Clause." (Smith, supra, at page 102.)
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Inasmuch as the United States Supreme Court specifically
discussed affirmative restraints on housing in its
consideration of the constitutionality of the Alaska sex
offender notification laws and also left the door open to
"whether other constitutional objections can be raised to a
mandatory reporting requirement," it appears reasonable that
this bill's expression of the right of any person, including
rental housing providers, to deny housing, services, benefits
or otherwise discriminate against registered sex offenders,
would be subject to constitutional challenge.
7)California Registered Sex Offenders : According to a
California Coalition on Sexual Offending (CCOSO) report, Using
the Internet to Provide Passive Community Notification About
Registered Sex Offenders, "Because California has been
requiring certain sex offenders to register since the mid
1940's, far longer than any other state, California's
cumulative total of registered sex offenders is much larger,
both in absolute numbers and proportionately, than the total
for any other state." According to the report, approximately
one out of every 180 adult males in California could be posted
on the Internet as sex offenders.
As of May 2003 (citing DOJ statistics), the report states there
were 100,501 registered sex offenders in California. Of that
number, 1,836 were classified as "high risk" and 82,190 as
"serious." It is those two groups who are subject to the
current Internet notification system. A third group of
registered sex offenders were convicted of crimes not
currently subject to public notification.
According to CCOSO, of the high risk and serious groups, 55,902
were living in the community, 14,556 had returned to jail or
prison, 10,800 had left the state, and 2,768 had been
deported. Altogether, 70,458 California residents (almost all
of them adult males) are subject to notification under the
present system. According to the CCOSO report, approximately
one of every 123 adult males in California is a registered sex
offender, although some of these have left the state or failed
to re-register as required.
The CCOSO report notes that in addition to the registered sex
offenders, there is a potentially large number of additional
individuals who are also impacted by Internet notification and
related actions, including parents, children, siblings, other
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relatives, employers, landlords, associates, etc. By
permitting the denial of housing to registered sex offenders,
this bill affects a much larger group of innocent persons,
such as their spouses, domestic partners, and minor children.
By evicting a registered sex offender from his rental housing,
the apartment owner effectively may be causing an entire
family to become homeless.
According to the CCOSO report, "Widespread notification is
making it increasingly difficult for registrants to find
housing. This tends to drive them into poorer neighborhoods,
where more dysfunctional families tend to live. Children from
these families are more easily victimized than children in
more affluent, better organized neighborhoods. The Third
National Incidence Study of Child Abuse and Neglect showed
that children living below the poverty line are 18 times as
likely to be sexually abused as children living at or above
the median income. [National Incidence Study on Child Abuse
and Neglect (1996), Department of Health and Human Services,
Administration for Children and Families, National Center on
Child Abuse and Neglect. ]
8)Legislative Counsel Opinion on Megan's Law and Rental Property
Discrimination : According to Legislative Counsel Opinion No.
0501030, "An owner of residential property is prohibited from
using information obtained through the [Megan's Law Web site]
as the basis for refusing to rent to a registered sex
offender, unless it is to protect a person at risk."
The Legislative Counsel opinion further states that "the
'at-risk' argument becomes more difficult for a property owner
to make if the offender's crimes were perpetrated against
children and the property in question houses only adult
tenants. If there are no persons arguably 'at-risk' of harm
by the sex offender on the property, the property owner would
be unable to use the information obtained from the Web site
for any 'purpose relating to . . . housing or accommodations'
and could not refuse to rent to the offender applicant.
"Offenders identified on the Web site may have committed
offenses ranging from the violent rape of an adult to a
misdemeanor annoying a child, may have one offense or multiple
offenses, and may have been recently convicted or convicted
decades ago. Determining whether there are persons on the
property 'at risk' of victimization by the offender will
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depend upon the offender's previous victim or victims, the
type of offense he or she has committed, and the nature of the
tenants in the building where the offender is seeking to
reside."
