BILL ANALYSIS                                                                                                                                                                                                    �



                                                                            



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                                    THIRD READING


          Bill No:  SB 467
          Author:   Leno (D)
          Amended:  4/1/13
          Vote:     21


           SENATE PUBLIC SAFETY COMMITTEE  :  5-1, 4/30/13
          AYES:  Hancock, Block, De Le�n, Liu, Steinberg
          NOES:  Anderson
          NO VOTE RECORDED:  Knight


          SUBJECT  :    Privacy:  electronic communications:  warrant

           SOURCE :     Electronic Frontier Foundation


           DIGEST  :    This bill requires a search warrant when a  
          governmental agency is seeking the contents of a wire or  
          electronic communication that is stored, held or maintained by a  
          provider, as specified.

           ANALYSIS  :    

          Existing law:

          1.Defines a "search warrant" as an order in writing in the name  
            of the People, signed by a magistrate, directed to a peace  
            officer, commanding him/her to search for a person or persons,  
            a thing or things, or personal property, and in the case of a  
            thing or things or personal property, bring the same before  
            the magistrate.

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          2.Provides grounds in which a search warrant may be issued, as  
            specified.

          3.Provides that a search warrant cannot be issued but upon  
            probable cause, supported by affidavit, naming or describing  
            the person to be searched or searched for, and particularly  
            describing the property, thing or things and the place to be  
            searched.

          4.Provides that a governmental entity may require the disclosure  
            by the provider of the contents of electronic communications  
            in electronic storage for one hundred and eighty days or less  
            only pursuant to a warrant under the Federal Rules or under an  
            equivalent state warrant.

          5.Provides for a process for a search warrant for records that  
            are in the actual or constructive possession of a foreign  
            corporation that provides electronic communication services or  
            remote computing services to the general public, where the  
            records would reveal the identity of the customers using those  
            services, data stored by, or on behalf of, the customer, the  
            customer's usage of those services, the recipient or  
            destination of communications sent or from those customers, or  
            the content of those communications.

          This bill:
           
           1.Removes the requirement that to be subject to warrant  
            procedures the corporation must provide services to the  
            general public.

          2.Provides that a governmental entity shall not obtain from a  
            provider of electronic communication services or remote  
            computing services the contents of a wire or electronic  
            communication that is stored, held, or maintained by that  
            service provider without a valid search warrant issued by a  
            duly authorized magistrate, with jurisdiction of the offense  
            under investigation.

          3.Provides that within three days after a governmental entity  
            receives those contents from a service provider, the  
            governmental entity shall serve upon, or deliver by registered  
            or first-class mail, electronic mail, or other means  
            reasonably calculated to be effective as specified by the  

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            court issuing the warrant, to the subscriber, customer, or  
            user a copy of the warrant and a notice that includes  
            specified information.

          4.Defines "governmental entity" as a department or agency of the  
            state or any political subdivision thereof, or any individual  
            acting for or on behalf of the state or any political  
            subdivision thereof.

          5.Provides that a governmental entity acting under Penal Code  
            Section 1524.5 may, when a search warrant is sought, include  
            in the application a request, supported by a sworn affidavit,  
            for an order delaying the warrant notification required under  
            this bill.  The court shall grant the request for delayed  
            notification if it determines there is reason to believe that  
            notification of existence of the warrant may have an adverse  
            result.  The delay of the notification shall not be for more  
            than 90 days, with extensions granted in 90 day increments  
            upon a continuing finding of the same grounds.

          6.Provides that upon expiration of the period of delay of  
            warrant notification, the governmental entity shall serve  
            upon, or deliver by registered or first-class mail, electronic  
            mail, or other means reasonably calculated to be effective as  
            specified but the court issuing the warrant, the customer,  
            user or subscriber a copy of the warrant together with a  
            notice that does both of the following:

             A.   States with reasonable specificity the nature of the  
               governmental inquiry.

             B.   Informs the customer, user, or subscriber all of the  
               following:

               (1)    That information maintained for the customer or  
                 subscriber by the service provider named in the process  
                 or request was supplied to, or requested by, that  
                 governmental entity and the date on which the supplying  
                 request took place.

               (2)    That warrant notification to the customer or  
                 subscriber was delayed.

               (3)    The grounds for the court's determination to grant  

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                 the delay.

               (4)    Which provisions of the Penal Code authorized the  
                 delay.

