BILL ANALYSIS                                                                                                                                                                                                    �







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

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          SB 1567( La Malfa)                                          
          As Amended April 16, 2012 
          Hearing date: April 24, 2012
          Penal Code
          SM:dl


                                      FIREARMS: 

                 ELIMINATING WAITING PERIODS FOR CCW LICENSE HOLDERS  


                                       HISTORY

          Source:  National Rifle Association

          Prior Legislation: SB 671 (Lewis) - Chap. 128, Stats. of 1996

          Support: Gun Owners of California

          Opposition:California Police Chiefs Association; California 
                   State Sheriffs' Association; Legal Community Against 
                   Violence; California Chapters of the Brady Campaign to 
                   Prevent Gun Violence



                                     KEY ISSUES

          SHOULD THE 10-DAY WAITING PERIOD BETWEEN THE TIME A GUN IS 
          PURCHASED AND WHEN IT MAY BE DELIVERED NOT APPLY TO THE SALE, 
          DELIVERY, OR TRANSFER OF FIREARMS MADE TO ANY PERSON WHO HAS 




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          BEEN ISSUED A LICENSE TO CARRY A CONCEALED WEAPON, AS SPECIFIED?

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          SHOULD THE DEPARTMENT OF JUSTICE (DOJ), IN RELATION TO ALL 
          BACKGROUND CHECKS OF FIREARMS PURCHASERS, BE REQUIRED TO IMMEDIATELY 
          NOTIFY A FIREARMS DEALER IF, AS A RESULT OF THE BACKGROUND CHECK, 
          DOJ  DETERMINES THAT THE STATUS OF THE PURCHASER IS APPROVED, 
          PROHIBITED, OR ON HOLD, AS SPECIFIED?  


                                       PURPOSE

          The purpose of this bill is to: (1) provide that the 10-day 
          waiting period between the time a gun is purchased and when it 
          may be delivered shall not apply to the sale, delivery, or 
          transfer of firearms made to any person who has been issued a 
          license to carry a concealed weapon, as specified; (2) create an 
          exemption from the 10-day waiting period for peace officers who 
          are allowed to carry concealed weapons even without a CCW; (3 
          specify that the background check required under current law of 
          all CCW license applicants or those applying to renew a CCW 
          license, must include a federal National Instant Criminal 
          Background Check System ("NICS") check; and (4) require the 
          Department of Justice (DOJ), in relation to all background 
          checks of firearms purchasers, to immediately notify a firearms 
          dealer if, as a result of the background check, DOJ determines 
          that the status of the purchaser is approved, prohibited, or on 
          hold, as specified.  

           Existing federal law  requires licensed firearms dealers, before 
          they may deliver a firearm to a purchaser, to perform a 
          background check on the purchaser through the federal National 
          Instant Criminal Background Check System ("NICS").  (18 U.S.C �� 
          921, et seq.)
           
          Current law  requires all sales, loans, and transfers of firearms 




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          to be processed through or by a state-licensed firearms dealer 
          or a local law enforcement agency.  (Penal Code � 27545.)

           Current law  provides that, except as specified, there is a 
          10-day waiting period when purchasing a firearm through a 
          firearms dealer.  During which time, a background check is 
          conducted and, if the firearm is a handgun, a handgun safety 
          certificate is required prior to delivery of the firearm.  
          (Penal Code �� 26815, 26840(b) and 27540.)

           Current law  states that no person shall make an application to 
          purchase more than one handgun within any 30-day period.  (Penal 
          Code � 27535(a).)  

           Current law  recognizes numerous exceptions to the 
          one-gun-per-month restriction, including an exception for anyone 
          who may claim an exemption to the 10-day waiting period.  (Penal 
          Code � 27535(b)(7).)
           
          Current law  states that when a person applies for a license to 
          carry a pistol, revolver, or other firearm capable of being 
          concealed upon the person, the sheriff of a county may issue a 
          license to that person upon proof of all of the following:
                 The applicant is of good moral character.
                 Good cause exists for issuance of the license.
                 The applicant is a resident of the county or a city 
               within the county, or the applicant's principal place of 
               employment or business is in the county or a city within 
               the county and the applicant spends a substantial period of 
               time in that place of employment or business.
                 The applicant has completed a course of training as 
               specified.

