BILL ANALYSIS �
SENATE COMMITTEE ON PUBLIC SAFETY
Senator Loni Hancock, Chair S
2013-2014 Regular Session B
9
8
2
SB 982 (Huff)
As Amended: April 9, 2014
Hearing date: April 22, 2014
Penal Code
JM:sl
PROSTITUTION:
SOLICITATION FROM A MINOR
HISTORY
Source: Los Angeles County Board of Supervisors
Prior Legislation: AB 17 (Swanson) - Ch. 211, Stats. 2009
AB 12 (Swanson) Ch. 75, Stats. 2011
Support: California Alliance of Child and Family Services;
California Contract Cities Association; Crittenton
Services for Children and Families; City of Long Beach;
Conference of California Bar Associations; Numerous
Private Individuals
Opposition:California Attorneys for Criminal Justice; California
Public Defenders Association; Taxpayers for Improving
Public Safety
KEY ISSUE
SHOULD A PERSON WHO SEEKS TO PURCHASE OR PURCHASES AN ACT OF
PROSTITUTION FROM A MINOR BE GUILTY OF AN ALTERNATE
FELONY-MISDEMEANOR?
SHOULD A REPEATED CONVICTION OF THIS CRIME BE A STRAIGHT FELONY?
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PURPOSE
The purpose of this bill is to provide that soliciting an act of
prostitution from a minor, or engaging in an act of prostitution
with a minor, is an alternate felony-misdemeanor for a first
conviction and a straight felony for a repeated conviction.
Prostitution Offenses Generally
Existing law provides that prostitution involves any lewd act
between persons for money or other consideration. (Pen. Code �
647, subd. (b); CALCRIM 1154)
Existing decisional law defines a lewd act as "touching the
genitals, buttocks, or female breast of either the prostitute or
customer with some part of the other person's body for the
purpose of sexual arousal or gratification." (CALCRIM 1154,
citing Pryor v. Municipal Court (1979) 25 Cal.3d 238, 256; See,
Wooten v. Superior Court (2001) 93 Cal.App.4th 422, pp.
431-433.)
Existing law provides that any person who solicits, agrees to
engage in, or engages in an act of prostitution is guilty of a
misdemeanor. The crime includes an element that the defendant
specifically intended to engage in an act of prostitution and
some act was done in furtherance of the agreed upon act. (Pen.
Code � 647, subd. (b).)
Existing law provides that where any person is convicted for a
second prostitution offense, the person shall serve a sentence
of at least 45 days, no part of which can be suspended or
reduced by the court regardless of whether or not the court
grants probation. (Pen. Code � 647, subd. (k).)
Existing law provides that where any person is convicted for a
third prostitution offense, the person shall serve a sentence of
at least 90 days, no part of which can be suspended or reduced
by the court regardless of whether or not the court grants
probation. (Pen. Code � 647, subd. (k).)
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Existing law provides that where a defendant is convicted of a
prostitution offense in which the defendant sought to procure or
procured the "sexual services of a prostitute who was a minor,
the following shall apply:
The defendant shall, in addition to any other fine or penalty,
be ordered to pay up to $25,000; and,
Upon appropriation by the Legislature, the proceeds of the
fine shall "be available to fund programs and services for
commercially sexually exploited minors in the counties" of
conviction. (Pen. Code �� 261.9 and 647, subd. (b).)
Sex Crimes Against or Involving Minors
Existing law provides that a minor cannot consent to a sexual
act, including sexual intercourse, oral copulation, sodomy,
sexual penetration with a foreign or unknown object, or lewd
conduct. (Pen. Code �� 261.5, 286, 288, 288a, and 289, in
relevant part.)
Existing law provides that sexual intercourse with a minor where
no aggravating elements are proved is the crime of "unlawful
sexual intercourse," punishable as follows:
Where the person having intercourse with the minor is no
more than three years older or younger than the minor, the
offense is a misdemeanor, with a maximum jail term of 6
months.
Where the person is at least three years older than the
minor, the offense is an alternate felony-misdemeanor
(wobbler), with a maximum misdemeanor term of one year and
a felony jail term of 16 months, two years or three years.
