BILL ANALYSIS                                                                                                                                                                                                    �







                      SENATE COMMITTEE ON PUBLIC SAFETY
                            Senator Loni Hancock, Chair              A
                             2011-2012 Regular Session               B

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          AB 1081 (Ammiano)                                          1
          As Amended May 14, 2012 
          Hearing date:  June 12, 2012
          Government Code
          SM:mc

                             IMMIGRATION DETAINER REQUESTS  

                                       HISTORY

          Source:  Asian Law Caucus; National Day Laborer Organizing 
                   Network; California Immigrant Policy Center

          Prior Legislation: None

          Support: African Advocacy Network; American Civil Liberties 
                   Union; American Federation of State, County and 
                   Municipal Employees; California Catholic Conference; 
                   California Labor Federation; California Partnership to 
                   End Domestic Violence; California Public Defenders 
                   Association; City of Petaluma Vice-Mayor; Dolores 
                   Street Community Services; Silicon Valley Alliance for 
                   Immigrant Reform; Silicon Valley Community Foundation; 
                   County of Santa Clara Board of Supervisors; Equality 
                   California; Nicaragua Center for Community Action; 
                   Orange County Community Housing Corporation; Peninsula 
                   Interfaith Action; National Association of Social 
                   Workers, California Chapter; Friends Committee on 
                   Legislation of California; California Attorneys for 
                   Criminal Justice; Legal Services for Prisoners with 
                   Children; Greater Long Beach ICO; Unitarian 
                   Universalist Legislative Ministry Action Network, CA; 
                   Nuestra Casa; National Network for Immigrant and 




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                   Refugee Rights; PODER; Oakland Catholic Worker; City of 
                   Chico; Diocese of San Bernardino; Los Amigos of Orange 
                   County; Coalition for Humane Immigrant Rights of Los 
                   Angeles; Council on American-Islamic Relations 
                   California; UNITEHERE Local 2850; Immigrant Legal 
                   Resource Center; Filipino Advocates for Justice; 
                   Services, Immigrant Rights and Education Network; LA 
                   Voice; Placer People of Faith Together; Monterey County 
                   Immigration Coalition; La Raza Centro Legal; 3rd and 
                   4th District Santa Barbara County Board of Supervisors; 
                   Immigration Center for Women and Children; San 
                   Francisco Organizing Project; Communities for a New 
                   California Education Fund; Central Valley Partnership 
                   for Citizenship; Community United Against Violence; 
                   City of Richmond; Chinese for Affirmative Action; Dream 
                   Team Los Angeles; City of Santa Barbara; Unitarian 
                   Universalist Refugee and Immigrant Services and 
                   Education; National Immigration Law Center; Arab 
                   Resource and Organizing Center; Orange County May Day 
                   Coalition; Community Legal Services in East Palo Alto; 
                   PICO California; Mexican American Legal Defense and 
                   Educational Fund; Day Worker Center of Mountain View; 
                   Canal Alliance; Street level Health Project; City of 
                   Palo Alto Police Department; International Institute of 
                   the Bay Area; Asian Law Alliance; San Francisco La Raza 
                   Lawyers Association; American Friends Service 
                   Committee; PUEBLO; 5th District, Board of Supervisors 
                   of Sonoma County; Asian Americans for Civil Rights and 
                   Equality; Pomona Economic Opportunity Center; 
                   California Hawaii State Conference of the NAACP

          Opposition:None known

          Assembly Floor Vote:  Not relevant, as this is entirely new 
          language


                                        KEY ISSUES

           SHOULD LAW ENFORCEMENT OFFICERS BE AUTHORIZED TO DETAIN INDIVIDUALS 




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          ON THE BASIS OF IMMIGRATION DETAINERS ONLY WHEN THAT PERSON HAS BEEN 
          CONVICTED OF A SERIOUS OR VIOLENT FELONY AND WHEN THAT DETENTION 
          WOULD NOT VIOLATE ANY FEDERAL, STATE, OR LOCAL LAW, OR ANY LOCAL 
          POLICY?

          SHOULD LOCAL GOVERNMENTS WHERE SUCH DETENTIONS TAKE PLACE BE 
          REQUIRED TO ADOPT A PLAN TO GUARD AGAINST DEPORTING U.S. CITIZENS, 
          RACIAL PROFILING AND CRIME VICTIMS AND WITNESSES BEING DISCOURAGED 
          FROM REPORTING CRIMES?



