BILL ANALYSIS                                                                                                                                                                                                    Ó







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

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          SB 1315 (De León)                                          5
          As Amended March 29, 2012 
          Hearing date:  April 17, 2012
          Government Code
          SM:mc

                       IMITATION FIREARMS: LOS ANGELES EXEMPTION  

                                       HISTORY

          Source:  Los Angeles Police Chief

          Prior Legislation: SB 798 (De León) - 2011, failed passage in 
          Assembly Public Safety
                       AB 352 (Solorio) - Ch. 422, Stats. 2008
                       AB 2537 (Montanez) - 2006, held in Senate 
          Appropriations     
                       SB 1858 (Dunn) - Ch. 607, Stats. 2004
                       SB 292 (Roberti) - Ch. 598, Stats. 1993
                       SB 1795 (Roberti) - Ch. 1605, Stats. 1988

          Support: Mayor of Los Angeles

          Opposition:Airsoft Safety Foundation; Animal Pest Management 
                   Services, Inc.; California Association of Firearms 
                   Retailers; California Rifle and Pistol Association; 
                   California Sportsman's Lobby; National Rifle 
                   Association; National Shooting Sports Foundation; 
                   Outdoor Sportsman's Coalition of California; Safari 
                   Club International


                                         KEY ISSUE




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          SHOULD THE COUNTY OF LOS ANGELES AND ANY CITY WITHIN THE COUNTY 
          OF LOS ANGELES, BE ALLOWED TO ENACT AND ENFORCE AN ORDINANCE OR 
          RESOLUTION THAT IS MORE RESTRICTIVE THAN STATE LAW REGULATING 
          THE MANUFACTURE, SALE, POSSESSION, OR USE OF ANY IMITATION 
          FIREARM THAT EXPELS A PROJECTILE THAT IS NO MORE THAN 16 
          MILLIMETERS IN DIAMETER?


                                       PURPOSE

          The purpose of this bill is create an exemption from the general 
          state preemption of the field regarding the regulation of 
          imitation firearms, to allow the County of Los Angeles, and any 
          city within the County of Los Angeles, to enact and enforce an 
          ordinance or resolution that is more restrictive than state law 
          regulating the manufacture, sale, possession, or use of any BB 
          device, toy gun, replica of a firearm, or other device, that is 
          so substantially similar to an existing firearm as to lead a 
          reasonable person to perceive that the device is a firearm and 
          expels a projectile that is no more than 16 millimeters in 
          diameter.
          
           Current federal law  requires that no person shall manufacture, 
          enter into commerce, ship, transport, or receive any toy, 
          look-alike, or imitation firearm ("device"), as defined, unless 
          such device contains, or has affixed to it a bright orange 
          marking, as specified, covering the circumference of the barrel 
          from the muzzle end for a depth of at least 6 millimeters, 
          unless exempted, as specified.  (15 United States Code § 5001, 
          15 Code of Federal Regulations §§ 1150.2, 1150.3.)  This 
          requirement does not apply to "traditional B-B, paint-ball, or 
          pellet-firing air guns that expel a projectile through the force 
          of air pressure."  (15 United States Code § 5001(c).)

           Current law  provides that by the enforcement of this section, 
          the Legislature occupies the whole field of regulation of the 
          manufacture, sale, or possession of imitation firearms, as 
          defined, and that subdivision shall preempt and be exclusive of 




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          all regulations relating to the manufacture, sale, or possession 
          of imitation firearms, including regulations governing the 
          manufacture, sale, or possession of BB devices and air rifles, 
          as defined.  (Gov. Code § 53071.5.)

           Current law  prohibits, subject to specific exceptions, purchase, 
          sale, manufacture, shipping, transport, distribution, or 
          receipt, by mail order or in any other manner, of an imitation 
          firearm.  (Manufacture for export is permitted.)  Violations are 
          punishable by a civil fine in an action brought by the city 
          attorney or the district attorney of up to $10,000 for each 
          violation.  (Penal Code § 20165.)

