BILL ANALYSIS                                                                                                                                                                                                    



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          Date of Hearing:  April 13, 2010
          Counsel:              Kimberly A. Horiuchi


                         ASSEMBLY COMMITTEE ON PUBLIC SAFETY
                                 Tom Ammiano, Chair

                 AB 2239 (Hagman) - As Introduced:  February 18, 2010
           

          SUMMARY  :   Exempts from the Administrative Procedures Act (APA),  
          as specified, rules related to the procedures, training of  
          staff, staffing levels, design and layout of an execution  
          chamber, or related processes for the administration of the  
          death penalty, as specified.  This exemption shall not be deemed  
          to alter or otherwise apply to habeas corpus or appellate  
          procedures in capitol cases.  

           EXISTING LAW  :

          1)States that the Secretary of California Department of  
            Corrections and Rehabilitation (CDCR) may prescribe and amend  
            rules and regulations for the administration of the prisons  
            and for the administration of the parole of persons sentenced  
            under the determinate sentencing law except as specified.  The  
            rules and regulations shall be promulgated and filed pursuant  
            to existing law, except as otherwise provided.  All rules and  
            regulations shall, to the extent practical, be stated in  
            language that is easily understood by the general public.  For  
            any rule or regulation filed as regular rulemaking as  
            specified copies of the rule or regulation shall be posted in  
            conspicuous places throughout each institution and shall be  
            mailed to all persons or organizations who request them no  
            less than 20 days prior to its effective date.  [Penal Code  
            Section 5058(a).]

          2)States the following are deemed not to be "regulations" as  
            defined in the Government Code: 

             a)    Rules issued by the director applying solely to a  
               particular prison or other correctional facility, provided  
               that the following conditions are met:  all rules that  
               apply to prisons or other correctional facilities  
               throughout California are adopted by the Secretary, as  
               specified; all rules except those that are excluded from  








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               disclosure to the public pursuant to the Government Code  
               are made available to all inmates confined in the  
               particular prison or other correctional facility to which  
               the rules apply and to all members of the general public.

             b)   Short-term criteria for the placement of inmates in a  
               new prison or other correctional facility, or subunit  
               thereof, during its first six months of operation, or in a  
               prison or other correctional facility, or subunit thereof,  
               planned for closing during its last six months of  
               operation, provided that the criteria are made available to  
               the public and that an estimate of fiscal impact is  
               completed pursuant to existing law, inclusive, of the State  
               Administrative Manual.

             c)   Rules issued by the Secretary that are excluded from  
               disclosure to the public pursuant to provisions of the  
               Government Code.  [Penal Code Section 5058(c)(1)(2).]

          3)Provides that the punishment of death shall be inflicted by  
            the administration of a lethal gas or by an intravenous  
            injection of a substance or substances in a lethal quantity  
            sufficient to cause death, by standards established under the  
            direction of the Department of Corrections.  [Penal Code  
            Section 3604(a).]

          4)States that persons sentenced to death prior to or after the  
            operative date of this subdivision shall have the opportunity  
            to elect to have the punishment imposed by lethal gas or  
            lethal injection.  This choice shall be made in writing and  
            shall be submitted to the warden pursuant to regulations  
            established by the Department of Corrections.  If a person  
            under sentence of death does not choose either lethal gas or  
            lethal injection within 10 days after the warden's service  
            upon the inmate of an execution warrant issued following the  
            operative date of this subdivision, the penalty of death shall  
            be imposed by lethal injection.  [Penal Code Section 3604(b).]

          5)States that where the person sentenced to death is not  
            executed on the date set for execution and a new execution  
            date is subsequently set, the inmate again shall have the  
            opportunity to elect to have punishment imposed by lethal gas  
            or lethal injection, according to the procedures set forth in  
            existing law.  [Penal Code Section 3604(c).]









