BILL ANALYSIS                                                                                                                                                                                                    �






                             SENATE JUDICIARY COMMITTEE
                             Senator Noreen Evans, Chair
                              2011-2012 Regular Session


          AB 1165 (Achadjian)
          As Amended January 5, 2012
          Hearing Date: June 12, 2012
          Fiscal: No
          Urgency: No
          RD   
                    

                                        SUBJECT
                                           
                         Domestic Violence: Probation: Terms

                                      DESCRIPTION  

          Existing law places specified conditions on the probation of a 
          criminal defendant convicted of certain domestic violence 
          crimes, including that he or she attend a Batterer's Treatment 
          Program (BTP) or another appropriate counseling program 
          designated by the court if none is available, for a period of 
          not less than one year, as specified.   Additionally, it 
          provides that the probation department has the sole authority to 
          approve a batterer's program for this purpose.  

          Existing law, under the Government Tort Claims Act, provides 
          that a public employee is not liable for an injury resulting 
          from the employee's act or omission where it was a result of the 
          exercise of the discretion vested in the employee, whether or 
          not such discretion was abused, except as otherwise provided by 
          statute. 

          This bill would provide that an act or omission relating to the 
          approval of the batterer's treatment programs, as specified, is 
          a discretionary act for the purposes of the above provision. 

                                      BACKGROUND  

          Since 2003, California law has required that, as a condition of 
          probation, a person who has committed certain crimes of domestic 
          violence must attend a Batterer's Treatment Program (BTP).  A 
          BTP must meet certain specifications to qualify for 
          certification for this purpose and existing law designates the 
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          probation department as the sole authority to approve any 
          issuance, denial, suspension, and revocation of BTP 
          certifications, as well as to cease new enrollments or referrals 
          to a batterer's program.  (Pen. Code Sec. 1203.097(c)(5).)  

          In recent years, even though California's Government Tort Claims 
          Act provides for the immunity of public employees and public 
          entities for their discretionary acts or omissions where the 
          injury is a result of the exercise of the discretion vested in 
          the employee, litigation arose in two instances over the issue 
          of certification of certain programs.  (Gov. Code Secs. 820.2 
          and 815.2(b), respectively.)  In light of those cases, this bill 
          seeks to address the issue of liability for probation 
          departments making decisions as to the approval of BTPs.  

          Thus, this bill, sponsored by the Chief Probation Officers of 
          California, would seek to prohibit the need for future 
          litigation over this issue by specifying in these sections that 
          the act or omission related to the approval of the batterer's 
          treatment programs is a discretionary act for the purposes of 
          Section 820.2 of the Government Tort Claims Act.  

                                CHANGES TO EXISTING LAW
           
           Existing law  provides that "domestic violence" is abuse 
          perpetrated against any of the specified persons, including 
          among others: 
           a spouse or former spouse;
           a person with whom the respondent is having or has had a 
            dating or engagement relationship; and
           a child of a party or a child who is the subject of an action 
            under the Uniform Parentage Act, where the presumption applies 
            that the male parent is the father of the child to be 
            protected.  (Fam. Code Sec. 6211.)  
           
          Existing law  requires that a person granted probation for a 
          crime of domestic violence, as defined above, be subject to 
          special conditions upon probation, including, among other 
          things, that the person successfully complete a batterer's 
          program, or another appropriate counseling program designated by 
          the court if none is available, for a period of not less than 
          one year, as specified.  (Pen. Code Sec. 1203.097(a)(6).)  

           Existing law  mandates that the court or the probation department 
          refer defendants only to batterer's programs that follow 
          specified standards.  Existing law requires that the probation 
                                                                      



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          department design and implement an approval and renewal process 
          for batterer's programs and solicit input from criminal justice 
          agencies and domestic violence victim advocacy programs.  (Pen. 
          Code Sec. 1203.097(c).)
           
          Existing law  provides that the probation department shall have 
          the sole authority to approve a batterer's program for probation 
          and that the program shall be required to obtain only one 
          approval, but shall renew that approval annually.  (Pen. Code 
          Sec. 1203.097(c)(5).)

           Existing law  prescribes certain procedures for the approval of a 
          new or existing program.  (Pen. Code Sec. 1203.097(c)(5)(A).)