                                       PURPOSE

          The purpose of this bill is to (1) make uncodified legislative 
          findings and declarations; 
          (2) provide that a law enforcement officer may not detain an 
          individual on the basis of an immigration hold after that 
          individual becomes eligible for release from criminal custody, 
          as specified, unless the individual has been convicted of a 
          serious or violent felony, and the continued detention of the 
          individual on the basis of the immigration hold would not 
          violate any federal, state, or local law, or any local policy; 
          and (3) provide further that the legislative body of the local 
          agency of the jurisdiction that the individual is being detained 
          in shall, prior to or after complying with an immigration hold, 
          adopt a plan that monitors and guards against a United States 
          citizen being detained pursuant to an immigration hold, racial 
          profiling and victims and witnesses to crime being discouraged 
          from reporting crimes.
          
           Existing federal law  provides that any authorized immigration 
          officer may at any time issue a Form I-247, Immigration 
          Detainer-Notice of Action, to any other federal, state, or local 
          law enforcement agency.  A detainer serves to advise another law 
          enforcement agency that the Department of Homeland Security 
          (DHS) seeks custody of an alien presently in the custody of that 
          agency, for the purpose of arresting and removing the alien.  
          The detainer is a request that such agency advise the DHS, prior 
          to release of the alien, in order for the DHS to arrange to 




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          assume custody, in situations when gaining immediate physical 
          custody is either impracticable or impossible.  (8 Code of 
          Federal Regulations � 287.7(a).) 

           Existing federal law  states that upon a determination by the DHS 
          to issue a detainer for an alien not otherwise detained by a 
          criminal justice agency, such agency shall maintain custody of 
          the alien for a period not to exceed 48 hours, excluding 
          Saturdays, Sundays, and holidays in order to permit assumption 
          of custody by the DHS.  (8 Code of Federal Regulations � 
          287.7(d).)
           
          Existing federal law  authorizes the Secretary of Homeland 
          Security under the 287(g) program to enter into agreements that 
          delegate immigration powers to local police.  The negotiated 
          agreements between ICE and the local police are documented in 
          MOAs.  (8 U.S.C. � 1357(g).)

           Existing law  provides that all protections, rights, and remedies 
          available under state law, except any reinstatement remedy 
          prohibited by federal law, are available to all individuals 
          regardless of immigration status who have applied for 
          employment, or who are or who have been employed, within the 
          state, and further provides that, for purposes of enforcing 
          specified state laws, a person's immigration status is 
          irrelevant to the issue of liability, and prohibits in 
          proceedings for discovery immigration status except where the 
          person seeking to make the inquiry has shown by clear and 
          convincing evidence that the inquiry is necessary in order to 
          comply with federal immigration law.  (Labor Code � 1171.5.)

           This bill  provides that an individual shall not be detained by a 
          law enforcement official on the basis of an immigration hold 
          after that individual becomes eligible for release from criminal 
          custody, unless, at the time the individual becomes eligible for 
          release from criminal custody, both of the following conditions 
          are satisfied:

                 The individual has been convicted of a serious or 
               violent felony, according to a criminal background check or 




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               documentation provided to the law enforcement official by 
               United States Immigration and Customs Enforcement.
                 The continued detention of the individual on the basis 
               of the immigration hold would not violate any federal, 
               state, or local law, or any local policy.

           This bill  provides that the legislative body of the local agency 
          of the jurisdiction that the individual is being detained in 
          shall, prior to or after complying with an immigration hold, 
          adopt a plan that monitors and guards against all of the 
          following:

                 A United States citizen being detained pursuant to an 
               immigration hold.
                 Racial profiling.
                 Victims and witnesses to a crime being discouraged from 
               reporting crimes.

           This bill  provides that the plan described above is a public 
          record for purposes of the California Public Records Act, as 
          specified.

           This bill  provides that a local agency is not required to adopt 
          a plan, as described above, prior to complying with an 
          immigration hold, as specified.

           This bill  makes uncodified legislative findings and 
          declarations. 