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           FISCAL EFFECT :   Unknown

           COMMENTS  :   

           1)Author's Statement  :  According to the author, "This  
            legislation is intended to allow CDCR to efficiently make the  
            necessary changes to the execution chamber so those families  
            who have been awaiting justice will finally receive what the  
            state promised them.  The death penalty is not something I or  
            the state courts take lightly, when the sentence is given it  
            is our duty to see it The current system of having every  
            change to the way the death penalty is administered open to  
            public comment severely hampers CDCR's ability to make the  
            necessary changes to carry out executions in the state of  
            California. 

          "The court concluded that the procedural requirements designated  
            by the APA for administrative regulations were applicable to  
            Operating Procedure (OP) 770 and that defendants' failure to  
            comply with the APA invalidated the protocol.  The protocol  
            was a rule of general application.  All condemned inmates who  
            had received an execution date were covered by OP 770 until a  
            method of execution was selected.  Unless an inmate  
            affirmatively selected the use of lethal gas, all death  
            sentences would be by lethal injection and would be carried  
            out consistently with the remainder of the protocol.  Because  
            the protocol declared how a certain class of inmates, those  
            whose execution dates had been set, would be treated, it was  
            subject to the APA, even if it did not apply to all inmates,  
            or even to all inmates sentenced to death.  The protocol was  
            not subject to the single prison exception set forth in Penal  
            Code Section 5058(c)(1) enacted in a timely fashion once all  
            appeals have been exhausted.  

           2)Administrative Procedures Act and Penal Code Section 5058  :   
            The APA provides rules for state agencies to adopt  
            regulations, which include public notice of the proposed  
            regulation, an opportunity for comment by interested parties,  
            and review by the Office of Administrative Law.  

          "Penal Code Section 5058(a) requires the Secretary of CDCR to  
            promulgate rules and regulations for the administration of  
            prisons pursuant to the APA (Government Code Section 11340 et.  
            seq.), unless enumerated exceptions apply.  The APA was  
            enacted to establish basic minimum procedural requirements for  








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            the adoption, amendment or repeal of administrative  
            regulations promulgated by administrative agencies (Government  
            Code Section 11346).  A major purpose of the APA is to provide  
            a procedure for persons or entities affected by a regulation  
            to be heard on the merits in its creation, and to have notice  
            of the law's requirements so they can conform their conduct  
            accordingly.  Because of this, any doubt as to the  
            applicability of the APA's requirements should be resolved in  
            favor of the APA."  [Grier vs. Kizer (1990) 219 Cal.App. 3rd  
            422, 431.]

          Furthermore, the purpose of the APA was to prevent  
            administrative agencies from engaging in "underground  
            regulation".  Administrative regulations are not subject to  
            legislative or voter approval; therefore, the APA ensures that  
            those who may be affected by the regulation have a voice in  
            the creation and enactment of those regulations. 

          There are a few exceptions to the APA where rules are not  
            considered "regulations" within the meaning of the statute:   
            if the rules issued by the Secretary of CDCR apply solely to a  
            particular prison assuming proper notice of the rules are made  
            pursuant to existing law, short-term criteria for the  
            placement of inmates at a new facility during the first six  
            months of operation or moving inmates out of facility that is  
            closing within six months, or rules related to a confidential  
            matter as defined in the law that are not to be disclosed to  
            the public.  

          In order for a regulation to be subject to the APA, the agency  
            must have intended that its rules apply generally rather than  
            in a specific case.  The rule need not apply universally, but  
            is considered to have general application so long as it  
            declares how a certain class of cases will be decided.   
            [Pacific Gas & Electric Co. vs. State Department of Water  
            Resources (2003) 112 Cal.App. 4th 477.]