          The sheriff may issue this license in either of the following 
          formats:

                 A license to carry concealed a pistol, revolver, or 
               other firearm capable of being concealed upon the person.
                 Where the population of the county is less than 200,000 




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               persons according to the most recent federal decennial 
               census, a license to carry loaded and exposed in only that 
               county a pistol, revolver, or other firearm capable of 
               being concealed upon the person.

          The police chief of a city or city and county may also issue 
          such licenses, according to the same criteria, to residents of 
          that city.

          (Penal Code � 26150.)

           Current law  provides that the fingerprints of each applicant 
          shall be forwarded to DOJ and that, upon receipt of the 
          fingerprints and the appropriate fees, DOJ shall promptly 
          furnish the forwarding licensing authority a report of all data 
          and information pertaining to any applicant of which there is a 
          record in its office, including information as to whether the 
          person is prohibited by state or federal law from possessing, 
          receiving, owning, or purchasing a firearm.  Current law 
          requires that no license shall be issued by any licensing 
          authority until after receipt of the report from the department. 
           (Penal Code � 26185.)

           This bill  would provide that the 10-day waiting period between 
          the time a gun is purchased and when it may be delivered shall 
          not apply to the sale, delivery, or transfer of firearms made to 
          any person who has been issued a license to carry a concealed 
          weapon, as specified.

           This bill  would create an exemption from the 10-day waiting 
          period for peace officers who are allowed to carry concealed 
          weapons even without a CCW.

           This bill  would specify that, one of the requirements that must 
          be met before a sheriff may issue a CCW license is proof that 
          the applicant is not prohibited by law from possessing a 
          firearm.

           This bill  would specify that the background check required under 




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          current law of all CCW license applicants or those applying to 
          renew a CCW license, must include a federal NICS check.

           This bill  would limit the exception to the 10-day waiting period 
          that exists under current law for peace officers to state that 
          this exception does not apply to the sale, delivery or transfer 
          of firearms to a peace officer for their personal use. 

          This bill  would require DOJ to immediately notify a firearms 
          dealer if the department determines that the status of the 
          purchaser is approved or prohibited.  If the status of the 
          purchaser is not approved or prohibited, then the department 
          would be required, within 24 hours of the transmission of the 
          electronic or telephonic record, to respond with an approved or 
          prohibited status immediately upon completion of the 
          department's background investigation.  For purposes of this 
          section, the following terms have the following meanings:

                 "Approved" means the individual is not prohibited by 
               state or federal law from possessing, receiving, owning, or 
               purchasing a firearm.
                 "On hold" means the available information indicates that 
               further investigation is required to determine whether the 
               individual is approved or prohibited from possessing, 
               receiving, owning or purchasing a firearm.
                 "Prohibited" means an individual is prohibited by state 
               or federal law from possessing, receiving, owning or 
               purchasing a firearm. 

          If a dealer receives a hold status, the dealer would be required 
          to withhold delivery of the firearm until the dealer receives an 
          approved status for the purchaser from DOJ.


                    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 




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          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 
          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 




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          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

          1.  Need for This Bill  

          According to the author:

               Currently all California residents are subject to a 
               10-day wait period for firearm purchases with few 
               exceptions.  There is no reason that holders of a 




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               permit to carry a concealed weapon need to be subject 
               to such a wait period.

               CCW holders have already gone through a rigorous 
               process to obtain these permits, which require 
               approval by local sheriffs and training in firearm 
               safety.  They have had to prove themselves qualified 
               both with their weapons and California firearms laws.  
               California trusts permit holders to carry guns on 
               their person every day. There is no reason to make 
               them wait to take possession of additional firearms.

               California CCW permit holders are part of what is 
               known as a "RapBack" system.  This system immediately 
               alerts the Department of Justice of any violation that 
               would prohibit a permit holder from possession of 
               firearms.  Upon notification, the DOJ in turn relays 
               that information to the permit issuing agency 
               (typically the local county sheriff's department). 
               That local agency would then confiscate any firearms 
               and the permit from the violating CCW holder.

