BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 421
                                                                  Page  1

          Date of Hearing:   April 12, 2011
          Counsel:        Sandy Uribe


                         ASSEMBLY COMMITTEE ON PUBLIC SAFETY
                                 Tom Ammiano, Chair

                  AB 421 (Smyth) - As Introduced:  February 14, 2011
           
           
           SUMMARY  :   Changes procedures in sexually violent predator (SVP) 
          commitment proceedings.  Specifically,  this bill  :  

          1)Specifies each party receives 10 peremptory challenges in 
            selecting the jury.

          2)Allows the prosecuting attorney access to all records 
            concerning the defendant without obtaining a court order.

          3)Expresses findings regarding the necessity for indeterminate 
            terms for SVP commitment proceedings.

           EXISTING LAW  :

          1)Defines a "sexually violent predator" as "a person who has 
            been convicted of a sexually violent offense against at least 
            one victim, and who has a diagnosed mental disorder that makes 
            the person a danger to the health and safety of others in that 
            it is likely that he or she will engage in sexually violent 
            criminal behavior."  �Welfare and Institutions Code (WIC) 
            Section 6600(a)(1).]
          
          2)Provides that a person found to qualify as a SVP shall be 
            committed to the Department of Mental Health for an 
            indeterminate term of confinement.  (WIC 6604.)

          3)Provides for a jury trial in sexually violent predator 
            proceedings.  �WIC Section 6603(a).]

          4)Characterizes cases filed under the Sexually Violent Predator 
            Act as "special proceedings of a civil nature", not criminal 
            proceedings.  �Civil Procedure Code (CPC) Section 
            2016.020(a).]

          5)Allows each party six peremptory challenges in civil cases.  








                                                                  AB 421
                                                                  Page  2

            �CPC Section 231(c).]

          6)Allows each party 20 peremptory challenges in criminal cases, 
            if the offense charged is punishable with death or with 
            imprisonment in the state prison for life.  �CPC Section 
            231(a).]

          7)Provides that, unless otherwise limited by order of the court 
            in accordance with this title, any party may obtain discovery 
            regarding any matter, not privileged, that is relevant to the 
            subject matter involved in the pending action or to the 
            determination of any motion made in that action, if the matter 
            either is itself admissible in evidence or appears reasonably 
            calculated to lead to the discovery of admissible evidence.  
            Discovery may relate to the claim or defense of the party 
            seeking discovery or of any other party to the action.  (CPC 
            Section 2017.010.)

          8)Provides that a patient has a privilege to refuse to disclose, 
            and to prevent another from disclosing, a confidential 
            communication between the patient and a psychotherapist.  
            (Evidence Code Section 1014.)

          9)Creates and exception to the psychotherapist-patient privilege 
            where the psychotherapist has reasonable cause to believe that 
            the patient is in such mental or emotional condition as to be 
            dangerous to himself or to the person or property of another 
            and that disclosure of the communication is necessary to 
            prevent the threatened danger.  (Evidence Code Section 1024.)

           FISCAL EFFECT  :   Unknown

           COMMENTS  : 

           1)Author's Statement  :  According to the author:

          "  Peremptory Challenges  .  Existing case law provides for only six 
            preemptory challenges per side in SVP trials on the grounds 
            that the commitment is civil in nature and therefore each side 
            should only get six peremptory challenges as they do in civil 
            cases.  However, the burden of proof in SVP trials is proof 
            beyond a reasonable doubt as found by a unanimous jury, 
            whereas, in a civil trial, the burden is a preponderance of 
            the evidence and only requires a 9-3 verdict.  Moreover, SVP 
            cases involve delicate issues of mental health and sexual 








                                                                  AB 421
                                                                  Page  3

            offenses, two areas that can make jury selection very 
            challenging.  Given the higher burden of proof, the 
            requirement of a unanimous verdict, the nature of the issues 
            involved in an SVP trial, and the indefinite commitment that 
            can result, each side should have a minimum of 10 peremptory 
            challenges, as this bill provides.