          This bill adds another exception to the APA requirements:  where  
            the rules are related to procedures, training of staff,  
            staffing levels, design and layout of an execution chamber, or  
            related processes for the administration of the death penalty.  
             This bill is aimed at resolving the on-going legal dispute  
            over the administration of lethal injection for inmates  
            sentenced to death in California.  California's lethal  
            injection policy has been reviewed for both violations of  








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            constitutional law and administrative procedure and  
            ultimately, rejected by the Courts of Appeal and the Federal  
            District Court.  CDCR attempted to redraft its policy on  
            lethal injection without complying with the APA and was also  
            rejected by the courts. M, o

           3)Morales vs.  Tilton (Morales I) :  In 2006, after California  
            executed three death row inmates, Michael Morales filed suit  
            in federal district court claiming the death penalty, as  
            administered in California, was unconstitutional as an  
            "unnecessary wanton infliction of pain" prohibited by the  
            Eighth Amendment.  [Morales vs. Tilton (Morales I) (2006) 465  
            F. Supp. 2nd 972, 974; See also Gregg vs. Georgia (1976) 428  
            U.S. 153, 173 (plurality opinion).]  The court considered what  
            it characterized as a "mountain of evidence" and concluded  
            that the three drug injection "cocktail" of sodium thiopental  
            (induces unconsciousness), pancuronium bromide (induces  
            paralysis), and potassium chloride (induces cardiac arrest) as  
            administered in California, were unconstitutional.  The court  
            stayed the use of the "cocktail" on any other inmates until  
            CDCR is able to show that the it did not permit the inmate to  
            essentially consciously suffocate to death.  (Morales I at  
            979.)  The court cited five reasons why the current  
            administration of lethal injection in California created an  
            unnecessary wanton infliction of pain:  

          "However, the record in this case, particularly as it has been  
            developed through discovery and the evidentiary hearing, is  
            replete with evidence that in actual practice OP 770 does not  
            function as intended.  The evidence shows that the protocol  
            and Defendants' implementation of it suffer from a number of  
            critical deficiencies, including:

          "Inconsistent and unreliable screening of execution team  
            members:  For example, one former execution team leader, who  
            was responsible for the custody of sodium thiopental (which in  
            smaller doses is a pleasurable and addictive controlled  
            substance), was disciplined for smuggling illegal drugs into  
            San Quentin; another prison guard led the execution team  
            despite the fact that he was diagnosed with and disabled by  
            post-traumatic stress disorder as a result of his experiences  
            in the prison system and he found working on the execution  
            team to be the most stressful responsibility a prison employee  
            ever could have.









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          "A lack of meaningful training, supervision, and oversight of  
            the execution team: Although members of the execution team  
            testified that they perform numerous 'walk-throughs' of some  
            aspects of the execution procedure before each scheduled  
            execution, the team members almost uniformly have no knowledge  
            of the nature or properties of the drugs that are used or the  
            risks or potential problems associated with the procedure.   
            One member of the execution team, a registered nurse, who was  
            responsible for mixing and preparing the sodium thiopental at  
            many executions, testified that '[w]e don't have training,  
            really.'  While the team members who set the intravenous  
            catheters are licensed to do so, they are not adequately  
            prepared to deal with any complications that may arise, and in  
            fact the team failed to set an intravenous line during the  
            execution of Stanley 'Tookie' Williams on December 13, 2005.   
            Although Defendants' counsel assured the Court at the  
            evidentiary hearing that 'Williams was a lesson well learned,  
            one that will never occur again,' the record shows that  
            Defendants did not take steps sufficient to ensure that a  
            similar or worse problem would not occur during the execution  
            of Clarence Ray Allen on January 17, 2006, or Plaintiff's  
            scheduled execution the following month.
           
          "Inconsistent and unreliable record-keeping:  For example, there  
            are no contemporaneous records showing that all of the sodium  
            thiopental in the syringes used for injections actually was  
            injected, and, in fact, testimony revealed that in at least  
            several executions it was not.  A number of the execution logs  
            are incomplete or contain illegible or overwritten entries  
            with respect to critical data such as the inmate's heart rate  
            and the time at which observations were made.  Inexplicably,  
            Defendants use blank paper for their electrocardiogram (EKG)  
            tracings instead of the graph paper that typically is used,  
            and provide neither standardization markings nor paper-speed  
            documentation, thereby precluding accurate interpretation of  
            the tracings, even as to heart rate. 