The Legislative Counsel Opinion also discussed the eviction of
tenants due to discovery of the tenant's sex offender
registrant status through the Internet Web site. The opinion
states "in our opinion, use of the information to evict a sex
offender would be subject to the same 'at-risk' standard as
used in determining whether or not to rent to a sex offender
in the first place. Based upon the offender's crime, previous
victim or victims, and the nature of the tenants presumably at
risk, the property owner must be able to make a reasonable
claim that he or she evicted the tenant to protect someone who
would be placed at risk by the sex offender's continued
presence in the dwelling."
The Legislative Counsel Opinion also discussed whether an
apartment owner or landlord may inform other tenants that a
tenant is a sex offender. Again, the opinion cites the
necessity of making at "at-risk" determination, stating "any
use of the information including giving information to other
tenants is prohibited unless it is to protect a person at
risk. Disclosure for the sake of disclosure, or mere gossip,
would clearly be prohibited. As discussed [above], the
determination of who is 'at risk' depends on the facts of the
case and the same standard would be used in the property
owner's argument that tenants have been notified of a sex
offender's status to protect the tenants from harm because
they are 'at risk' due to the presence of the sex offender.
"Penal Code Section 290.46 imposes various penalties for misuse
of the information obtained through the Web site. Use of the
information [for purposes relating to housing] could expose a
property owner to liability for actual damages, up to three
times the amount of actual damages, attorney fees, exemplary
damages, or a civil penalty of up to $25,000. [Penal Code
Section 290.46(j)(4)(A.)]
"In summary, it is our opinion that if an owner of residential
property discovers through the Web site that a tenant is a
registered sex offender, the property owner may not, on the
basis of that information, evict the tenant or disclose the
information to other tenants, unless it is to protect persons
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at risk."
9)Information Not Obtained from the Megan's Law Web Site : The
Legislative Counsel opinion concluded that if information that
the applicant or tenant is a registered sex offender is not
derived from the Megan's Law Web site, an owner of residential
property is not otherwise restricted from refusing to rent to
the person for that reason. However, the opinion points out
that "courts have historically held that the Unruh Civil
Rights Act (Civil Code Sections 51 and 52) prohibits
discrimination based on classifications that are not
enumerated in the statute, such as unconventional dress,
families with children, homosexuality, and minors. [Hessians
Motorcycle Club v. Flanagans (2001) 86 Cal. App. 4th 833,
836.] Subsequent opinions by courts of appeal have elaborated
and a three-step inquiry has developed for use when
considering whether a 'new' classification should be eligible
for protection under the Unruh Act. The three-part test
includes analysis of: (a) the statute's language, (b) the
legitimate business interests of the defendant, and (c) the
consequences of allowing the new discrimination claim."
In applying this three-step analysis in the Hessians Motorcycle
Club case, supra, the court held that a business could have a
policy of excluding from its establishment bike riders who
wear gang insignia or colors. Although the Legislative
Counsel opinion did not raise the issue of the significant
distinction between bike riders and elderly or disabled sex
offender registrants needing skilled nursing care, it is
likely that an appellate court, in considering the issue of
the elderly or disabled sex offender registrants as a
protected class, might reach an entirely different conclusion.
Certainly the legitimate business interests of the apartment
owners in protecting their residents would merit a different
analysis of the issue of admission to the facility of a sex
offender whose offense was against a related child
(intra-familial) than the analysis of an offender who targeted
strangers. Similarly, the owner of a housing complex for the
elderly would be required to conduct a different risk analysis
as to a sex offender registrant who committed one offense, in
an intra-familial setting, against a child.
Moreover, the consequences of allowing the new discrimination
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claim would be far different when considering bike riders
wearing gang colors than the consideration of thousands of sex
offenders and their families being forced to become homeless
and deprived of one of life's basic needs, the need for
shelter. In the case involving the bikers and their gang
colors, the court found that allowing a discrimination claim
of this type would lead to frivolous lawsuits challenging
other neutral business policies.
It would be harder to make a persuasive argument that a lawsuit
by a sex offender that the sex offender and his or her spouse
and minor children were made homeless by the provisions of
this bill is frivolous. This is particularly true if their
homelessness was caused by an eviction unaccompanied by an
honest assessment of the risk posed by the sex offender in
question.