           Current law  defines "imitation firearm" for most purposes to 
          mean any BB device, toy gun, replica of a firearm, or other 
          device that is so substantially similar in coloration and 
          overall appearance to an existing firearm as to lead a 
          reasonable person to perceive that the device is a firearm.  
          However, for purposes of the prohibition on commercial 
          manufacture, sale, etc., "imitation firearm" does not include 
          any of the following: 

                 A nonfiring collector's replica that is historically 
               significant, and is offered for sale in conjunction with a 
               wall plaque or presentation case. 
                 A BB device. 
                 A device where the entire exterior surface of the device 
               is white, bright red, bright orange, bright yellow, bright 
               green, bright blue, bright pink, or bright purple, either 
               singly or as the predominant color in combination with 
               other colors in any pattern, as provided by federal 
               regulations governing imitation firearms, or where the 
               entire device is constructed of transparent or translucent 
               materials which permits unmistakable observation of the 
               device's complete contents, as provided by federal 
               regulations governing imitation firearms.  (Penal Code § 
               16700.)

           Current law  defines "BB device" as any instrument that expels a 




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          projectile, such as a BB or a pellet, not exceeding 6mm caliber, 
          through the force of air pressure, gas pressure, or spring 
          action, or any spot marker gun.  (Penal Code § 16250.)

           Current law  provides that sale of any BB device to a minor is a 
          misdemeanor, punishable by up to 6 months in county jail, a fine 
          of up to $1,000, or both.  (Penal Code § 19910.)

           Current law  provides that every person who furnishes any BB 
          device to any minor, without the express or implied permission 
          of a parent or legal guardian of the minor, is guilty of a 
          misdemeanor, punishable by up to 6 months in county jail, a fine 
          of up to $1,000, or both.  (Penal Code § 19915.)

           Current law  provides that any person who changes, alters, 
          removes, or obliterates any coloration or markings that are 
          required by any applicable state or federal law or regulation 
          for any imitation firearm in a way that makes the imitation 
          firearm or device look more like a firearm, is guilty of a 
          misdemeanor.  This section does not apply to a manufacturer, 
          importer, or distributor of imitation firearms.  This section 
          does not apply to lawful use in theatrical productions, 
          including motion pictures, television, and stage productions.  
          (Penal Code § 20150.)

           Current law provides that any imitation firearm manufactured 
          after July 1, 2005, shall, at the time of offer for sale in this 
          state, be accompanied by a conspicuous advisory in writing as 
          part of the packaging, but not necessarily affixed to the 
          imitation firearm, to the effect that the product may be 
          mistaken for a firearm by law enforcement officers or others, 
          that altering the coloration or markings required by state or 
          federal law or regulations so as to make the product look more 
          like a firearm is dangerous, and may be a crime, and that 
          brandishing or displaying the product in public may cause 
          confusion and may be a crime. 

          Any manufacturer, importer, or distributor that fails to comply 
          with this advisory for any imitation firearm manufactured after 




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          July 1, 2005, shall be liable for a civil fine for each action 
          brought by a city attorney or district attorney of not more than 
          one thousand dollars ($1,000) for the first action, five 
          thousand dollars ($5,000) for the second action, and ten 
          thousand dollars ($10,000) for the third action and each 
          subsequent action.  (Penal Code § 20160.)

           Current law  provides that no person may openly display or expose 
          any imitation firearm in a public place, as defined.  (Penal 
          Code § 20170.)  A violation is an infraction punishable by a 
          fine of $100 for the first offense, and $300 for a second 
          offense.  A third or subsequent violation is punishable as a 
          misdemeanor.  (Penal Code § 20180.)

           Current law  provides that every person who, except in 
          self-defense, draws or exhibits an imitation firearm, as 
          defined, in a threatening manner against another in such a way 
          as to cause a reasonable person apprehension or fear of bodily 
          harm is guilty of a misdemeanor punishable by imprisonment in a 
          county jail for a term of not less than 30 days.  (Penal Code § 
          417.4.)

           Current law  provides that possession of an imitation firearm 
          while on school grounds, while going to or coming from school, 
          during the lunch period whether on or off the campus, during, or 
          while going to or coming from a school sponsored activity, or if 
          the possession is otherwise related to school activity or school 
          attendance, is grounds for expulsion.  (Education Code § 
          48900(m).)

           This bill  would provide that, notwithstanding the general state 
          preemption of the field regarding the regulation of imitation 
          firearms, the County of Los Angeles, and any city within the 
          County of Los Angeles, would be permitted to enact and enforce 
          an ordinance or resolution that is more restrictive than state 
          law regulating the manufacture, sale, possession, or use of any 
          BB device, toy gun, replica of a firearm, or other device that 
          is so substantially similar to an existing firearm as to lead a 
          reasonable person to perceive that the device is a firearm and 




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          expels a projectile that is no more than 16 millimeters in 
          diameter.