          "Improper mixing preparation and administration of sodium  
            thiopental by the execution team:  Among other things, team  
            members' admitted failure to follow the simple directions  
            provided by the manufacturer of sodium thiopental further  
            complicates the inquiry as to whether inmates being executed  
            have been sufficiently anesthetized.

          "Inadequate lighting, overcrowded conditions, and poorly  








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            designed facilities in which the execution team must work:   
            The execution chamber was not designed for lethal-injection  
            executions; San Quentin officials simply made slight  
            modifications to the existing gas chamber, such as drilling  
            holes in the chamber wall for intravenous lines and installing  
            a metal hook at the top of the chamber from which the bags  
            containing the lethal drugs are suspended.  The bags are too  
            high to permit the execution team to verify whether the  
            equipment is working properly.  The lighting is too dim, and  
            execution team members are too far away, to permit effective  
            observation of any unusual or unexpected movements by the  
            condemned inmate, much less to determine whether the inmate is  
            conscious; this is exacerbated by the fact that the chamber  
            door is sealed shut during executions as if lethal gas were  
            being disseminated, rendering it virtually impossible to hear  
            any sound from the chamber.  For some executions, the small  
            anteroom from which the execution team injects the lethal  
            drugs has been so crowded with prison officials and other  
            dignitaries that even simple movement has been difficult.   
            (Morales I at 979-980.)

           4)Morales vs. California Department of Corrections and  
            Rehabilitation (Morales II)  :  In an effort to administer  
            lethal injection in a constitutional manner, CDCR amended OP  
            0-770 without following the guidelines in the APA.  Morales  
            filed suit in Marin County Superior Court seeking to enjoin  
            CDCR from implementing the changes to OP 770 without complying  
            with the APA.  The lower court granted the injunction and CDCR  
            appealed to the California Court of Appeals.  CDCR argued that  
            OP-770 was not a rule of general application and at any rate  
            applied to a single facility and was an internal management  
            issue.  [Morales vs. California Department of Corrections and  
            Rehabilitation (Morales II) (2008) 168 Cal.App. 4th 729, 732.]  
             The Court of Appeals rejected CDCR's arguments and found that  
            OP-770 must comply with the provisions of the APA, which means  
            that changes to OP-770 must presented in a public manner so as  
            to give interested parties an opportunity to comment.  

           5)Lethal Injection Procedures Should Adhere to the  
            Administrative Procedures Act  :  As the court in Morales I  
            stated at the beginning of its opinion, few issues garner such  
            strong reactions as the death penalty.  

          "Few issues in American society have generated as much  
            impassioned debate as the death penalty.  At one end of the  








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            spectrum, abolitionists condemn the intentional taking of  
            human life by the State as barbaric and profoundly immoral.   
            At the other, proponents see death, even a painful death, as  
            the only just punishment for crimes that inflict unimaginable  
            suffering on victims and their surviving loved ones.  Even  
            among those with less absolute positions, there are vigorous  
            arguments about the social, penological, and economic costs  
            and benefits of capital punishment.  Any legal proceeding  
            arising in this context thus acts as a powerful magnet, an  
            opportunity for people who care about this divisive issue to  
            express their opinions and vent their frustrations."  (Morales  
            I at 973.)  A full and fair opportunity to be heard should be  
            granted to interested parties and to society at large in order  
            to establish an execution procedure that has the full faith of  
            the citizens of California.  

