BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 1854
                                                                  Page  1

          Date of Hearing:   May 5, 2010

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Julia Brownley, Chair
                    AB 1854 (Ammiano) - As Amended:  April 5, 2010
           
          SUBJECT  :  School attendance: residency requirements.

           SUMMARY  :  Authorizes school districts to accept documents that  
          reasonably provide evidence that a pupil meets residency  
          requirements for school attendance within the district; and,  
          specifies certain types of documents that can be considered  
          reasonable evidence.  Specifically,  this bill  :   

          1)Authorizes a school district to accept a wide range of  
            documents and representations that reasonably provide evidence  
            that a pupil meets residency requirements for school  
            attendance within the district.

          2)Specifies that "reasonable evidence" of district residency may  
            be established by documentation including, but is not limited  
            to:

             a)   Property tax payment receipts.

             b)   Rent payment receipts.

             c)   Utility service payment receipts.

             d)   Declaration of residency executed by the parent or  
               guardian of the pupil.

          3)Specifies that if any employee of a school district reasonably  
            believes that the parent or guardian of a pupil has provided  
            false or unreliable evidence of residency, the school district  
            may make reasonable efforts to determine that the pupil meets  
            the requirements.

           EXISTING LAW  : 

          1)Requires pupils to attend school in the district in which the  
            residency of either the parent or legal guardian is located.   
            (Education code 48200)

          2)Recognizes that school districts, adjacent to the  








                                                                  AB 1854
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            international border, face unique circumstances in conducting  
            the verification of a pupil's residency and therefore  
            authorizes these districts to accept a wide range of documents  
            as reasonable evidence that the pupil meets the residency  
            requirements for school attendance within the district.   
            Specifies that if any employee of a school district that is  
            adjacent to an international border reasonably believes that  
            the parent or guardian has provided false or unreliable  
            evidence of residency, the school district shall make  
            reasonable efforts to determine that the pupil actually meets  
            the residency requirements.  Specifies that documentation of  
            residency for these districts may include, but not be limited  
            to:

             a)   Property tax payment receipts.

             b)   Rent payment receipts.

             c)   Utility service payment receipts.

             d)   Declaration of residency executed by the parent or  
               guardian of the pupil. 
               (Education code 48204.6)

           FISCAL EFFECT  :   This bill is keyed non-fiscal.

           COMMENTS  :   The education code requires that all students attend  
          school in the district in which the residency of either the  
          parent or legal guardian is located, but it does not provide any  
          definition of school district residency, nor does it provide  
          school districts with any guidance about how to verify  
          residency, except for those districts adjacent to the  
          international border.  According to the author, some districts  
          are imposing overly burdensome requirements on parents to  
          establish their residence in the district, with some districts  
          establishing complex matrices with requirements that far exceed  
          those for border area districts.  One could argue that these  
          requirements go against the legal advisory opinions issued by  
          the California Department of Education (CDE) and make it  
          difficult to implement the public policy of ensuring universal  
          enrollment and education.  Providing uniform guidelines that are  
          easily understandable and not overly burdensome will ensure that  
          California children enroll in and attend school and provide  
          clear guidance to school districts.  









                                                                  AB 1854
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          The CDE has promulgated regulations regarding eligibility for  
          child care and development services that allow a wide range of  
          documents to be accepted by providers as proof of residency.   
          CDE has also issued several legal advisory documents intended to  
          assist districts and county offices regarding the information  
          they may rely on to determine that a child is a resident for  
          purposes of school attendance, including, in the context of the  
          homeless, advising districts to accept any kind of document,  
          including a parental declaration of intent to remain in the  
          district indefinitely.  In Legal Advisory LO:1-95, the CDE  
          states that the general rule is that districts may accept a wide  
          range of documents and parent representation regarding  
          residency, there is no particular list of documents that may be  
          accepted, and that any reasonable evidence of residence is  
          sufficient.  

          In 2008, the Evergreen school district governing board was asked  
          by their community to implement a strict "proof of residence"  
          policy aimed at eliminating falsely registered children.  The  
          community brought forth registration documents from a  
          neighboring high performing district as proof that the school  
          district could also require such proof to determine residency.   
          The district disagreed with the legal direction and denied the  
          initiative at a public board meeting.  The community's solution  
          amounted to requiring specific documents which would very likely  
          lead to disclosure of a student's immigration status and would  
          clearly be in violation of the Fourteenth Amendment of the US  
          Constitution.  The district Superintendent argued at that time,  
          "I cannot accept requiring a singular proof of residence that  
          compromises a child/family's immigration status and is clearly  
          against the law."  Some school districts utilize a strict proof  
          of residence policy as described above.  





          For example, the Acalanes Union High School requires three forms  
          of residency verification, one form of documentation is required  
          from each of the following groups to register a child in the  
          district:

           ----------------------------------------------------------------- 
          |       Group 1       |       Group 2       |       Group 3       |
          |---------------------+---------------------+---------------------|








                                                                 AB 1854
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          |                     |                     |                     |
          |   ?    Current      |   ?    Current      |   ?    State or     |
          |     Passport        |     Rental/Lease    |     Federal Tax     |
          |                     |     Agreement with  |     Return with W-2 |
          |   ?    Current      |     name and        |     attached        |
          |     Driver License  |     address of      |                     |
          |     with vehicle    |     parent and      |   ?                 |
          |     registration    |     property        |     Payroll/Check Stub with name |
          |                     |     manager         |     & address       |
          |   ?    Current CA   |                     |                     |
          |     ID              |   ?    Current      |   ?    Other form   |
          |                     |     property tax    |     of              |
          |   ?     Current     |     bill            |     identification  |
          |     Military ID     |                     |     or              |
          |                     |   ?     Current     |     correspondence  |
          |                     |     Homeowner's or  |     from a          |
          |                     |     Renter's        |     government      |
          |                     |     Insurance       |     agency          |
          |                     |     Policy          |                     |
           ----------------------------------------------------------------- 
           Source: Acalanes Union High School District website.

           Committee Amendments  :  Staff recommends the bill be amended in  
          the following ways:
          1)Require districts to accept rental contracts or leases,  
            utility contracts or statements, pay stubs, voter  
            registration, and correspondence from a government agency  
            displaying the address and name of the parent or guardian, in  
            addition to those documents currently listed in the bill.  
          2)Specify that districts are required to accept a declaration of  
            residency executed by the parent or guardian of the pupil  
            within the context of homelessness as defined by the federal  
            McKinney-Vento Act. 
          3)Clarify that this bill will not limit access to pupil  
            enrollment in a school district as provided by state and  
            federal statutes and regulations.

           Previous Legislation  :  SB 1735 (Romero), which was vetoed by the  
          Governor in 2008 with the generic budget veto message, required  
          school districts to accept documents and representations that  
          reasonably provide evidence that a pupil meets residency  
          requirements for school attendance within the district that show  
          the name and address of the parent or guardian within the school  
          district; and, specified certain types of documents that shall  
          be considered reasonable evidence.  








                                                                  AB 1854
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          AB 687 (Goldsmith), Chapter 309, Statutes of 1995 established an  
          annual state General Fund appropriation to school districts  
          adjacent to an international border to assist those districts in  
          verifying pupil residency; and, required school districts  
          receiving money to employ appropriate due process procedures for  
          pupil expulsion relating to residency.

           REGISTERED SUPPORT / OPPOSITION  :   
           
          Support 
           American Civil Liberties Union

           Opposition 
           None on file.
           
          Analysis Prepared by  :    Chelsea Kelley / ED. / (916) 319-2087