          1.Provides that a service provider may divulge the contents of a  
            communication under any of the following circumstances:

             A.   To an addressee or intended recipient of the  
               communication or an agent of the addressee or intended  
               recipient.

             B.   As otherwise authorized by Penal Code Section 1524.2.

             C.   With the lawful consent of the originator, an addressee  
               or intended recipient of the communication, or the  
               subscriber in the case of remote computing service.

             D.   To a person employed or authorized or whose facilities  
               are used to forward the communication to its destination.

             E.   As may be necessary incident to the rendition of the  
               service or to the protection of the rights or property of  
               the provider of that service.

             F.   To law enforcement agency if the contents were  
               inadvertently obtained by the service provider and appear  
               to pertain to the commission of a crime.

             G.   To a governmental entity, if the provider, in good  
               faith, believes that an emergency involving the danger of  
               death or serious physical injury to any person requires  
               disclosure without delay of communications relating to the  
               emergency.

          1.Provides that any provider of electronic communication service  
            or remote computing service, subscriber, or other person  
            aggrieved by any knowing or intentional violation of the  
            warrant and notice provisions may in a civil action, recover  
            from the person, entity, or governmental entity that committed  
            the violation, relief as may be appropriate including but not  
            limited to the following:

             A.   Preliminary and other equitable or declaratory relief.

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             B.   Actual damages suffered by the plaintiff and any profits  
               made by the violator as a result of the violation but no  
               less than $1,000.

             C.   Reasonable attorney's fees and other litigation costs  
               reasonably incurred.

             D.   Punitive damages if the violation is willful and  
               intentional.

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  No   Local:  
           No

           SUPPORT  :   (Verified  5/7/13)

          Electronic Frontier Foundation (source)
          American Civil Liberties Union
          California Attorneys for Criminal Justice
          California Newspaper Publishers Association
          California Public Defenders Association
          The First Amendment Coalition

           OPPOSITION  :    (Verified  5/7/13)

          California District Attorneys Association
          California State Sheriffs' Association

           ARGUMENTS IN SUPPORT  :    According to the author:

               SB 467 updates California's electronic privacy law into the  
               modern age, ensuring emails and other electronic  
               communications content are protected from warrantless  
               government intrusion when stored online and in the cloud.

               Under SB 467, no government entity shall obtain the  
               contents of an electronic communication without a warrant  
               issued by an officer of the court, regardless of how long  
               it has been in electronic storage or whether it has been  
               opened or unopened.

               Law enforcement's ability to investigate and solve crimes  
               with the aid of electronic communications will not be  
               harmed by SB 467.  First, the Federal Department of Justice  

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               recently announced for the first time that it supports a  
               requirement that law enforcement obtain a search warrant  
               before accessing the contents of electronic communications  
               from a service provider.

               Second, SB 467 codifies the practices of some of the  
               biggest technology companies in California, including  
               Google, Facebook, Microsoft and Yahoo!, all of whom require  
               a search warrant before disclosing the contents of  
               electronic communications.

           ARGUMENTS IN OPPOSITION  :    The California District Attorneys  
          Association (CDAA) states:  This bill creates an unnecessary and  
          duplicative state requirement that a government entity obtain a  
          search warrant in order to access the contents of electronic  
          communications from service providers.  This is already required  
          under federal law.

          SB 467 attempts to graft onto California law more of the federal  
          statute without adopting the full federal legislation, which  
          would be unnecessary because it already applies to state and  
          local law enforcement.  The piecemeal approach will simply cause  
          confusion about how to reconcile the two statutory schemes.

          The federal statutes provide a number of exemptions to the  
          nondisclosure rule.  The bill copies those verbatim (except that  
          it eliminates the federal exemption for reports to the National  
          Center for Missing and Exploited Children).  Because the bill  
          would govern private systems, a problem arises because none of  
          those exemptions appear to allow IT in the private system to  
          disclose to management (corporate or governmental)  
          communications of an employee who is abusing the 
          e-mail system.  Obviously, this could be disruptive of business  
          or government operations.

          In short, this bill appears to be completely unnecessary in view  
          of the extensive federal statutes on this subject.  It will  
          inject confusion into the matter by applying different rules to  
          private communications systems and, in fact, may be preempted by  
          federal law.


          JG:ej  5/7/13   Senate Floor Analyses 


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                           SUPPORT/OPPOSITION:  SEE ABOVE

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