          Moreover, as explained above, the APA allows for those parties  
            affected by the regulations to have a say in how those  
            regulations are drafted.  In this case, the right of inmates  
            and their counsel to ensure that the CDCR-adopted procedures  
            do not inflict unnecessary wanton pain and are not in  
            violation of the Eighth Amendment must be maintained.  As the  
            U.S. Supreme Court famously stated in Woodson vs. North  
            Carolina:

          "The penalty of death is qualitatively different from a sentence  
            of imprisonment, however long.  Death, in its finality,  
            differs more from life imprisonment than a 100-year prison  
            term differs from one of only a year or two.  Because of that  
            qualitative difference, there is a corresponding difference in  
            the need for reliability in the determination that death is  
            the appropriate punishment in a specific case."  [Woodson vs.  
            North Carolina (1976) 428 U.S. 280, 305; Ford vs. Wainwright  
            (1986) 477 U.S. 399, 410; Carter, Understanding Capitol  
            Punishment (2004) pp. 19-20.]  Death is different; as such,  
            any procedure to exact execution ought to adhere to all  
            administrative procedures. 

           6)Operation Procedure No. 0-770:  Execution by Lethal Injection  :  
             OP 770 was adopted by the CDCR to implement Section 3604  
            which states that a condemned inmate will be executed by  
            lethal injection unless he or she expresses an affirmative  
            desire to be executed by lethal gas. The protocol states the  
            following purposes and objectives:









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             a)   "The purpose of this procedure is to establish  
               appropriate guidelines for the execution of condemned  
               inmates in compliance with the laws of the State of  
               California and the United States.

             b)   "The objectives of this procedure are:

               i)     "To establish the care, treatment and management of  
                 condemned inmates from the time an execution date is set  
                 through the completion of the execution.

               ii)    "To establish criteria for the selection, training,  
                 and oversight of the Lethal Injection Team.

               iii)   "To delineate specific duties and responsibilities  
                 of personnel in preparation for and completion of the  
                 execution by lethal injection of condemned inmates.

               iv)    "To ensure direct supervision and managerial  
                 oversight of the Lethal Injection Process.

            "OP 770 states the procedure is subject to the approval of the  
            San Quentin Warden (Warden) and the CDCR Secretary.  It  
            provides, 'The Warden is responsible for the recruitment,  
            selection, retention, and training of all staff involved in  
            the Lethal Injection process' and 'for managerial oversight  
            and overall implementation of this procedure.'

            "OP 770 provides that, upon receipt of the execution order,  
            the Warden and certain other designated officials interview  
            the condemned inmate and serve the warrant of execution. The  
            inmate is informed of 'the choices of execution method,' and  
            is instructed to indicate his choice within 10 days on a  
            prescribed form. Further, he is informed that 'if no choice is  
            made, lethal injection will be the method of execution.'  

            "As to the recruitment, screening and selection of lethal  
            injection team members, OP 770 provides in part:

             a)   "With the assistance of the Director, Division of Adult  
               Institutions (DAI), the Warden will coordinate the  
               recruitment and selection of Lethal Injection Team Members.  
                The Lethal Injection Team will consist of a minimum of 20  
               members.  The total number of Lethal Injection Team Members  
               will be determined by the Warden.








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             b)   "In the event the Warden is unable to field a sufficient  
               number of qualified Lethal Injection Team Members, the  
               Warden will contact the Director, DAI, to coordinate the  
               identification of additional potential candidates for team  
               membership.  Prospective team members will be selected from  
               departmental locations as determined appropriate by the  
               Director, DAI. 

             c)   "The hiring authorities from designated locations will  
               select prospective team members from personnel assigned to  
               their respective areas of responsibility consistent with  
               selection criteria [enumerated in OP 770].  The hiring  
               authorities will forward the names and classifications of  
               prospective team members to the Director, DAI.

            "OP 770 provides that the DAI Director will ensure that a  
            sufficient number of lethal injection team members will be  
            maintained.