                    RECEIVERSHIP/OVERCROWDING CRISIS AGGRAVATION
                                      ("ROCA")
          
          In response to the unresolved prison capacity crisis, since 
          early 2007 it has been the policy of the chair of the Senate 
          Committee on Public Safety and the Senate President pro Tem to 
          hold legislative proposals which could further aggravate prison 
          overcrowding through new or expanded felony prosecutions.  Under 
          the resulting policy known as "ROCA" (which stands for 
          "Receivership/Overcrowding Crisis Aggravation"), the Committee 




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          has held measures which create a new felony, expand the scope or 
          penalty of an existing felony, or otherwise increase the 
          application of a felony in a manner which could exacerbate the 
          prison overcrowding crisis by expanding the availability or 
          length of prison terms (such as extending the statute of 
          limitations for felonies or constricting statutory parole 
          standards).  In addition, proposed expansions to the 
          classification of felonies enacted last year by AB 109 (the 2011 
          Public Safety Realignment) which may be punishable in jail and 
          not prison (Penal Code section 1170(h)) would be subject to ROCA 
          because an offender's criminal record could make the offender 
          ineligible for jail and therefore subject to state prison.  
          Under these principles, ROCA has been applied as a 
          content-neutral, provisional measure necessary to ensure that 
          the Legislature does not erode progress towards reducing prison 
          overcrowding by passing legislation which could increase the 
          prison population.  ROCA will continue until prison overcrowding 
          is resolved.

          For the last several years, severe overcrowding in California's 
          prisons has been the focus of evolving and expensive litigation. 
           On June 30, 2005, in a class action lawsuit filed four years 
          earlier, the United States District Court for the Northern 
          District of California established a Receivership to take 
          control of the delivery of medical services to all California 
          state prisoners confined by the California Department of 
          Corrections and Rehabilitation ("CDCR").  In December of 2006, 
          plaintiffs in two federal lawsuits against CDCR sought a 
          court-ordered limit on the prison population pursuant to the 
          federal Prison Litigation Reform Act.  On January 12, 2010, a 
          three-judge federal panel issued an order requiring California 
          to reduce its inmate population to 137.5 percent of design 
          capacity -- a reduction at that time of roughly 40,000 inmates 
          -- within two years.  The court stayed implementation of its 
          ruling pending the state's appeal to the U.S. Supreme Court.  

          On May 23, 2011, the United States Supreme Court upheld the 
          decision of the three-judge panel in its entirety, giving 
          California two years from the date of its ruling to reduce its 
          prison population to 137.5 percent of design capacity, subject 




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          to the right of the state to seek modifications in appropriate 
          circumstances.  Design capacity is the number of inmates a 
          prison can house based on one inmate per cell, single-level 
          bunks in dormitories, and no beds in places not designed for 
          housing.  Current design capacity in CDCR's 33 institutions is 
          79,650.

          On January 6, 2012, CDCR announced that California had cut 
          prison overcrowding by more than 11,000 inmates over the last 
          six months, a reduction largely accomplished by the passage of 
          Assembly Bill 109.  Under the prisoner-reduction order, the 
          inmate population in California's 33 prisons must be no more 
          than the following:

                 167 percent of design capacity by December 27, 2011 
               (133,016 inmates);
                 155 percent by June 27, 2012;
                 147 percent by December 27, 2012; and
                 137.5 percent by June 27, 2013.
               
           This bill  does not aggravate the prison overcrowding crisis 
          described above under ROCA.

                                      COMMENTS

          1.  Need for This Bill  

          According to the author:

            Secure Communities (S-Comm) is an Immigration and Customs 
            Enforcement (ICE) program that enlists local law enforcement 
            to engage in civil immigration enforcement through the sharing 
            of biometric data at the point of arrest.  The program 
            automatically leads to investigation of the immigration 
            background of every individual, citizen or non-citizen, at the 
            point of arrest by electronically crosschecking fingerprints 
            through an immigration database allowing ICE officials to 
            detain and deport non-citizen individuals - without the basic 
            right to a day in court. 





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            While U.S Immigration Customs and Enforcement's (ICE) stated 
            mission for S-Comm is to target serious offenses, the program 
            casts far too wide a net.  ICE's own data shows that in 
            California 7 out of 10 of the over 67,900 individuals deported 
            under S-Comm had no convictions or were accused only of minor 
            offenses.<1>  Unfortunately, this means immigrant residents 
            who are victims or witnesses to a crime now fear cooperating 
            with police since any contact with law enforcement can result 
            in separation from their families and deportation. 

            This program is eroding trust between immigrant communities 
            and local law enforcement.  As a result, years of community 
            policing initiatives are ruined as entire communities lose 
            trust in law enforcement and stop reporting crimes or seeking 
            help.  S-Comm makes us all less safe and sends the state in 
            the wrong direction.  The program is exactly what ICE said it 
            is not supposed to be, a simple tool for mass, indiscriminate 
            non-criminal immigration enforcement. 

            In addition to the public safety concerns, S-Comm has also 
            failed to provide accountability and transparency.  ICE has 
            given contradictory and inconsistent answers to questions from 
            Congress, media, and local officials regarding the 
            participation of unwilling jurisdictions.
            Forcing this problematic program on localities against their 
            will creates an undue burden and jeopardizes local community 
            policing strategies. 

