BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 207
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          Date of Hearing:   March 30, 2011

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Julia Brownley, Chair
                 AB 207 (Ammiano) - As Introduced:  January 31, 2011
           
          SUBJECT  :   School attendance: residency requirements.

           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 legal 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.

          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.








                                                                  AB 207
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           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 
            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 








                                                                  AB 207
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          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 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       |
          |---------------------+---------------------+---------------------|








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          |                     |                     |                     |
          |       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:  AB 1854 (Ammiano) from 2010, which was 
          substantially similar to this bill and was vetoed by the 
          Governor, required school districts to accept reasonable 
          evidence that a pupil meets residency requirements for school 
          attendance within the district; and, specified certain types of 
          documents that shall be considered reasonable evidence.  The 
          Governor vetoed this bill with the following message:

                This bill would undermine and potentially limit a local 
                district's current residency verification process.  
                Determining what proofs of residency should be accepted 
                should continue to remain a local decision.  Nothing in 
                current law prohibits a school district from using any 
                type of documentation that fits its local circumstances.  
                For these reasons, I am unable to sign this bill.

          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. 
           
           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 








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          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
          American Federation of State, County and Municipal Employees, 
          ALF-CIO
          California Association for Bilingual Education
          California Federation of Teachers
          California Immigrant Policy Center
          Californians Together Coalition
          Evergreen School District
          Mexican American Legal Defense and Educational Fund
          Public Advocates

           Opposition 
           
          None on file.
           

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