            "As to news media witnesses at executions, OP 770 provides,  
            'When an execution is scheduled,  the CDCR, Assistant  
            Secretary, Office of Public and Employee Communications, will  
            notify the media and establish a 10-day filing period in which  
            media may request to witness the execution.'  It further  
            provides, 'The Assistant Secretary, Office of Public and  
            Employee Communications, and the San Quentin Public  
            Information Officer will consult with the Warden to select the  
            members of the news media to witness an execution.'  OP 770  
            also provides:  'The San Quentin Public Information Officer  
            and Assistant Secretary, Office of Public and Employee  
            Communications will be responsible for all CDCR press releases  
            prior to, during and after an execution and for the developing  
            of all information releases.'

            "As to the chronology of events prior to an execution, OP 770  
            provides that approximately 30 days prior to an execution, the  
            CDCR Secretary will notify the Governor's legal affairs  
            secretary in writing of all referrals made to the Marin County  
            District Attorney's office for sanity review requests under  
            section 3701.  Approximately 10 days before an execution, the  
            Warden will compile and send a final seven-day report  
            regarding any changes to the inmate's mental condition to the  
            DAI Director, whose office will forward it to the Governor's  
            legal affairs secretary.  OP 770 is available for review by  








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            condemned inmates at San Quentin and by the general public."   
            [Morales II (2008) 168 Cal.App. 4th 729, 733-734.] 

           7)Condemned Inmate Complex Project  :  As the court in Morales I  
            points out overcrowding and lack of light and space contribute  
            to the unconstitutional administration of lethal injection.   
            Hence, plans have long been in the works to expand and  
            modernize California's death row.  According to CDCR's Web  
            site, "San Quentin was established in July 1852 at Point  
            Quentin in Marin County on approximately 432 acres.  San  
            Quentin's first condemned row was established in 1893.  North  
            Block was built in 1934 and housed all males sentenced to  
            death in the State of California.  San Quentin's original  
            condemned unit was designed to house 68 inmates based on  
            California demographics and average stay of a condemned inmate  
            (less than three years) when the facility was first  
            established.  Even though San Quentin State Prison has the  
            capacity to house over 6,200 inmates, today, San Quentin State  
            Prison houses approximately 5,850 total inmates, which  
            includes California's condemned male population.  The prison  
            includes a reception center that houses approximately 3,000  
            new commitments and a main facility that houses approximately  
            600 condemned inmates, approximately 1,900 medium and low  
            security inmates, and approximately 265 minimum security  
            inmates.  

           "As a result of today's lengthy sentence and appeal process and  
            the increase in number of individuals convicted under the  
            sentence of death, the number of condemned inmates has  
            exceeded the reasonable design capacity of facilities suitable  
            for this use.  Court intervention has also resulted in the  
            classification of condemned inmates based on the level of  
            management required, escape risk, and level of allowed  
            interaction, all resulting in the need for additional  
            condemned facilities.  

          "The condemned inmate population largely consists of violent and  
            aggressive individuals that must be separated from the  
            remainder of the inmate population.  Because of the aggressive  
            nature of these individuals, condemned inmates should be  
            classified and housed in small, manageable groups that are  
            physically separated from one another.  However, the design of  
            San Quentin State Prison and the growing population of  
            condemned inmates in California have forced CDCR to house  
            condemned inmates in four separate housing areas with other  








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            institutional inmates rather than in one isolated and managed  
            area.  Furthermore, the design of the existing facilities  
            provides physical barriers limiting the ability of CDCR to  
            maintain the appropriate controls, separation, and security  
            required to house condemned male inmates.  To address these  
            issues, CDCR has determined that a new housing complex and  
            associated support facilities should be built to house the  
            condemned male inmate population at San Quentin State Prison.  