           Existing law  provides that the probation department has the sole 
          authority to approve the issuance, denial, suspension, or 
          revocation of approval and to cease new enrollments or referrals 
          to a batterer's program.  Existing law requires the probation 
          department to review information relative to a program's 
          performance or failure to adhere to standards, or both.  
          Existing law permits the probation department to suspend or 
          revoke any approval, or deny an application to renew an 
          approval, or to modify the terms and conditions of approval, as 
          specified.  (Pen. Code Sec. 1203.097(c)(5)(C).)    

           Existing law  , the Government Tort Claims Act, provides that a 
          public employee is not liable for an injury resulting from the 
          employee's act or omission where it was a result of the exercise 
          of the discretion vested in the employee, whether or not such 
          discretion was abused, except as otherwise provided by statute.  
          (Gov. Code Sec. 820.2.)

           Existing law  provides that a public entity is not liable for an 
          injury resulting from an act or omission of an employee of the 
          public entity where the employee is immune from liability. (Gov. 
          Code Sec. 815.2(b).)  

           This bill  would provide that an act or omission relating to the 
          approval of the batterer's treatment programs under Section 
          1203.097(c)(5) is a discretionary act pursuant to the above 
          provision. 

           This bill  makes other technical and non-substantive changes. 

                                        COMMENT
           
                                                                      



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          1.    Stated need for the bill  

          According to the author: 

            County probation departments are not clearly provided immunity 
            from civil liability in existing statute for the 
            �certification] of domestic violence batterers programs, 
            resulting in litigation filed against probation departments.  
            Two cases have been brought against a county probation 
            department for failing to approve or renew applications by a 
            provider seeking batterer's Treatment Certification.  As a 
            result of those cases, the concern has been raised to seek to 
            clarify that the decision to approve or disapprove a program 
            is discretionary. 

            Assembly Bill 1165 would provide county probation departments 
            responsible for the certification of domestic violence 
            batterers programs with immunity from civil liability, similar 
            to immunity that is provided to public entities in the 
            Government Code.  This bill would clarify that decisions to 
            approve or disapprove a batterer's treatment program shall be 
            deemed a "discretionary" act.

          The sponsor of the bill, the Chief Probation Officers of 
          California writes: that, "�s]ince 2003, a person who is on 
          probation for committing a crime of domestic violence is subject 
          to special conditions on probation, including completion of an 
          approved batterer's treatment program.  As part of this 
          requirement, probation departments are given 'sole authority' to 
          approve, renew, or revoke a batterer's program.  . . .  It is 
          critical that probation departments have the authority to 
          certify programs that meet all of the requirements of the 
          statute and show compliance with the requirements of the law 
          without being held civilly liable for carrying out these 
          requirements."  

          2.    Government liability traditionally hinges on discretionary 
          versus ministerial acts  

          Existing law requires, as condition of probation, that a 
          defendant who has committed specified crimes of domestic 
          violence complete a Batterer's Treatment Program (BTP), as 
          specified.  Under this law, the probation department is 
          designated as the sole authority for approving the issuance, 
          denial, suspension or revocation of a program's certification 
          and is required to design and implement an approval and renewal 
                                                                      



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          process for these programs.  This bill would expressly state 
          within that section that an act or omission relating to the 
          approval of the batterer's treatment programs, as specified, is 
          a discretionary act for the purposes of the existing provision 
          in the Government Tort Claims Act that provides government 
          employees and entities with this immunity as a general matter.  

          Specifically, that immunity provision provides that a public 
          employee is not liable for an injury resulting from the 
          employee's act or omission where it was a result of the exercise 
          of the discretion vested in the employee, whether or not such 
          discretion was abused, except as otherwise provided by statute.  
          (Gov. Code Sec. 820.2.)  Moreover, because a public entity is 
          not liable for an injury resulting from an act or omission of an 
          employee of the public entity where the employee is immune from 
          liability, the probation department, as well as its employees, 
          would be expressly protected from liability.  (Gov. Code Sec. 
          815.2(b).)  In other words, this bill would result in express 
          immunity from liability for probation departments and their 
          employees who are exercising discretion in the performance of 
          their vested duties under California law, Section 1203.097 of 
          the Penal Code relating to BTPs. 