            Local jails internalize the entire cost of submitting to ICE 
            holds triggered by the program, which ask local authorities to 
            hold individuals in local jails for a longer period of time.  
            S-Comm does not provide any reimbursement to localities for 
            the cost of participating in the program.  At a time when 
            localities are strapped for cash they should not be spending 
            vital resources on federal civil immigration enforcement. 

            AB 1081 will rebuild the trust that S-Comm has undermined 
            --------------------------
          <1> U.S. Immigration and Customs Enforcement, Secure Communities 
          IDENT/IAFIS Interoperability Monthly Statistics October 27, 
          2008, through Feb. 29, 2012.  



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            between immigrant communities and local police by establishing 
            statewide standards for responding to burdensome ICE hold 
            requests.  This bill sets a clear standard for local 
            governments to not submit to ICE's request to detain an 
            individual unless the individual has a serious or violent 
            felony conviction.  AB 1081 also requires localities to 
            develop a plan to prevent racial profiling and keep children, 
            crime victims, or survivors of domestic violence from being 
            wrongfully targeted. 

          2.  Background: California's MOA with the Department of Homeland 
          Security  

          In April 2009, California's Department of Justice (DOJ) signed a 
          memorandum of agreement (MOA) with U.S. Immigration and Customs 
          Enforcement (ICE) regarding a program developed by ICE called 
          "Secure Communities."  The purpose of the program, as described 
          in a letter from the program's director to DOJ urging DOJ to 
          sign the MOA, is "to improve community safety by identifying, 
          detaining and removing all aliens convicted of serious crimes 
          who are held in state or local correctional facilities."  
          (Letter dated January 23, 2009, from David J. Venturella (ICE) 
          to Linda Denly (DOJ), on file with the Committee.)

          The MOA itself states the goals of Secure Communities as 
          follows: 

               ICE is committed to improving public safety by 
               transforming the way the federal government cooperates 
               with state and local law enforcement agencies to 
               identify, detain, and remove aliens who have been 
               convicted of and incarcerated for a Priority Level 1 
               offense and who are therefore amenable to removal.  SC 
               will apply a risk-based methodology to focus 
               resources.  This is accomplished by using advanced 
               technology to improve information sharing among law 
               enforcement agencies, leading to the removal of 
               high-risk convicted aliens.  

          The MOA states that it would identify "qualifying aliens 




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          convicted of serious crimes" based on a "3-level hierarchy of 
          aggravated felonies and other serious crimes."  It identifies 
          the three levels as:

                 Level 1 - Individuals who have been convicted of major 
               drug offenses and violent crimes such as murder, 
               manslaughter, rape, robbery or kidnapping;
                 Level 2 - Individuals who have been convicted of minor 
               drug and property offenses such as burglary, larceny, 
               fraud, and money laundering; and,
                 Level 3 - Individuals who have been convicted of other 
               offenses.  (Memorandum of Agreement between Department of 
               Homeland Security Immigration and Customs Enforcement and 
               California Department of Justice Bureau of Criminal 
               Identification and Information, on file with the 
               Committee.)

          The MOA provides that DOJ will electronically submit 
          fingerprints of arrested individuals who are being booked to the 
          FBI, who will then enter that data into its Automated Biometric 
          Identification System (IDENT) and, where a match is found, check 
          the person's immigration status.  ICE will send search results 
          back to DOJ, who will relay that information to the local law 
          enforcement agency that submitted the fingerprints to DOJ.  
          Lastly, the MOA provides that "Following identification of a 
          Level 1 alien who is found to be subject to removal, ICE will 
          take the alien into custody after completion of the individual's 
          sentence and proceed to institute removal (deportation) 
          proceedings."

          3.  Mounting Concerns about the Secure Communities Program  

          The S-Comm program has created controversy and raised concerns 
          among state governments that have entered MOA's similar to 
          California's, several members of Congress, as well as civil 
          rights organizations, and some local law enforcement agencies.  
          Some of the areas of concern are:

          Failing to Comply with Stated Priorities





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          For some time, S-Comm has been criticized for not adhering to 
          its stated purpose of targeting serious offenders but rather 
          using local law enforcement officers as immigration agents and 
          deporting large numbers of undocumented people who have either 
          no criminal convictions at all or only for minor offenses.  One 
          such critic was former San Francisco Sheriff Michael Hennessey.  
          (See, Immigration Bait and Switch, New York Times Editorial 
          (August 17, 2010).)  The Times editorial stated:




               It turns out the critics were right. 