               CCW permit holders are held to a much stricter 
               standard than the average gun owner in California.  
               Because of the RapBack system, any violation that 
               would prevent or even question their worthiness to be 
               entrusted with firearms in the state is discovered 
               immediately.  This is not the case with non CCW 
               holders.  Residents that attempt the thorough process 
               of obtaining a permit and are successfully granted one 
               are willingly placing themselves under the increased 
               scrutiny of law enforcement.

               This bill would also include both current and retired 
               law enforcement that have been approved for concealed 
               carry as they are not required to obtain a CCW.

          2.  The 10-Day Waiting Period  





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          Under California law, prior to 1997, there was a 15-day waiting 
          period between the time a gun was purchased and the time the 
          dealer could deliver the gun to the buyer.  In 1997, that was 
          shortened to the current 10-day waiting period.  (SB 671 (Lewis) 
          - Chap. 128, Stats. of 1996.)  The rationale for a waiting 
          period is twofold: first, to give law enforcement officials an 
          opportunity to conduct a background check on the prospective 
          firearm purchaser to ascertain whether that person is prohibited 
          by law from possessing a firearm and, second, to allow a 
          "cooling off" period in the event the purchaser is seeking the 
          firearm in a state of distress.  The differences between 
          California and federal background checks are discussed in detail 
          below.

          3.   Background Checks, State and Federal  

          Both state and federal law require licensed firearms dealers to 
          perform background checks on prospective firearms purchasers 
          before the weapon may be delivered, to determine whether the 
          purchaser falls into a category of persons prohibited by law 
          from purchasing or possessing firearms.  However, the background 
          checks performed in California are, according to the state 
          Department of Justice (DOJ), more extensive than that performed 
          by the federal NICS background check.  

          The Federal National Instant Criminal Background Check System 
          ("NICS")
          
          The Brady Handgun Violence Prevention Act of 1993 originally 
          imposed a five-day waiting period on handgun purchases for law 
          enforcement to review the background of a prospective purchaser. 
          The five-day waiting period has now been replaced with an 
          instant check system, which can be extended to three days when 
          the results of the check are not clear.  (18 U.S. C. � 921, et 
          seq.)  If the firearms dealer has not been notified within three 
          business days that the sale would violate federal or state laws, 
          the sale may proceed, even if the background check is not 
          completed.  (18 U.S.C. � 922(t)(1).)





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          In complying with federal firearms background check requirements 
          (the "Brady Act"), States have the option of serving as a state 
          Point of Contact ("POC") and conducting their own NICS checks, 
          or having those checks performed by the Federal Bureau of 
          Investigation (FBI).  FBI checks are provided at no charge; 
          state law determines the cost of background checks performed by 
          the state (POC).  

          A licensed firearms dealer initiates a NICS check by contacting 
          the FBI or state POC (typically by telephone or computer) after 
          the prospective purchaser has provided a government-issued photo 
          I.D. and completed a federal Firearms Transaction Record.  (27 
          Code of Fed.Regs. � 478.124(c)(4).)  The FBI or POC must then 
          conduct a name-based search of federal and state databases.  FBI 
          searches include three federal databases: 

                 The National Crime Information Center (NCIC), which 
               includes records regarding wanted persons (fugitives) and 
               persons subject to protective/restraining orders;
                 The Interstate Identification Index, which contains 
               state criminal history records; and
                 The NICS Index, which contains records of other persons 
               prohibited under federal law from receiving or possessing 
               firearms.

          (Criminal Justice Information Services Division of the Federal 
          Bureau of Investigation, U.S. Department of Justice, National 
          Instant Criminal Background Check System (NICS) Operations 2010, 
          at page 1.) 