          "  SVP Records  .  In SVP proceedings, the defense has consistently 
            opposed efforts by district attorneys to access even the most 
            routine and relevant records of their clients.  This includes 
            the defendant's hospital psychological treatment records, as 
            well as jail and prison records (including medical, 
            psychiatric, and disciplinary records.)

          "It is critical for the prosecution to be able to review these 
            records to properly prepare for trial.  The motions and writs 
            filed by the defense in these cases opposing release of 
            records unduly delay the proceedings, and when granted, leave 
            the prosecution less than fully informed and at a 
            disadvantaged position at trial.

          "One might argue that such language violates an individual's 
            right to privacy. However, the Ninth Circuit recently held 
            that a potential SVP's medical information is not protected by 
            the right to privacy.  (Seaton v. Mayberg (2010) 610 F.3d 
            530).  Notwithstanding, the defense continues to resist 
            efforts by the prosecution to obtain records relevant to the 
            proceedings.  The proposed change is phrased in terms of 'all 
            records concerning the person' based upon identical language 
            in Welfare and Institutions Code section 6605(a), essentially 
            to level the playing field.  Adding the proposed language 
            directly to the statutory scheme will give the prosecution 
            timely access to the relevant records, discourage future 
            litigation, and prevent unnecessary delay.

          "  Justification of Indeterminate Commitment  .  In People v. McKee 
            (2010) 47 Cal.4th 1172, the California Supreme Court concluded 
            that the People had not met their burden to show that 
            differential treatment of SVPs, as it relates to length of 
            commitment, was justified under an equal protection analysis.  
            Specifically, the court found that the state had not justified 
            an indeterminate length of commitment for SVPs in light of 
            determinate lengths of commitment for other persons civilly 
            committed such as mentally disordered offenders (MDO) or 
            persons found not guilty by reason of insanity (NGI).  The 








                                                                  AB 421
                                                                  Page  4

            case was remanded for further hearings, which are pending.

          "Indeterminate terms are imposed in SVP/sexually dangerous 
            person statutes in all jurisdictions having such statutes in 
            the United States.  This is because of the long-term treatment 
            needs of this population, as well as the particularized threat 
            to public safety that these individuals represent. In 2006, as 
            part of Jessica's Law, California changed its statute to 
            conform with the other states in this regard.  As it was only 
            one part of Jessica's Law, there was not a specific 
            justification of this particular provision, but rather a 
            generalized statement of purpose relating to the entire 
            measure.

          "The court did not find this sufficient.  Adding the proposed 
            language to the SVP Act will make it clear that the 
            Legislature has specifically considered and recognizes the 
            differential treatment needs of the SVP population, including 
            length of commitment."

           2)Background on Sexually Violent Predator Act  :  Originally, a 
            SVP commitment was for two years.  In 2006, the act was 
            amended to create a lifelong commitment or until it is shown 
            the defendant no longer poses a danger to others.  �See People 
            v. McKee (2010) 47 Cal.4th 1172, 1185-1187.]

           3)Inadequate Statement of Necessity to Overcome Equal Protection 
            Concerns  :  The Supreme Court recently found that persons 
            subject to commitment under the SVP Act are similarly situated 
            to persons committed as MDOs and to persons not guilty by 
            reason of insanity (NGI) subject to extended commitment.  
            (People v. McKee, supra, 47 Cal.4th 1172, 1203-1207.)  But 
            SVPs are treated differently than others committed in special 
            civil proceedings.  While SVPs may be held indefinitely 
            unless, by a preponderance of the evidence, they prove 
            themselves no longer mentally ill and dangerous, MDOs and 
            persons not guilty by reason of insanity may be held for 
            periods of one or two years respectively, unless the state 
            proves beyond a reasonable doubt that they remain mentally 
            disordered and dangerousness.  (Id. at pp. 1201-1202, 1207.)  
            The court held that, absent a showing of a compelling state 
            interest that justifies the differential treatment, the equal 
            protection clause requires that SVPs be afforded procedural 
            protections equivalent to those that govern MDO and NGI 
            extended commitment proceedings.  (Id. at pp. 1197- 1198, 








                                                                  AB 421
                                                                  Page  5

            1207-1210.)  The court found the State had not satisfied its 
            burden of showing that SVPs are more dangerous and so should 
            be treated differently.  The assertions cited in the ballot 
            initiative that sex offenders are more likely to reoffend are 
            not the same as facts, and they alone do not justify treating 
            SVPs differently.  (Id. at p. 1206.)