               The Immigration and Customs Enforcement records show 
               that a vast majority, 79 percent, of people deported 
               under Secure Communities had no criminal records or 
               had been picked up for low-level offenses, like 
               traffic violations and juvenile mischief.  Of the 
               approximately 47,000 people deported in that period 
               only about 20 percent had been charged with or 
               convicted of serious "Level 1" crimes, like assault 
                                                                and drug dealing.  (Id.)

          Recent national statistics provided by ICE documenting 
          deportations under S-Comm through March of this year are not 
          much different than those cited in the Times editorial.  They 
          reveal that 182,896 people have been deported as a result of 
          this program and only 49,389 or 27% of these were Level 1 
          offenders.  The remaining 73% are undocumented immigrants who 
          have been convicted of minor offenses or who have never been 
          convicted of a criminal offense.  California has, by far, the 
          highest number of deportations of all the states as a result of 
          S-Comm.  In California, from May of 2009 to March 31, 2012, 
          70,330 undocumented immigrants were deported as a result of 
          S-Comm.  Of the 70,330 deportations, 18,524 or 26% had no 
          criminal convictions and another 30,086 or 43% are classified by 
          ICE as low-level offenders.  (U.S. Immigration and Customs 
          Enforcement, Secure Communities IDENT/IAFIS Interoperability 
          Monthly Statistics October 27, 2008 through March 31, 2012.)




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          Public Safety Concern

          One concern is that using local law enforcement agencies for 
          immigration enforcement may cause victims and witnesses to crime 
          to be afraid to report criminal activity for fear of themselves 
          or a loved one being deported as a result.  (See, Immigration 
          Initiative May Put Domestic Violence Victims At Risk, (March 3, 
          2011), California Watch, 
          http://californiawatch.org/dailyreport/immigration-initiative-may
          -put-domestic-violence-victims-risk-8993.)  

          Last year, former Sheriff Hennessey wrote:

               The use of fingerprints to initiate immigration 
               scrutiny is of particular concern to victims of 
               domestic violence.  In a recent case in San Francisco, 
               a woman called 911 to report domestic violence, but 
               the police arrested both her and her partner.  
               Although no charges were ever filed against the woman, 
               she is now fighting deportation.  There should be no 
               penalty for a victim of a crime to call the police.  
               (Secure Communities Destroys Public Trust, Michael 
               Hennessey, San Francisco Chronicle, (May 1, 2011), 
               http://www.sfgate.com/cgi-bin/article.cgi?f=/c/a/2011/0
               5/01/INB81J8OCL.DTL#ixzz1OGDTs6gK)




          On November 2, 2010, the Sacramento Bee reported:

               Every day, 2-year-old Kimberly Vrabo peeks around her 
               apartment complex for her mom.  If she hears police 
               sirens, she runs inside.


               Kimberly's mother, Maria Magdalena Perez-Rivera, got 
               into a fight with her boyfriend, Vicente Tellez, on a 
               Saturday night.




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               The next morning, Perez-Rivera's sister called Lodi 
               police.  Two days later, the undocumented couple were 
               deported to Mexico, leaving behind Kimberly and the 
               couple's 3-month-old son Anthony Tellez. 


               Their swift removal has shattered the family.  And 
               Sacramento's Mexican Consul General Carlos Gonz�lez 
               Guti�rrez and UC Davis Law School Dean Kevin Johnson 
               question whether justice has truly been served.


                                    * * * * * * *


               "Instead of giving them a chance to talk to a judge 
               and present their case for some type of legal relief 
               to resolve the issue, two days later the ICE van picks 
               them up and they are sent to Mexico," said Gonz�lez 
               Guti�rrez.  "The tragedy is that there are two little 
               kids who remain with the grandmother."