           "CDCR proposes to construct a new CIC on approximately 40 acre  
            site on the westerly side of the grounds San Quentin State  
            Prison.  The facility would be constructed in an area  
            currently developed with minimum security, warehouse, and  
            other support buildings.  The CIC would include 1,028 cells  
            capable of housing up to 1,408 condemned male inmates at  
            maximum capacity.  Facilities will be designed to provide  
            maximum security and will be within a secured perimeter that  
            includes a lethal electrified fence.  Primary access to the  
            site will be from the existing Main Gate in San Quentin  
            Village.  The proposed CIC would consist of two  
            semi-autonomous maximum-security facilities providing a total  
            of approximately 618,000 square-feet of housing, service, and  
            support space.  The CIC would be separated from the rest of  
            the prison by an outer patrol road, electrified fencing and an  
            inner patrol road."

          8)Argument in Support  :  None submitted.

           9)Arguments in Opposition  : 

             a)   According to  Death Penalty Focus  , "AB 2239 would  
               eliminate all rules related to the execution procedure from  
               the requirements of the APA.  The APA process is a  
               necessary check against abuse government power and  
               excessive regulations.  Nowhere is this safeguard more  
               critical that when the state exercises the power to take a  
               human life.  The purpose of the APA is to protect the  
               interests of all Californians from excessive, burdensome,  
               and incoherent regulations.  When a government agency is  
               given unfettered authority to implement rules and  
               regulations, there is a substantial likelihood that the  
               fundamental rights of individuals will be infringed.  The  
               APA provides a critical safeguard against government  
               overreaching and abuse.  By providing an opportunity for  
               all interested individuals to comment on proposed rules and  








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               regulations and by requiring the Office of Administrative  
               Law to review all regulations before they take effect, the  
               APA ensures that government agencies only adopt regulations  
               that are necessary and clear, and that regulations do not  
               place unnecessary burdens on individuals and businesses.  

             "The previous execution protocol-which had never been through  
               the APA process-resulted in serious mistakes during  
               executions.  Problems included the theft of controlled  
               substances, unequal and unfair treatment of witnesses and  
               errors during the execution itself.  The repeated and  
               serious nature of these problems led the Federal District  
               Court to conclude that California's execution procedures  
               could be found unconstitutional.  In response to that  
               ruling, the Governor agreed that the process would be  
               overhauled, leading eventually to a new proposed layer of  
               execution regulations.  

             "The recent public correspondence regarding these proposed  
               regulations demonstrates why the APA process is so  
               important in this context.  The California public is  
               extremely concerned about the execution procedures: more  
               than 20,000 comments were submitted about the regulations  
               during the two comment periods.  Many supporters of Death  
               Penalty Focus submitted comments both in writing and in  
               person on June 30, 2009.  Some of these supporters traveled  
               from as far as San Diego and Fresno to have their voices  
               heard on June 30th.  Death Penalty Focus also submitted two  
               separate comments with detailed objections to the proposed  
               regulations.  These comments objected to aspects of the  
               regulations that infringe fundamental rights including the  
               First Amendment rights of the press, the religious rights  
               of the person being executed, and the equal protection  
               rights of women facing execution.  

             "In response to the first comment period, CDCR acknowledged  
               that changes must be made to the original proposed  
               regulations.  Notably, the CDCR responded to concerns about  
               the religious rights of the person being executed, about  
               the unequal treatment of witnesses and about the failure to  
               mention women inmates at all in the first set of  
               regulations.  If the execution protocol was not subjected  
               to the APA process, these acknowledged defects in the  
               regulations would not have been corrected.  









                                                                  AB 2239
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             "The APA process has provided the CDCR with valuable  
               information about the impact of the proposed regulations on  
               a wide range of individuals in California-information that  
               CDCR did not have when it first drafted the regulations.   
               The CDCR may now use this information to further improve  
               the regulations, to ensure that all fundamental rights are  
               protected and that the regulations place the least burden  
               possible on individuals and businesses.  Changing and  
               improving the regulations based on information provided  
               through the APA process would allow the CDCR to avoid  
               potential litigation on these issues.

             b)   According to the  California Public Defenders  
               Association  , "This bill would exempt from the requirements  
               of the APA regulations that relate to the procedures,  
               training of staff, staffing levels, design and layout of an  
               execution chamber, or related processes for the  
               administration of the death penalty.