Where the person is at least 21 and the minor under 16
years of age, the offense is a wobbler, with a felony jail
term of 2, 3 or 4 years. (Pen. Code � 261.5.)
Existing law provides that in the absence of aggravating
elements each crime of sodomy, oral copulation or penetration
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with a foreign or unknown object with a minor is punishable as
follows:
Where the defendant is over 21 and the minor under 16
years of age, the offense is a felony, with a prison term
of 16 months, 2 years or 3 years.
In other cases sodomy with a minor is a wobbler, with a
felony prison term of 16 months, 2 years or 3 years. (Pen.
Code �� 286, subd. (b), 288a, subd. (b), 289, subd. (h).)
Existing law provides that where each crime of sodomy, oral
copulation or penetration with a foreign or unknown object with
a minor who is under 14 and the perpetrator is more than 10
years older than the minor, the offense is a felony, punishable
by a prison term of 3, 6 or 8 years. (Pen. Code �� 286, subd.
(c)(1), 288a, subd. (c)(1), 289, subd. (j).)
Existing law specifically provides that sexual intercourse is
rape "[w]here a person is incapable, because of a mental
disorder or developmental or physical disability, of giving
legal consent, and this is known or reasonably should be known
to the" perpetrator. (Pen. Code � 261, subd. (a)(1).)
Existing law provides that any person who engages in lewd
conduct - any sexually motivated touching or a defined sex act -
with a child under the age of 14 is guilty of a felony,
punishable by a prison term of 3, 6 or 8 years. Where the
offense involves force or coercion, the prison term is 5, 8 or
10 years. (Pen. Code � 288, subd. (b).)
Existing law provides that where any person who engages in lewd
conduct with a child who is 14 or 15 years old, and the person
is at least 10 years older than the child, the person is guilty
of an alternate felony-misdemeanor, punishable by a jail term of
up to one year, a fine of up to $1,000, or both, or by a prison
term of 16 months, two years or three years and a fine of up
$10,000. (Pen. Code � 288, subd. (c)(1).)
This bill provides that a person who "seeks to procure or does
procure the sexual services" of a juvenile prostitute "in
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violation of subdivision (b) of Section 647" is guilty of an
alternate felony-misdemeanor for a first conviction and a felony
for a second or subsequent conviction.
A first conviction is alternate felony-misdemeanor, punishable
by a jail term of up to six months, a fine of up to $1,000, or
both, or by a felony jail term (Pen. Code � 1170, subd. (h))
of 16 months, two years or three years and a fine of up to
$10,000.
A second or subsequent conviction is a felony, punishable by a
felony jail term (Pen. Code � 1170, subd. (h)) and a fine of
up to $10,000.
This bill provides that it shall only apply to the person in a
prostitution offense who agrees to provide anything of value to
a minor in exchange for a sex act or provided something of value
to a minor in exchange for a sex act.
RECEIVERSHIP/OVERCROWDING CRISIS AGGRAVATION
For the last several years, severe overcrowding in California's
prisons has been the focus of evolving and expensive litigation
relating to conditions of confinement. On May 23, 2011, the
United States Supreme Court ordered California to reduce its
prison population to 137.5 percent of design capacity within two
years from the date of its ruling, subject to the right of the
state to seek modifications in appropriate circumstances.
Beginning in early 2007, Senate leadership initiated a policy to
hold legislative proposals which could further aggravate the
prison overcrowding crisis through new or expanded felony
prosecutions. Under the resulting policy, known as "ROCA"
(which stands for "Receivership/ Overcrowding Crisis
Aggravation"), the Committee held measures that created a new
felony, expanded the scope or penalty of an existing felony, or
otherwise increased the application of a felony in a manner
which could exacerbate the prison overcrowding crisis. Under
these principles, ROCA was applied as a content-neutral,
provisional measure necessary to ensure that the Legislature did
not erode progress towards reducing prison overcrowding by
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passing legislation, which would increase the prison population.