                                    * * * * * * *


               "This deportation scenario is all too common.  It 
               illustrates the potential pitfalls of local police 
               cooperating with immigration authorities," said 
               Johnson.  "Immigrant women in particular are going to 
               underreport domestic violence, and generally, 
               immigrant communities are going to be less likely to 
               cooperate with police for fear of being deported."  
               (Deported Mexicans Leave Two Small Kids in Lodi, 
               (November 2, 2010) Sacramento Bee, 
               http://www.sacbee.com/2010/11/02/3151148/deported-mexic
               ans-leave-two-small.html#ixzz1OK7n0NA8)





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          Pre-Textual Stops and Racial Profiling
          
          Due to the fact that, under the S-Comm program, no criminal 
          conviction is required before the person's fingerprints are sent 
          to ICE, local law enforcement may be encouraged to stop people 
          who appear to be foreign nationals without a legal basis for the 
          stop, which poses Fourth Amendment concerns.  An officer may not 
          detain a motorist without a showing of reasonable suspicion.  
          This objective basis, or reasonable suspicion, must consist of 
          specific, articulable facts which, together with objective and 
          rational inferences, form the basis for suspecting that the 
          particular person detained is engaged in criminal activity.  
          (U.S. v. Brignoni-Ponce, (1975) 422 U.S. 873, 884.)  Ethnic 
          appearance is not an appropriate factor in the reasonable 
          suspicion analysis.  (U.S. v. Montero-Camargo (9th Cir. 2000) 
          208 F.3d 1122, 1132-1135.)

          To protect these Fourth Amendment guarantees, items or 
          statements obtained during an unlawful stop or seizure are 
          generally inadmissible as evidence in a criminal proceeding.  
          (See Mapp v. Ohio (1961) 367 U.S. 643, 657, Penal Code Section 
          1538.5.)  For individuals arrested and detained under S-Comm, 
          even if the arrestee was unlawfully arrested or the charges are 
          later dropped, the arrestee will still likely be placed on an 
          ICE detainer for deportation proceedings because their 
          fingerprints are shared with ICE and the FBI upon arrest only, 
          not a conviction.  This removes the deterrent that is meant to 
          discourage any police officers who might be so inclined from 
          making unlawful stops based on racial profiling or perceived 
          immigration status because ICE will take them into custody once 
          the criminal case is concluded, even if all charges are dropped. 
           Data from ICE confirms that at least one jurisdiction which has 
          been criticized for racial profiling, Maricopa County, Arizona, 
          has an extraordinarily high rate of fingerprint submissions 
          under the S-Comm program: 821,175 submissions as of March 31, 
          2012, amounting to 79% of all submissions from the entire state 
          of Arizona.  (U.S. Immigration and Customs Enforcement, Secure 
          Communities IDENT/IAFIS Interoperability Monthly Statistics 
          October 27, 2008 through March 31, 2012.)





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          Inconsistent Statements by ICE on Counties Ability to Opt-Out
          
          On July 27, 2010, Representative Zoe Lofgren, then the 
          Chairwoman of the House Subcommittee on Immigration, 
          Citizenship, Refugees, Border Security and International Law, 
          wrote Janet Napolitano, Secretary of Homeland Security and Eric 
          Holder, the United States Attorney General:

               There appears to be significant confusion about how 
               local law enforcement agencies may "opt out" of 
               participating in Secure Communities, such that 
               fingerprints submitted by them to State Identification 
               Bureaus (SIBs) in order to be checked by the Federal 
               Bureau of Investigations (FBI) Criminal Justice 
               Information Services Division (CJIS) Integrated 
               Automated Fingerprint Identification System (IAFIS) 
               will not also be checked against databases or 
               identification systems maintained by the U.S. 
               Department of Homeland security for purposes of 
               determining immigration status.  Staff from the 
               Subcommittee on Immigration, Citizenship, Refugees, 
               Border Security and International Law were briefed on 
               this program by ICE and were informed that localities 
               could opt out simply by making such a request to ICE.  
               Subsequent conversations with ICE and FBI CJIS have 
               added to the confusion by suggesting that this might 
               not be so.  (Letter on file with the Committee.)

          On April 25, 2011, the Los Angeles Times reported, "U.S. Rep. 
          Zoe Lofgren (D-San Jose) on Friday accused ICE officials of 
          lying to local governments and to Congress and called for a 
          probe into whether ICE Director John Morton and Homeland 
          Security Secretary Janet Napolitano, who oversees the agency, 
          were aware of the deception."  (Noncriminals Swept Up In Federal 
          Deportation Program (April 25, 2011) 
          http://www.latimes.com/news/local/la-me-secure-communities-201104
          25,0,1739725.story.)


          The Times reported further:




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               Supporters applaud Secure Communities for replacing ad 
               hoc immigration enforcement with a nationwide effort 
               that targets criminals.



               "Before what was happening was the local officers had 
               no way of knowing or had to take special steps to find 
               out if the people they arrested were potentially 
               removable from the community," said Jessica Vaughan, 
               director of policy studies for the Washington, 
               D.C.-based Center for Immigration Studies, which 
               advocates for tougher immigration enforcement.  Los 
               Angeles County Sheriff Lee Baca also supports the 
               program.