          Once the initial search is complete, the FBI or POC notifies the 
          dealer that the sale: 1) may proceed; 2) may not proceed; or 3) 
          is delayed pending further investigation.  The NICS check is 
          valid for a single transaction for up to 30 calendar days from 
          the date NICS was initially contacted.  (27 Code of Fed.Regs. � 
          478.102(c).)  The 30-day period covers only a single 
          transaction. The transaction may, however, involve the transfer 
          of multiple firearms.  





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          As noted above, if the initial NICS check does not come back 
          "clean," but the reason for that cannot be determined within 3 
          days, the firearms dealer, the sale may proceed.  (18 U.S.C. � 
          922(t)(1).)  As a result, in 2010, the NICS Section referred 
          2,955 cases to the federal Bureau of Alcohol Tobacco and 
          Firearms to retrieve firearms that were sold to persons later 
          determined to be prohibited.  (Criminal Justice Information 
          Services Division of the Federal Bureau of Investigation, U.S. 
          Department of Justice, National Instant Criminal Background 
          Check System (NICS) Operations 2010, at page 15.)  No 
          information is available to determine how successful federal law 
          enforcement authorities were in retrieving those firearms.



          Background Checks in California
          
          According to DOJ:

          All firearm purchaser-related background checks properly 
          submitted by dealers through the DOJ Dealer Record of Sale 
          (DROS) Entry System initiate a CA Basic Firearms Eligibility 
          Check (BFEC).  This process includes name-based checks (not 
          fingerprint based checks) for records in the following 
          state/federal databases: 

                 California Automated Criminal History System (ACHS); 
                 California Restraining and Protective Order System 
               (CARPOS);
                 California Wanted Persons System (WPS); 
                 California Mental Health Firearms Prohibition System 
               (MHFPS); 
                 California Department of Motor Vehicles (DMV) for ID 
               validation; 
                 The federal Interstate Identification Index (III) 
               database; 
                 Federal National Crime Information Center (NCIC) 
               database; 
                 Federal National Instant Criminal Background Check 




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               System (NICS); and 
                 Federal Immigration Customs and Enforcement (ICE) 
               database.

          In addition to checking databases that the federal NICS does not 
          check, and tracking down information that is not automated, 
          unlike the federal NICS check, if DOJ is unable to receive 
          complete information in connection with the background check 
          within the 10-day waiting period has run, according to DOJ, they 
          will instruct the firearms dealer not to release the firearm to 
          the purchaser until they have resolved the issue and determined 
                                                  that the purchaser is not a prohibited person.  

          4.  CCW Holders Are Exempt from Background Checks Under Federal 
          Law  

          A person holding a state-issued permit allowing the person to 
          acquire or possess firearms (e.g., a concealed weapons permit or 
          CCW) is not required, under federal law, to undergo a background 
          check if the permit was issued: 1) within the previous five 
          years in the state in which the transfer is to take place; and 
          2) after an authorized government official has conducted a 
          background investigation to verify that possession of a firearm 
          would not be unlawful.  (18 U.S.C. � 922(t)(3); 27 Code of Fed. 
          Regs. � 478.102(d).)  Permits issued after November 30, 1998 
          qualify as exempt only if the approval process included a NICS 
          check.  (27 Code of Fed. Regs. � 478.102(d).) 

          5.  What this Bill Would Do  

          This bill would establish that the current 10-day waiting period 
          would not apply to persons holding a license to carry a 
          concealed weapon or to a peace officer who is authorized to 
          carry a concealed weapon.  This bill would further require DOJ 
          to make substantial changes to the way it conducts background 
          checks on all prospective firearms purchasers.  Regardless of 
          the 10-day waiting period, it would require DOJ to immediately 
          notify a firearms dealer if the department determines that the 
          status of the purchaser is approved or prohibited.  If DOJ is 




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          not able to determine whether the buyer is a prohibited person, 
          it would be required, within 24 hours of "the transmission of 
          the electronic or telephonic record," to respond with an 
          approved or prohibited status immediately upon completion of the 
          department's background investigation.






