                    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 
          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 




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          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 
          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




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          1.  Need for This Bill  

          According to the author:

               Penal Code Section 16700 exempts BB guns from the laws 
               that govern imitation firearms.  Therefore, BB guns 
               are not required to follow the requirements set forth 
               for imitation firearms in Penal Code Section 20165.  Ý 
               ] Penal Code Section 20165 restricts the sales, 
               purchase, distribution, manufacturing and 
               transportation of imitation firearms.  This code 
               section exempts the use of imitation firearms for 
               interstate or foreign commerce, sporting and 
               ceremonial military activities, motion picture and 
               theatrical productions. 

               As a result of the exemption of BB guns in Penal Code 
               Section 16700, BB guns are not required to be 
               distinguishable from a real firearm.  Given their 
               striking resemblance to an actual firearm, BB guns 
               have caused the accidental shootings of Californians, 
               especially young adults and minors, by law 
               enforcement.  The use of deadly force by law 
               enforcement should not be taken lightly and the 
               Legislature must act to require BB guns to be 
               distinguishable from real firearms in order to protect 
               law enforcement and the general public.

               SB 798 will Ýamend] Government Code Section 53071.5 to 
               allow LA County and Cities within LA County to enact 
               laws and regulations to address the problem of copycat 
               firearms.

          2.    BB Guns - Background  

          According to Wikipedia:

               BB guns are a type of air gun designed to shoot 




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               projectiles named BBs after the birdshot pellet of 
               approximately the same size.  These projectiles are 
               usually spherical but can also be pointed; those are 
               usually used for bird hunting.  Modern day BB guns 
               usually have a smoothbore barrel, with a bore diameter 
               and caliber of 0.177 inches (4.5 mm).  BBs for modern 
               day BB guns are usually steel, plated either with zinc 
               or copper to resist corrosion, and measure 0.171 to 
               0.173 inches (4.34 mm to 4.39 mm) in diameter.  Some 
               manufacturers also still make lead balls of slightly 
               larger diameter and which are generally intended for 
               use in rifled BB gun barrels, as were formerly used in 
               BB guns.  Some Asian companies make plastic BBs for 
               recreation.


               One of the most famous BB guns is the Red Ryder BB Gun 
               by Daisy Outdoor Products, modeled after the western 
               Winchester rifle.  First introduced in 1938, the BB 
               gun became an iconic American toy, and is still in 
               production today.

               Airsoft guns are also commonly referred to as BB guns 
               or pellet guns, as they also launch spherical 
               projectiles (typically through a smoothbore barrel).  
               Common airsoft "BBs" are 6 mm in diameter (0.24 
               inches), and are generally made of plastic or other 
               non-metallic materials specifically designed to impart 
               low target damage (however, such can still be 
               dangerous if carelessly or improperly used). Airsoft 
               projectiles are often employed for wargames similar to 
               paintball.  (http://en.wikipedia.org/wiki/BB_gun)

          3.  Problems Posed by Imitation Firearms 

           In December 2010, the Los Angeles Times reported:

               The shooting of a 13-year-old Glassell Park boy 
               carrying what turned out to be a pellet gun by a Los 




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               Angeles Police Department officer is a "tragedy," 
               Chief Charlie Beck said.

               "This is a tragedy for all involved, but in particular 
               for the young man injured in this police shooting and 
               for the officer who believed that he was protecting 
               himself and his partner from a real threat," Beck said 
               in a statement.  "The pellet gun the juvenile was 
               using is the exact dimensions of a Beretta 92F and is 
               indistinguishable from a real handgun on a dark 
               night."


               The chief added: "We have seen far too much heartbreak 
               involving these types of realistic-looking guns that 
               are labeled as toys."

               The incident occurred about 7:50 p.m. Thursday when 
               two LAPD officers on routine patrol in the 3000 block 
               of North Verdugo Road saw three pedestrians in the 
               middle of the street and stopped to investigate.  The 
               three people ran, with one ending up behind a van.

               The officers got out of their patrol car, and one of 
               them, Officer Victor Abarca, shined a flashlight on 
               the person behind the van and ordered him to 
               surrender. Based on the person's 5-foot-7, 200-pound 
               frame, Abarca assumed that he was a young adult male.

               Police said the boy refused to comply and instead 
               produced what was later found to be a fake Beretta 92F 
               handgun.  Abarca fired his gun, striking the boy.  Los 
               Angeles Fire Department personnel responded and took 
               the boy to a hospital, where he underwent surgery and 
               was listed in critical but stable condition.