               But Lofgren and others are upset over what they see as 
               the deception with which the Secure Communities 
               program was implemented.



               The congresswoman was most angered by the hundreds of 
               ICE internal documents recently released by order of a 
               federal judge.  A review of the correspondence reveals 
               an agency that misled local and state officials as it 
               struggled to defuse what one email called "a domino 
               effect" of political opposition.



               As early as November 2009, Secure Communities Acting 
               Director Marc Rapp declared in an email that 
               "voluntary" meant "the ability to receive the 
               immigration response" about fingerprint matches, not 




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               the ability to decline to provide the data in the 
               first place.



               But for nearly a year that was not made clear to local 
               agencies.  "They said, 'You set up a meeting and you 
               opt out.'  That's why we're pretty unhappy," said 
               Santa Clara County Counsel Miguel Marquez.



               San Francisco County Sheriff Michael Hennessey also 
               unsuccessfully sought to opt out of the program last 
               summer.  Hennessey is developing a policy that would 
               honor ICE detainer requests only for felons and 
               misdemeanants whose crimes involve "violence, guns, 
               and certain sex offenses."  Santa Clara County is 
               exploring a similar policy.



               In July, Lofgren wrote Napolitano and U.S. Atty. Gen. 
               Eric Holder seeking "a clear explanation of how local 
               law enforcement agencies may opt out of Secure 
               Communities by having the fingerprints they collect ? 
               checked against criminal, but not immigration 
               databases."  In September, she received letters back 
               stating that locals need only submit the request in 
               writing to state and federal officials.



               ICE officials knew the language was misleading.  "I 
               like the thought.  But reading the response alone 
               would lead one to believe that a site can elect to 
               never participate should they wish," an FBI staffer 
               wrote to ICE colleagues in an August email exchange 
               about the draft.  In October, Napolitano and Morton 
               finally held a news conference to clarify that opting 




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               out of Secure Communities is not possible.



               A Homeland Security official said Friday that "Secure 
               Communities is not voluntary and never has been.  
               Unfortunately, this was not communicated as clearly as 
               it should have been to state and local jurisdictions." 
                (Id.)

          4.  Illinois and New York Withdraw from S-Comm, and Massachusetts 
          Stays Out  

          On May 4, 2011, Illinois Governor Pat Quinn terminated that 
          state's MOA with ICE regarding S-Comm.  In a letter to the 
          Acting Assistant Director of the Secure Communities program he 
          wrote:

               ISP �Illinois State Police] and ICE executed the 
               Secure Communities MOA in November 2009.  The stated 
               purpose of the program, as set forth in the MOA, is to 
               "identify, detain and remove from the United States 
               aliens who have been  convicted of  serious criminal 
               offenses  and are subject to removal" (emphasis added). 
                ICE statistics on the Secure Communities Program, 
               compiled through February 28, 2011, reveal that the 
               implementation of the Secure Communities program in 
               Illinois is contrary to the stated purpose of the MOA: 
               more than 30% of those deported from the United 
               States, under the program, have never been convicted 
               of  any  crime, much less a serious one.  In fact, by 
               ICE's own measure, less than 20% of those who have 
               been deported from Illinois under the program have 
               ever been convicted of a serious crime.  (Letter dated 
               May 4, 2011, from Illinois Governor Pat Quinn to Mr. 
               Marc Rapp, Immigration and Customs Enforcement, on 
               file with the Committee.)

          On May 5, 2011, the Congressional Hispanic Caucus wrote 
          President Obama asking him to "freeze the Secure Communities 




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          Program ('S-Comm'), effective immediately."  (Letter dated May 
          5, 2011, from Rep. Charles A. Gonzales, Chair, Congressional 
          Hispanic Caucus, to President Barack Obama on file with the 
          Committee.)

          On June 2, 2011, New York Governor Andrew Cuomo announced that 
          he was suspending New York's participation in S-Comm.  Mylan 
          Denerstein, Counsel to Governor Cuomo, wrote in a letter to John 
          Sandweg, Counselor to the Secretary of Homeland Security:

               �U]ntil the numerous questions and controversies 
               regarding the program can be resolved, we have 
               determined that New York is best served by relying on 
               existing tools to ensure the safety of its residents, 
               especially given our overriding concern that the 
               current mechanism is actually undermining law 
               enforcement.  As a result, we are suspending New 
               York's participation in this program.  (Letter dated 
               June 1, 2011, from Mylan Denerstein, Counsel to 
               Governor Cuomo, to John Sandweg, ICE, on file with the 
               Committee; see also Cuomo Ends State's Role in 
               Checking Immigrants (June 2, 2011) New York Times, 
               http://www.nytimes.com/2011/06/02/nyregion/cuomo-pulls-
               new-york-from-us-fingerprint-checks.html?scp=2&sq=%22Se
               cure%20communities%22&st=cse) 