          The Supreme Court remanded for an evidentiary hearing, which has 
            yet to occur.

            The language in the ballot initiative which the court found to 
            be inadequate was:  "Sex offenders have very high recidivism 
            rates.  According to a 1998 report by the U.S. Department of 
            Justice, sex offenders are the least likely to be cured and 
            the most likely to reoffend, and they prey on the most 
            innocent members of our society.  More than two-thirds of the 
            victims of rape and sexual assault are under the age of 18.  
            Sex offenders have a dramatically higher recidivism rate for 
            their crimes than any other type of violent felon."  �See 
            Voters Information Guide, Gen. Elec. (Nov. 7, 2006) text of 
            Prop. 83, p. 127.]  The statement of necessity recited in AB 
            421 is very similar to the assertions in the ballot 
            initiative.  In fact, they are arguably even less persuasive 
            because they do not cite to any reports or findings at all.  
            Thus, the bill does not seem to alleviate equal protection 
            concerns.

           4)Implicates Constitutional Right to Privacy  : The federal 
            constitutional right to privacy encompasses the doctor-patient 
            relationship, although that right is conditional and may be 
            waived.  �Caesar v. Mountanos (1977) 542 F.2d 1064, 1067, 
            fn.9.]  The California Supreme Court has also recognized the 
            privacy of psychotherapist-patient relationship.  �In re 
            Lifschutz (1970) 2 Cal.3d 415, 431-432.]  Furthermore, 
            state-created liberty interests are entitled to the protection 
            of the federal Due Process Clause �see, e. g., Vitek v. Jones 
            (1979) 445 U.S. 480, 488], and the full scope of a patient's 
            federal due process rights can be determined by substantive 
            liberty interests created by state.  Thus, even if there were 
            not a clearly established federal constitutional right to 
            privacy, there is a California state-created liberty interest 
            in the right to privacy.  �People v. Gonzales, supra, 192 
            Cal.App.4th at pp. 179-180.]

           5)Effect on the Psychotherapist-Patient Privilege  :  The courts 








                                                                  AB 421
                                                                  Page  6

            have consistently recognized "the public interest in 
            supporting effective treatment of mental illness and . . . the 
            consequent public importance of safeguarding the confidential 
            character of psychotherapeutic communication."  �People v. 
            Wharton (1991) 53 Cal.3d 522, 555.]  This interest is 
            reflected in Evidence Code which protects confidential 
            communications between a psychotherapist and patient from 
            disclosure.  But, there is a "dangerous patient" exception to 
            the privilege. There is no privilege where the psychotherapist 
            has reasonable cause to believe that the patient is in such 
            mental or emotional condition as to be dangerous to himself, 
            herself, or to the person or property of another and that 
            disclosure of the communication is necessary to prevent the 
            threatened danger.  This exception would allow the prosecution 
            to view the patient's records if it presents evidence to show 
            that the communications were not confidential, the privilege 
            was waived, or the communications fall within an exception to 
            the privilege.  �Story v. Superior Court (2003) 109 
            Cal.App.4th 1007, 1015.]  The exception should be narrowly 
            construed.  �People v. Gonzales (2011) 192 Cal.App.4th 152, 
            165.]

          This bill rests on the premise that commencement of SVP 
            proceedings operates as an automatic waiver of the privilege.  
            The institution of SVP Act proceedings does not strip an 
            individual of the right to privacy against the unjustified 
            disclosure of information protected by the 
            psychotherapist-patient privilege such that the 
            dangerous-patient exception automatically applies.  �People v. 
            Gonzales, supra, 192 Cal.App.4th at p. 170.]