             "By way of background, in 2005, a US District Judge held that  
               California's lethal injection procedure creates an 'undue  
               and unnecessary risk' of cruel and unusual punishments in  
               violation of the 8th Amendment to the Constitution, and  
               ordered the state of California to address the issue prior  
               to proceeding with any executions.  Approximately two years  
               later, CDCR promulgated regulations regarding the  
               administration of lethal injection, however these rules  
               were not promulgated in accordance with the APA, thus, a  
               superior court judge enjoined the regulation, and that  
               ruling was upheld by the Court of Appeal.  In response to  
               this, CDCR has proposed a new regulation in accordance with  
               the APA, which has yet to be finalized.

             "By attempting to exempt regulations regarding execution  
               procedures from the APA, AB 2239 seeks to avoid having any  
               public scrutiny or public input whatsoever regarding  
               executions.  Such public input helps to ensure that the 8th  
               amendment's prohibition against cruel and unusual  
               punishment is not violated.  Certain countries such as  
               China and Iran do not post their death penalty procedures  
               or allow information about staffing and training of the  
               executioners and their staff.  America stands in sharp  
               contrast, as a transparency is one of the defining  
               hallmarks of due process in the American criminal justice  
               system.








                                                                  AB 2239
                                                                  Page 15


             "The public needs to know exactly what staff are being  
               trained to do and not to do and the procedures in which  
               staff are trained must stand up to constitutional scrutiny.  
                Moratoriums on the death penalty have been declared in  
               several states because the 8th amendment was violated  
               precisely because the procedures involved were found not to  
               pass Constitutional muster.  Under AB 2239, CDCR could  
               loosen the number and quality of trainings and instruction  
               and safeguards that are currently in place.  The Public  
               would have no right to know, before or after an actual  
               execution took place, what any of the changes were.   
               Further, if the public comment process were to be  
               eliminated, then the rate of executions would be  
               expedited-while that may be the goal of some, it does not  
               comport with the Constitution."

           10)Related Legislation  :  AB 1359 (Huffman) authorizes CDCR to  
            house condemned inmates in any state prison that contains  
            Level 4 security or a condemned facility designated by CDCR,  
            as specified.  AB 1359 was held on the suspense file in the  
            Assembly Committee on Appropriations. 

           11)Prior Legislation  :  

             a)   AB 1672 (Nation), of the 2005-06 Legislative Session,  
               would have required CDCR to solicit bids and award a  
               contract for an independent analysis of the cost to expand  
               death row at San Quentin State Prison, as well as possible  
               alternatives, such as a rural and urban facility for death  
               row prisoners.  AB 1672, as amended, was never heard by the  
               Assembly Committee on Appropriations. 

             b)   AB 1715 (Nation), of the 2005-06 Legislative Session,  
               would have provided that a condemned inmate shall be housed  
               in any state prison that contains Level 4 security or is a  
               condemned facility subject to similar privileges and  
               classifications as would be applied to the inmate if the  
               inmate were housed at San Quentin State Prison, as  
               specified.  AB 1715 failed passage in this Committee. 

             c)   AB 1762 (Nation), of the 2005-06 Legislation Session,  
               was exactly the same as AB 1715 as amended on April 24,  
               2006 and was never heard by the Senate Committee on Public  
               Safety.  








                                                                  AB 2239
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           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Crime Victims United of California

           Opposition 
           
          American Civil Liberties Union
          California Catholic Conference
          California Public Defenders Association
          Death Penalty Focus
          Friends Committee on Legislation
          Murder Victims' Families for Reconciliation
          California Attorneys for Criminal Justice
          Legal Services for Prisoners with Children
           

          Analysis Prepared by  :    Kimberly Horiuchi / PUB. S. / (916)  
          319-3744