          On June 3, 2011, Mary Heffernan, Massachusetts Secretary of 
          Public Safety and Security sent a letter to the Acting Director 
          of the Secure Communities program stating that Governor Deval 
          Patrick has directed that Massachusetts not enter any MOA to 
          participate in the program for reasons similar to those stated 
          by the Governors of New York and Illinois.  (Letter dated June 
          3, 2011, from Mary Heffernan, Secretary of Public Safety and 
          Security, to Marc Rapp, Acting Director, Secure Communities, 
          Immigration and Customs Enforcement, on file with the 
          Committee.) 

          On August 5, 2011, in response to growing resistance to 
          participation in S-Comm from several states, ICE Director John 




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          Morton wrote Governors stating that his agency was rescinding 
          all signed MOAs and stating further that no signed agreement was 
          necessary for the data sharing to take place, and that the 
          program is mandatory for all jurisdictions.  (Letter dated 
          August 5, 2011, from John Morton to Governor Brown on file with 
          the Committee.)






































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          5.  What This Bill Would Do  

          This bill would direct all law enforcement agencies in 
          California not to continue to detain a person in custody, who is 
          otherwise eligible for release, on the basis of an immigration 
          detainer requests from ICE unless it pertained to a person who 
          had a prior serious or violent felony conviction and did not 
          otherwise violate any federal, state, or local law, or any local 
          policy.  This raises the question whether an immigration "hold" 
          or "detainer" is a voluntary request from ICE or a legal 
          obligation.  Federal regulations on the subject state: 

               Any authorized immigration officer may at any time 
               issue a Form I-247, Immigration Detainer-Notice of 
               Action, to any other Federal, State, or local law 
               enforcement agency.  A detainer serves to advise 
               another law enforcement agency that the Department 
               seeks custody of an alien presently in the custody of 
               that agency, for the purpose of arresting and removing 
               the alien.  The detainer is a request that such agency 
               advise the Department, prior to release of the alien, 
               in order for the Department to arrange to assume 
               custody, in situations when gaining immediate physical 
               custody is either impracticable or impossible.  (8 
               Code of Federal Regulations � 287.7(a).)



          Federal regulations also state:

               Upon a determination by the Department to issue a 
               detainer for an alien not otherwise detained by a 
               criminal justice agency, such agency shall maintain 
               custody of the alien for a period not to exceed 48 
               hours, excluding Saturdays, Sundays, and holidays in 
               order to permit assumption of custody by the 
               Department.  (8 Code of Federal Regulations � 
               287.7(d).)





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          While use of the word "shall" in subdivision (d) of section 
          287.7 could be read to mean that detainers are not requests, it 
          could also be read to mandate that detainers not extend for more 
          than 48 hours.  A federal district court in Indiana recently 
          interpreted these regulations to mean ICE detainers are 
          voluntary requests, which expire after 48 hours:

               If federal or local law enforcement informs ICE that 
               an alien is in custody on non-immigration related 
               charges, ICE may issue a detainer requesting that the 
               law enforcement agency hold the individual for up to 
               48 hours (not including weekend days and holidays) 
               beyond the time that the detainee would otherwise be 
               released in order to allow ICE to assume custody, if 
               it chooses to do so.  (8 C.F.R. � 287.7(d).)  A 
               detainer is not a criminal warrant, but rather a 
               voluntary request that the law enforcement agency 
               "advise �DHS], prior to release of the alien, in order 
               for �DHS] to arrange to assume custody."  (Id. � 
               287.7(a).)  The detainer automatically expires at the 
               end of the 48-hour period. Id.  (Buquer v. City of 
               Indianapolis, 797 F. Supp. 2d 905, 911 (S.D. Ind. 
               2011).)

          This bill also requires the local government in the jurisdiction 
          where a person is held on an ICE detainer to adopt a plan to 
          guard against a United States citizen being detained pursuant to 
          an immigration hold, racial profiling, and victims and witnesses 
          to crime being discouraged from reporting crimes.  The bill 
          specifies, however, that adoption of such a plan is not required 
          before a law enforcement agency could detain a person based on 
          an ICE hold, provided the other criteria in the bill are 
          satisfied.


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