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          The first issue this raises is whether possession of a concealed 
          weapons permit obviates the need for a waiting period.  
          Proponents argue that such CCW holders are part of a database at 
          DOJ that is constantly being updated to reflect any new 
          information that would render them ineligible to possess a 
          firearm.  This database, however, relies on input from several 
          sources.  How quickly relevant data, such as a new criminal 
          conviction or the CCW holder being declared mentally unstable, 
          would be uploaded into the Automated Firearms System (AFS) would 
          likely vary, depending on the resources available at the point 
          where that data would need to be entered.  The result could be 
          that a CCW holder who has, since the time they were issued their 
          CCW license, become prohibited from possessing a firearm, would 
          nonetheless be able to purchase and take possession of a firearm 
          without any background check being conducted.  

          Proponents argue that the rationale for the background check no 
          longer applies since this person already has at least one 
          firearm already anyway.  Members may wish to consider whether 
          this would always be true.  A CCW holder could be purchasing a 
          new gun to replace one that was lost or stolen and it is not 
          currently required for gun owners to report lost or stolen guns. 
           Given the potential delays in updating information in the AFS 
          database, as described above, even if the CCW holder does 
          already possess a firearm, would that justify allowing a 
          potentially prohibited person to obtain more firearms than they 
          already have?  

          Another issue this raises is whether the Department of Justice 
          should be required to completely revamp the way it conducts 
          background checks to allow CCW holders to avoid having to wait 
          10 days to obtain a new firearm.  

          6.  Statements in Support  

          The National Rifle Association states:

               Californians that are licensed to carry a concealed 
               weapon (CCW), have been screened, trained and 




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               background checked by the Law Enforcement agencies 
               that have issued the license.  The information 
               pertaining to the CCW licenses have been entered into 
               a special database that is maintained by the 
               California Department of Justice (DOJ).  This 
               "wrap-back file" monitors the legal status of the CCW 
               licensee on a day to day basis to assure the issuing 
               Law Enforcement agency that the licensee has not 
               committed an act that would make them prohibited from 
               possessing a firearm or make them ineligible for 
               continuing to retain the CCW license issued to them.


          The Gun Owners of California state:

               This bill is nothing more than a common sense measure 
               that exempts law-abiding citizens who have already 
               passed extensive background checks and personal 
               interviews with their local law enforcement agencies, 
               and active and retired police and sheriff's deputies 
               from having to wait 10 days before receiving a newly 
               purchased firearm.

               The 10 day Waiting Period serves no purpose because by 
               definition these individuals already have firearms and 
               are the most tightly controlled and monitored people 
               in California regarding firearm use and possession.

          7.  Statement in Opposition

           The California Chapters of the Brady Campaign Against Gun 
          Violence states:

               Based on our conversations with personnel at DOJ, the 
               agency responsible for performing background checks, 
               it often takes a full 10 days to perform a complete 
               and thorough records check, particularly in the case 
               of first time purchasers.  It might, in theory, be 
               possible to shorten this time period.  In order to 











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               accomplish this, the Bureau's workload would be 
               significantly altered and expanded, including costly 
               database upgrades.  This additional cost should be 
               covered entirely by individuals requesting expedited 
               service and not from general Dealer Record of Sale 
               reserve funds that are critical for firearms-related 
               regulatory and enforcement activities.

               Stepping away from the details of how to actually 
               accomplish this proposal is the larger question of 
               whether it is in the public interest to expedite the 
               delivery of firearms to prospective purchasers.  In 
               this case, the purchasers are already in possession of 
               a firearm so expedited delivery serves no protective 
               function whatsoever.  If this system were to be in 
               place, it would be used as an argument to shorten 
               waiting periods in other situations, including first 
               time buyers.  This would clearly not be in the 
               interest of public safety.

          The California State Sheriffs' Association states:

               SB 1567 presents a significant problem for public 
               safety.  While we understand the � ] rationale that 
               individuals who possess a concealed weapons permit 
               (CCW) have been through a thorough background check, 
               we must not neglect to take into account that these 
               individuals also have the potential to go purchase a 
               gun in a fit of rage.  The 10 day wait period that is 
               in current law isn't to prevent individuals from 
               obtaining guns, but to instead help to guard against 
               impulsive acts of violence.


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