BILL ANALYSIS                                                                                                                                                                                                    



                                                                AB 1854
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        ASSEMBLY THIRD READING
        AB 1854 (Ammiano)
        As Amended  May 12, 2010
        Majority vote 

         EDUCATION           6-2                                         
         
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        |Ayes:|Brownley, Ammiano,        |     |                          |
        |     |Arambula, Carter, Eng,    |     |                          |
        |     |Torlakson                 |     |                          |
        |     |                          |     |                          |
        |-----+--------------------------+-----+--------------------------|
        |Nays:|Nestande, Miller          |     |                          |
        |     |                          |     |                          |
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         SUMMARY  :  Requires school districts to accept reasonable evidence  
        that a pupil meets residency requirements for school attendance  
        within the district; and, specifies certain types of documents that  
        shall be considered reasonable evidence.  Specifically,  this bill  :    


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

           a)   Property tax payment receipts;

           b)   Rent contract, lease, or payment receipts;

           c)   Utility service contract, statement, or payment receipts;

           d)   Pay stubs;

           e)   Voter registration;

           f)   Correspondence from a government agency; and,

           g)   Declaration of residency executed by the parent or guardian  
             of the pupil who is homeless, as defined in Section 725 of the  
             federal McKinney-Vento Act.

        2)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  








                                                                AB 1854
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          reasonable efforts to determine that the pupil meets the  
          requirements.

        3)Specifies that nothing in this section shall be construed as  
          limiting access to pupil enrollment in a school district as  
          otherwise provided by state and federal statutes and regulations.

         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.  

        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  








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        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.  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:

         ----------------------------------------------------------------- 
        |       Group 1       |       Group 2       |       Group 3       |
        |---------------------+---------------------+---------------------|
        |                     |                     |                     |
        |   ?    Current      |   ?    Current      |   ?    State or     |
        |     Passport        |     Rental/Lease    |     Federal Tax     |
        |   ?    Current      |     Agreement with  |     Return with W-2 |
        |     Driver License  |     name and        |     attached        |
        |     with vehicle    |     address of      |   ?                 |
        |     registration    |     parent and      |     Payroll/Check Stub with name |
        |   ?    Current CA   |     property        |     & address       |
        |     ID              |     manager         |   ?     Other form  |
        |   ?     Current     |   ?    Current      |     of              |
        |     Military ID     |     property tax    |     identification  |
        |                     |     bill            |     or              |
        |                     |   ?     Current     |     correspondence  |
        |                     |     Homeowner's or  |     from a          |
        |                     |     Renter's        |     government      |
        |                     |     Insurance       |agency               |
        |                     |     Policy          |                     |
         ----------------------------------------------------------------- 
        Source: Acalanes Union High School District website.

        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. 
         








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        Analysis Prepared by  :    Chelsea Kelley / ED. / (916) 319-2087 FN:  
        0004306