           6)Effect on Discovery Provisions :  Criminal discovery rules do 
            not apply to SVP proceedings.  �Albertson v. Superior Court 
            (2001) 25 Cal.4th 796, 804.]  Rather, because a case filed 
            under the SVP Act contemplates a non-punitive commitment for 
            treatment purposes, it is a "special proceeding of a civil 
            nature," and so the Civil Discovery Act (CPC Section 2016.010 
            et seq.) applies.  (CPC Section 363.)  This bill overrides the 
            discovery provisions of the state's Civil Procedure Code to 
            allow the prosecution access to the defendant's normally 
            privileged medical records without a court order.

           7)Right to a Jury Trial and Peremptory Challenges  :  An SVP 
            proceeding is a special civil proceeding with a statutory 
            right to a jury trial, not a constitutional one.  �People v. 








                                                                  AB 421
                                                                  Page  7

            Rowell (2005) 133 Cal.App.4th 447, 451.]  The Sixth Amendment 
            right to jury trial does not apply to civil proceedings.  The 
            Seventh Amendment right to jury trial in civil law cases does 
            not apply to the states.  �Dohany v. Rogers (1930) 281 U.S. 
            363, 369.]  And it would not apply to special proceedings, in 
            any event.  

            People v. Calhoun (2004) 118 Cal.App.4th 519, 523-524, held 
            the parties were entitled to only six peremptory challenges.  
            However, this was before the act provided for indefinite 
            commitments.  Under Proposition 83, an individual SVP's 
            commitment term is indeterminate, rather than a two-year term 
            as in the previous version of the act.  Now, the outcome of a 
            commitment proceeding is akin to a life sentence.  In criminal 
            cases where the offense is punishable by a life sentence, each 
            party receives 20 peremptory challenges.  �CPC Section 
            231(a).]  While the bill increases the number of peremptory 
            challenges, the author notes this number is the minimum that 
            should be afforded.  Should there be even more preemptory 
            challenges given the implications of the proceedings?

           8)Argument in Support  :  According to the  California District 
            Attorneys Association  (the sponsor of this bill), 
            "�P]rosecutors' efforts to access records of potential SVPs 
            have met with resistance from the defense.  In SVP 
            proceedings, the defense has consistently opposed efforts by 
            district attorneys to access even the most routine and 
            relevant records of their clients.  This includes the 
            defendant's hospital psychological treatment records, as well 
            as jail and prison records (including medical, psychiatric, 
            and disciplinary records).

          "It is critical for the prosecution to review these records to 
            properly prepare for trial.  The motions and writs filed by 
            the defense in these cases opposing release of records unduly 
            delay the proceedings, and when granted, leave the prosecution 
            less than fully informed and at a disadvantaged position at 
            trial.  . . .

          "Finally, a California Supreme Court ruling has called into 
            question the state's justification for setting a term of 
            commitment for SVPs that is different from other offenders who 
            are civilly committed.  In People v. McKee (2010) 47 Cal.4th 
            1172, the California Supreme Court concluded that the People 
            had not met their burden to show that different treatment of 








                                                                  AB 421
                                                                  Page  8

            SVPs, as it relates to length of commitment, was justified 
            under an equal protection analysis.  Specifically, the court 
            found that the state had not justified an indeterminate length 
            of commitment for SVPs in light of the determinate lengths of 
            commitment for other persons civilly committed such as 
            mentally disordered offenders (MDO) or persons found not 
            guilty by reason of insanity (NGI).  The case was remanded for 
            further hearings, which are pending.

          "Indeterminate terms are imposed in SVP/sexually dangerous 
            persons statutes in all jurisdictions having such statutes in 
            the United States.  This is because of the long-term treatment 
            needs of this population, as well as the particularized threat 
            to public safety that these individuals represent.  In 2006, 
            as part of Jessica's Law, California changed its statute to 
            conform with the other states in this regard.  As it was only 
            one part of Jessica's Law, there was not a specific 
            justification of this particular provision, but rather a 
            generalized statement of purpose relating to the entire 
            measure.  The court did not find this sufficient.  Adding the 
            proposed language to the SVP Act will make it clear that the 
            Legislature has specifically considered and recognizes the 
            differential treatment needs of the SVP population, including 
            length of commitment."