               After the shooting, Abarca and rescue personnel were 
               stunned to learn that the wounded male was, in fact, 
               just 13.  The other two youths, ages 13 and 14, were 




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               detained without incident after dropping their fake 
               handguns.  Three faux weapons were recovered.

               Detectives from the LAPD's force investigation 
               division responded to the scene. Police said they had 
               determined that the subjects had been playing in the 
               dark street, shooting pellets at one another with the 
               fake handguns.  They said they anticipated that no 
               criminal charges would be filed against any of the 
               three juveniles.  (LAPD shooting of 13-year-old with 
               pellet gun is a 'tragedy,' Chief Beck says, Los 
               Angeles Times, December 18, 2010.  
                http://latimesblogs.latimes.com/lanow/2010/12/lapd-shoo
               ting-of-13-year-old-with-pelet-gun-tragedy-for-all-invo
               lved-chief-beck-says.html  )







          4.  State Preemption and the Effect of This Bill  

          The state Constitution authorizes cities and counties to enact 
          "and enforce . . . all local police, sanitary and other 
          ordinances and regulations not in conflict with general laws."  
          (Article XI, section 7).  Since 1988, the Government Code has 
          provided that the state law preempts local regulation of the 
          manufacture, sale, or possession of imitation firearms, 
          including BB devices.  (Gov. Code § 53071.5.)  State law 
          requires bright coloration on "imitation firearms" but does not 
          extend this requirement to "BB guns."  (Penal Code § 
          16700(b)(2).)  Last year SB 798 (De León) proposed extending 
          this requirement to "BB guns" and that bill failed passage in 
          the Assembly Public Safety Committee.  This bill takes a 
          narrower approach and would allow the County of Los Angeles, or 
          any city within the county, to enact its own ordinance or 
          resolution that is more restrictive than state law regulating 




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          the manufacture, sale, possession, or use of any BB device, toy 
          gun, replica of a firearm, or other device that is so 
          substantially similar to an existing firearm as to lead a 
          reasonable person to perceive that the device is a firearm and 
          expels a projectile that is no more than 16 millimeters in 
          diameter.

          COULD THIS RESULT IN A PATCHWORK OF INCONSISTENT STATUTES IN LOS 
          ANGELES COUNTY?

          WHAT ISSUES WOULD THAT POSE FOR LAW ENFORCEMENT?

          5.  Federal Preemption Issues  

          State or local laws that "interfere with, or are contrary to" 
          Federal law are invalid under the Supremacy Clause of the United 
          States Constitution.  (US Const., Art VI, cl (2).)  This is 
          known as the doctrine of preemption.  One issue raised by this 
          bill is whether any local ordinance would be preempted by the 
          Federal Toy Gun Law of 1988.  (15 USC § 5001 and its 
          implementing regulations, 15 CFR 1150.1 et seq.)

          Federal law, the Federal Toy Gun Law, regulates the manufacture 
          of and interstate commerce in "look-alike" or imitation 
          firearms.  (15 USC § 5001.)  Federal law requires that "each 
          toy, look-alike, or imitation firearm shall have as an integral 
          part, permanently affixed, a blaze orange plug inserted in the 
          barrel of such toy, look-alike, or imitation firearm.  Such plug 
          shall be recessed no more than 6 millimeters from the muzzle end 
          of the barrel of such firearm."  (15 USC § 5001(b)(1).)  
          However, these requirements do not apply to any ". . . 
          traditional B-B, paint-ball, or pellet-firing air guns that 
          expel a projectile through the force of air pressure."  (15 USC 
          § 5001(c).)  

          The Federal Toy Gun Law specifically addresses the issue of 
          preemption, which states:

               The provisions of this section shall supersede any 




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               provision of State or local laws or ordinances which 
               provide for markings or identification inconsistent 
               with provisions of this section provided that no State 
               shall--
                  (i) prohibit the sale or manufacture of any 
               look-alike, nonfiring, collector replica of an antique 
               firearm developed prior to 1898, or
                  (ii) prohibit the sale (other than prohibiting the 
               sale to minors) of traditional B-B, paint ball, or 
               pellet-firing air guns that expel a projectile through 
               the force of air pressure.  (15 USCS § 5001(g).)
