10)Argument in Support : According to the Apartment Association
of Greater Los Angeles and the Santa Barbara Rental Property
Association , "[o]n behalf of the above mentioned clients and
other apartment owner organizations in the past, I have been
deeply involved with attempts over the years to make some
sense out of the duties and obligations of owners of rental
property to their residents on issues relation to Megan's Law.
To say the experience has been frustrating is an
understatement. My clients were the sponsors of AB 2712(Leno)
in 2006 that would have provided a limited relief from
liability if all an owner did was to rent to someone on the
database, that measure was vetoed by the Governor.
"Owners often find themselves in a quandary in dealing with
these matters. Other tenants might discover a fellow tenant
is on the Megan's Law database and approach property managers
to request or demand some action. Also, a property manager
might also discover in some way that a tenant or prospective
tenant is on the data base. Unfortunately the state of the
law puts the owner in a no win situation in either case. If
the owner attempts to evict or to not rent to the person on
the database he or she faces the possibility of a large
financial penalty under existing law. On the other hand there
is a common law duty for an owner of rental property to take
reasonable steps to protect the safety and quiet enjoyment of
residents. It has been extremely difficult to try and provide
appropriate advice to owner when these issues arise.
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"More information about the state of the law, and other issues
related to this area can do nothing but help both owners and
tenants to navigate this confusing and emotional subject. It
is voluntary, will not have any cost to the state and will
provide much needed clarity in a decidedly unclear area.
Please vote AYE."
11)Argument in Opposition : According to the California
Apartment Association , "It is the Association's position that
creation and distribution of such a booklet is an inefficient
use of tax payer dollars as well as government and private
organizations' time.
"The bill requires the Department of Justice to create a
booklet to educate consumers about federal and state sex
offender laws as they relate to the lease or rental of real
property. There are no federal sex offender laws, however,
that specifically relate to the lease or rental of real
property. In California, there are two provisions that relate
to Megan's Law and rental housing - a disclosure provision at
Civil Code Section 2079.10a and a prohibition on certain uses
of the sex offender database Penal Code Section 290.4(d).
"With respect to the first provision, California law is very
clear that rental property owners must provide specific
language in their leases pertaining to the availability of the
Megan's Law data base. This language has been in effect for 9
years, and is already included in the leases available through
the California Association of Realtors. The law states that
no other disclosure is required. We don't believe the DOJ
booklet is necessary to explain this.
"The second provision, Penal Code Section 290.4(d) provides
that information from the Megan's Law Web side may not be used
for purposes related to housing except 'to protect a person at
risk.' 'Person at risk' is not defined, although the Attorney
General's Web site suggests that any person may be at risk,
because sex offenders' future victims may be of a different
type or category than their past victims."
12)Prior Legislation :
a) AB 438 (Parra), 2005-06 Legislative Session, would have
allowed a lessor of residential real property to refuse to
provide housing to, or to evict, registered sex offenders
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whose address must be made public pursuant to the Megan's
Law Internet Web site. AB 438 failed passage in this
Committee.
b) AB 2712 (Leno), 2005-06 Legislative Session, would have
clarified existing law regarding the duty of a residential
landlord regarding the tenancy of individuals who are
required to register as sex offenders. AB 2712 was vetoed.
c) AB 1197 (Aghazarian), 2007-08 Legislative Session, would
have stated that denial or termination of tenancy in rental
housing of a person who has been conviction of the
commission or attempted commission of specified offenses
listed in Penal Code Section 290.46(b)(2) is presumed to
protect a person at risk. AB 1197 failed passage in this
Committee.
REGISTERED SUPPORT / OPPOSITION :
Support
Apartment Association of Orange County
Apartment Association of California Southern Cities
Apartment Association of Greater Los Angeles
California Coalition Against Sexual Assault
Santa Barbara Rental Property Association
Opposition
California Apartment Association
Analysis Prepared by : Gabriel Caswell / PUB. S. / (916)
319-3744