           9)Arguments in Opposition  :  According to the  California Public 
            Defenders Association  (CDPA), "CPDA does however oppose the 
            proposed amendment of WIC �6604.  We view this amendment as an 
            attempt to preempt the evidentiary hearing process that is 
            presently ongoing in People v. McKee (2010) 47 Cal.4th 1172.  
            Therein the appellant challenged the constitutionality of the 
            SVPA on the grounds that it violates equal protection by 
            imposing an indeterminate commitment, and places the burden on 
            the committee to prove a change in condition to secure his 
            release.  The Supreme Court remanded the matter 'to the trial 
            court to determine whether the People, applying the equal 
            protection principles articulated in Moye and related cases 
            discussed in the present opinion, can demonstrate the 
            constitutional justification for imposing on SVP's a greater 
            burden than is imposed on MDO's and NGI's in order to obtain 
            release from commitment.'  At page 1209.

          "Similar language was included in the original legislative 
            intent of AB 888, which ultimately was enacted as the Sexually 
            Violent Predator Act, effective January 1, 1996.   Because the 








                                                                  AB 421
                                                                  Page  9

            legislative enactment declares it, does not make it so.  
            Absent evidentiary justification, a different statutory scheme 
            for SVPs as opposed to MDOs and NGIs, imposing disparate 
            treatment, cannot withstand a constitutional challenge under 
            the Equal Protections clause.   The issue has been addressed 
            by our state Supreme Court, based on constitutional grounds.  
            It is inappropriate for the legislature to try to preempt the 
            evidentiary process that has been ordered to be pursued by our 
            highest court.

            "These 'findings' seek to justify, five years after the fact, 
            the indeterminate term of civil commitment created initially 
            by SB 1128, which was then superseded by Proposition 83.  
            These 'findings' are not evidence-based; to the contrary:

              "(a)  The poor prognosis for 'curing' Axis I mental 
            illnesses is not a basis for civil commitment under any 
            statutory scheme. "Treatment" to reduce future dangerousness 
            has always been the justification for civil commitment in 
            California and elsewhere.  No civil commitment scheme exists 
            anywhere in the nation which aims to 'cure' mental illness.

              "(b)  There is no basis for a 'finding' that the prognosis 
            for 'treating' sexually violent predators is any better or 
            worse than the prognosis for treating any other category of 
            civilly committed individuals, or that the SVP treatment takes 
            longer.  Treatment needs vary from human being to human being, 
            across all categories of civil commitment.  Treatment 
            amenability does as well.  According to recent testimony in 
            the hearing mandated by the Supreme Court, from the Chief 
            Psychiatrist of Coalinga State Hospital, the Phase program, 
            currently in place for SVP's, can be completed by a motivated 
            individual in fewer than four years.  Moreover, there is no 
            scientific basis for the belief that completion of all five 
            phases of the program must be accomplished, in every instance, 
            to ensure public safety.

              "(c)  There is no basis for finding that the treatment needs 
            of SVP's are 'very different' than the traditional treatment 
            modalities for other classes of civilly committed individuals. 
             Overwhelming evidence exists that the 
            'Risk-Needs-Responsivity' model of treatment is the best 
            practice for all mentally disordered individuals who are 
            civilly committed.  Treatment for sex offenders continually 
            changes with advances in science, and what was considered 








                                                                  AB 421
                                                                  Page  10

            'best practices' for treatment three years ago no longer is.  
            Moreover, sex offenders who are civilly committed as MDO's, 
            NGI-X's, and MDSO's require (and receive) the same type of sex 
            offender treatment as SVP's, in addition to the complicating 
            need for medication treatment and all  it entails.  These 
                                                      'findings' are nothing more than a transparent attempt to 
            invent a justification for disparate treatment for SVP's, 
            when, in fact, no such justification exists.