          It should be noted that probation departments arguably already 
          enjoy the protection of this provision of the Tort Claims Act.  
          While some of the features that a program seeking certification 
          must meet are specified in the statute, and while the probation 
          department is otherwise required to design and provide certain 
          processes for its approval process, the ultimate decision of 
          whether to approve the certification of a program (or, 
          inversely, deny it) is for the probation department to make.  
          Thus, a probation department's performance of its duty to 
          approve such programs necessarily involves discretionary acts as 
          the determination of whether or not an applicant program meets a 
          statutorily required component or otherwise should be certified, 
          on some level, inherently requires the exercise of judgment and 
          discretion of the probation department.  
          Nonetheless, proponents point to two cases that were brought in 
          2009 and 2010 against a probation department regarding the 
          certification of a program.  (See Winds v. Probation Department 
          of Sacramento (2009) U.S. Dist. LEXIS 105548; Sabb v. Sacramento 
          County Superior Court, Sacramento County Probation Department 
          (2010) Case No. 34-2010-80000579.)  While these cases have since 
          been resolved by way of summary judgment in the first case and, 
          according to the author, a settlement in the second, their 
          existence arguably supports the need to specify in the 
                                                                      



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          BTP-related statute that the act of making that decision of 
          approval (or denial) is a discretionary act for which the 
          probation department has immunity under the Tort Claims Act.  

          As a matter of public policy, significant concerns can arise 
          when immunity is provided to certain persons or groups, 
          precluding them from being held liable for injuries they have 
          caused others by their acts or omissions.  At the same time 
          however, governmental immunity serves a significant public 
          policy interest of encouraging public employees and entities to 
          perform their duties as otherwise mandated under the law, 
          without fear of litigation as a result of carrying out 
          compliance with those duties.  The basis of the immunity rule 
          codified in the Tort Claims Act is that "�t]he subjection of 
          officials, the innocent as well as the guilty, to the burden of 
          a trial and to the danger of its outcome would impair their zeal 
          in the performance of their functions and it is better to leave 
          the injury unredressed than to subject honest officials to the 
          constant dread of retaliation."  (Lipman v. Brisbane Elementary 
          School Dist.  (1961) 55 Cal.2d 224, 229.)  

          With respect to the issue of governmental immunity, and 
          important to the application of that immunity both in general 
          and in this bill, is that a distinction has been drawn between 
          discretionary acts and ministerial acts by public employees.  
          Ministerial acts are generally those in which the entity or 
          employee has no choice and is required by law to perform-such as 
          a statutory requirement that the probation department provide a 
          party notice of the requirements to complete a batterer's 
          program under Penal Code Section 1203.097(b)(4).  (Scott v. 
          County of Los Angeles (1994) 27 Cal.App.4th 125.)  In other 
          words it does not require the exercise of judgment and 
          discretion.  This distinction is important, as immunity of a 
          public entity is not achieved where its employee's acts 
          complained of are not discretionary acts within the meaning of 
          the Section 820.2 of the Tort Claims Act.  (Elton v. County of 
          Orange (1970) 3 Cal.App.3d 1053.)  Again, the decision of 
          whether or not to approve the certification of a program is 
          ultimately left to the probation department, and while the 
          statute otherwise provides for elements that a program must 
          meet, it does not require that the probation department approve 
          one that does meet those elements.  

          In attempting to ensure the immunity of probation departments in 
          making decisions surrounding the approval of a program, the bill 
          is appropriately limited in scope to only those discretionary 
                                                                      



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          acts or omissions involved in making that decision of whether or 
          not to approve the certification of a program, as specified.  It 
          does not provide immunity to the probation department or its 
          employees for any other acts or omissions taken in the 
          performance of its other duties under Section 1203.097 relating 
          to the probation of these individuals and BTPs.  
           Support  :  American Federation of State, County and Municipal 
          Employees, AFL-CIO; Association for Los Angeles Deputy Sheriffs; 
          California Probation Parole and Correctional Association; Los 
          Angeles County Probation Officers Union; Riverside Sheriffs' 
          Association; State Coalition of Probation Organizations

           Opposition  :  None Known

                                        HISTORY
           
           Source  :  Chief Probation Officers of California (CPOC)

           Related Pending Legislation  :  None Known

           Prior Legislation  :  None Known

           Prior Vote  :

          Assembly Floor (Ayes 64, Noes 0)
          Assembly Judiciary Committee (Ayes 10, Noes 0)

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