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          The question this raises is whether any local ordinance that 
          would require additional or different markings than federal law 
          would be inconsistent with the federal law.  The New York State 
          Court of Appeal has addressed this issue in relation to a local 
          ordinance.  The City of New York passed an ordinance which 
          prohibited look-alike or imitation firearms unless "the entire 
          exterior surface of such toy or imitation firearm is colored 
          white, bright red, bright orange, bright yellow, bright green, 
          bright blue, bright pink or bright purple, either singly or as 
          the predominant color in combination with other colors in any 
          pattern; or such toy or imitation firearm is constructed 
          entirely of transparent or translucent materials which permits 
          unmistakable observation of the imitation or toy firearm's 
          complete contents" as well as other requirements.  (NYC 
          Administrative Code 10-131.)  In response to the claim of one 
          manufacturer that the New York City ordinance was preempted by 
          Federal Toy Gun Law, the Court stated:

               The Federal Toy Gun Law only supersedes State or local 
               laws that "provide for markings or identification 
               inconsistent with" its terms.  The additional 
               conditions imposed by Administrative Code § 10-131 (g) 
               do not conflict with the conditions enumerated in the 
               Federal Toy Gun Law.  As the Appellate Division noted 
               "it is feasible to make a red or purple toy gun Ýwhich 
               bears the manufacturer's trade name and contains] an 
               orange Ýplug], thus satisfying both laws".  Therefore, 
               it is not impossible to comply with both the Federal 
               Toy Gun Law and Administrative Code § 10-131 (g).  
               That the sale of JA-RU's toy guns is only illegal 
               under the terms of the local provision is not a basis 
               for preemption of the City law, as the dissenters 
               below opine, because "this general principle applies 
               only where the Legislature has shown its intent to 
               preempt the field."  Indeed, compliance with both the 
               Federal and local laws at once furthers the intent of 
               Congress and achieves the public safety objective 
               underlying each measure.  The Federal Toy Gun Law 
               seeks to impose some regulatory guidelines, in part, 




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               to override local laws that completely banned toy guns 
               from certain jurisdictions.  In response to these 
               local bans, the Hobby and Toy Industry of America and 
               the Toy Manufacturers of America pressed congressional 
               members for passage of the Federal Toy Gun Law, which 
               by its terms incorporates markings voluntarily adopted 
               by the industry. Against this backdrop, the Federal 
               Toy Gun Law is not an attempt to dominate the field.  
               States and localities can erect a regulatory framework 
               that expands upon the Federal foundation and to the 
               extent that Administrative Code § 10-131 (g) 
               complements the Federal Toy Gun Law, the City's 
               regulatory conditions can coexist with the Federal 
               statute.  (City of New York v. Job-Lot Pushcart, 88 
               N.Y.2d 163, 170-171 (1996).) (citations omitted.) 
               California, like the New York ordinance, already 
               requires imitation firearms to contain similar 
               markings with bright colors throughout the outer 
               surface.  (Penal Code § 16700.)  BB guns, however, 
               were specifically exempted from this requirement.  

          DOES THE FEDERAL TOY GUN LAW PREEMPT LOCAL LAWS REGULATING 
          IMITATION FIREARMS?

          6.  Statement in Support  

          The Mayor of Los Angeles states:

               Currently, local governments are preempted by the 
               Legislature from regulating imitation firearms.  This 
               lack of local regulation has created a public safety 
               concern.  Given their stunning resemblance to 
               firearms, these devices have been involved in the 
               accidental shootings of youth by law enforcement 
               officers.  We must aid our officers in discerning 
               these devices from real firearms by regulating 
               imitation firearms.  Moreover, the safety of our youth 
               who unwittingly point these devices at law enforcement 
               officers is at issue.  We must work to eliminate these 











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               tragic circumstances involving the youth within our 
               cities.  The passage of SB 1315 will provide for the 
               City of Los Angeles to enact regulations that will aid 
               the LAPD to clearly distinguish an imitation gun from 
               a real firearm.

          7.  Statement in Opposition  

          Airsoft Safety Foundation states:

               If paintball gun owners comply with existing state 
               imitation firearm laws applying to BB devices, there 
               should be few, if any problems with paintball gun 
               possession and use at the local level.  The problem is 
               failure to comply with current state laws, not a need 
               for more laws at the local level.

               State BB device laws are generally adequate, but if 
               revisions are needed they should be made at the state 
               level, not by local government.

               Since paintball guns may be transported through 
               several jurisdictions while traveling from a person's 
               home to a place where they may be used, such as a 
               paintball shooting facility, statewide uniformity of 
               laws is necessary.  If each local jurisdiction has its 
               own laws, a person could easily and unknowingly be in 
               an out of compliance while enroute.


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