            "CPDA also opposes the proposed addition of �6609.4, which 
            provides that notwithstanding other provisions of law, the 
            prosecutor shall have access to all records concerning a 
            person subject to proceedings in ��6601, 6602, 6605, and 6608, 
            upon written request of third party without the necessity of a 
            court order.  Proceedings under ��6601 & 6602 are 'pre-trial' 
            proceedings.   Proceedings pursuant to ��6605 & 6608 are after 
            an individual has been committed as an SVP.  Under �6605, upon 
            the recommendation of the Department of Mental Health �DMH], a 
            person can either petition for conditional release and/or 
            unconditional release to the community.  However, in the 
            fifteen years the SVPA has been in effect, DMH has never once 
            made such a recommendation, so the provision is of little 
            effect.  Under �6608 a person, without the concurrence of DMH, 
            can petition for conditional release to a state-operated 
            forensic conditional release program.  The person has the 
            burden of proof by a preponderance of the evidence to prove 
            that he would not be a danger to the health and safety of 
            others while under supervision and treatment in the community.

            "This amendment seeks to abrogate the statutory and 
            constitutional rights afforded other civil committees, so once 
            again the potential SVP committee is treated differently, 
            despite the fact the individual has not even received the due 
            process of adjudication on the merits.   Further, this 
            provision is unnecessary.  Section 6601(d) presently provides 
            the prosecutor access to the DMH Evaluations performed on the 
            potential committee while he is in prison, prior to his 
            scheduled parole release date.  Additionally, the prosecutor 
            is afforded copies of any other supporting documents, for 
            purposes of making a filing determination. 

            "Once probable cause has been found (�6602), the prosecutor 
            can seek updated evaluations and/or replacement evaluations 
            pursuant to �6603(c), once per year for purposes of preparing 
            the case for trial.   The treatment information is presently 








                                                                  AB 421
                                                                  Page  11

            available to the prosecutor without need for a Subpoena Duces 
            Tecum �see Lee v. Superior Court of Orange County (2009)177 
            Cal.App.4th 1108.]   Under People v. Martinez (2001) 88 
            Cal.App.4th 465, a potential committee has no expectation of 
            privacy in prior commitment records.  

            "Once again this legislation appears to be an attempt to 
            circumvent a recent holding in People v. Gonzalez (2011) 192 
            Cal.App.4th 152, wherein the reviewing court ruled that the 
            trial court, in an SVP proceeding,  erred in releasing 
            privileged psychotherapeutic records generated while the 
            potential committee was on parole in the community seeking 
            treatment.  The Sixth District determined that the records 
            were privileged under Evidence Code �1014, and the 'dangerous 
            patient' exception, under Section 1024, was not established.

            "Other civil committees, including MDOs and NGIs, enjoy the 
            confidentiality of treatment records under Welfare and 
            Institutions Code �5328, psychotherapist-patient privilege 
            under EC �1014, the right to privacy under the California 
            Constitution, Article 1, Section 1, and the Due Process Clause 
            of the United States Constitution.   The aforementioned 
            privileges are not absolute, as discussed above.  Indeed, the 
            statutory exceptions that exist in favor of the prosecutor are 
            more numerous within the SVPA than in other civil commitments. 
              

            "If the petitioning agency, without judicial oversight, is 
            permitted to get all records pertaining to the person sought 
            to be committed, this would circumvent Welfare and 
            Institutions Code section 827 (confidentiality of juvenile 
            court records) and would allow the petitioning agency to 
            obtain records covered by other statutory and constitutional 
            privileges (i.e. HIPPA, constitutional right to privacy, 
            attorney/client privilege) without judicial oversight or 
            notice to the interested parties."

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California District Attorneys Association (Sponsor)
          California State Sheriffs' Association

           Opposition 








                                                                 AB 421
                                                                  Page  12

           
          California Attorneys for Criminal Justice
          California Public Defenders Association  

          Analysis Prepared by  :    Sandy Uribe / PUB. S. / (916) 319-3744