In January of 2013, just over a year after the enactment of the
historic Public Safety Realignment Act of 2011, the State of
California filed court documents seeking to vacate or modify the
federal court order requiring the state to reduce its prison
population to 137.5 percent of design capacity. The State
submitted that the, ". . . population in the State's 33 prisons
has been reduced by over 24,000 inmates since October 2011 when
public safety realignment went into effect, by more than 36,000
inmates compared to the 2008 population . . . , and by nearly
42,000 inmates since 2006 . . . ." Plaintiffs opposed the
state's motion, arguing that, "California prisons, which
currently average 150% of capacity, and reach as high as 185% of
capacity at one prison, continue to deliver health care that is
constitutionally deficient." In an order dated January 29,
2013, the federal court granted the state a six-month extension
to achieve the 137.5 % inmate population cap by December 31,
2013.
The Three-Judge Court then ordered, on April 11, 2013, the state
of California to "immediately take all steps necessary to comply
with this Court's . . . Order . . . requiring defendants to
reduce overall prison population to 137.5% design capacity by
December 31, 2013." On September 16, 2013, the State asked the
Court to extend that deadline to December 31, 2016. In
response, the Court extended the deadline first to January 27,
2014 and then February 24, 2014, and ordered the parties to
enter into a meet-and-confer process to "explore how defendants
can comply with this Court's June 20, 2013 Order, including
means and dates by which such compliance can be expedited or
accomplished and how this Court can ensure a durable solution to
the prison crowding problem."
The parties were not able to reach an agreement during the
meet-and-confer process. As a result, the Court ordered
briefing on the State's requested extension and, on February 10,
2014, issued an order extending the deadline to reduce the
in-state adult institution population to 137.5% design capacity
to February 28, 2016. The order requires the state to meet the
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following interim and final population reduction benchmarks:
143% of design bed capacity by June 30, 2014;
141.5% of design bed capacity by February 28, 2015; and,
137.5% of design bed capacity by February 28, 2016.
If a benchmark is missed the Compliance Officer (a position
created by the February 10, 2016 order) can order the release of
inmates to bring the State into compliance with that benchmark.
In a status report to the Court dated February 18, 2014, the
state reported that as of February 12, 2014, California's 33
prisons were at 144.3 percent capacity, with 117,686 inmates.
8,768 inmates were housed in out-of-state facilities.
The ongoing prison overcrowding litigation indicates that prison
capacity and related issues concerning conditions of confinement
remain unresolved. While real gains in reducing the prison
population have been made, even greater reductions may be
required to meet the orders of the federal court. Therefore,
the Committee's consideration of ROCA bills -bills that may
impact the prison population - will be informed by the following
questions:
Whether a measure erodes realignment and impacts the
prison population;
Whether a measure addresses a crime which is directly
dangerous to the physical safety of others for which there
is no other reasonably appropriate sanction;
Whether a bill corrects a constitutional infirmity or
legislative drafting error;
Whether a measure proposes penalties which are
proportionate, and cannot be achieved through any other
reasonably appropriate remedy; and,
Whether a bill addresses a major area of public safety
or criminal activity for which there is no other
reasonable, appropriate remedy.
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COMMENTS
1. Need for this Bill
According to the author:
The Protected Innocence Challenge Report gives
California a failing grade because penalties for
solicitation of a minor are not making a dent in sex
trafficking. Prosecutors can charge persons who
solicit or pay for the sexual services of a minor with
a felony if the minor is age 15 or younger. However,
where the minor is 16 or 17 years of age, buyers, or
"johns" often face minimal penalties and return to
their lives virtually unscathed, while the children
they exploit are shattered and denied justice.
Because California has failed to make the actions of
the buyer a serious crime, solicitation of a minor
will continue to be viewed as a mere "vice" crime,
rather than rape and sexual abuse of a child. Until
the law is changed we are perpetuating the
exploitation of children caught in a web of sexual and
financial slavery they cannot easily escape.
Sweden's landmark legislation 1999 criminalizing sex
buyers resulted in a significant decrease in
trafficking - from 13.6% to less than 8%. Sweden now
has the least trafficking victims in the European
Union. Many other states are drafting their own
version of the Swedish model to combat sex
trafficking.
According to the LA Times, May 31, 2012, "When the Los
Angeles County Probation Department ?analyzed arrests
for prostitution, they found that underage sex
trafficking is a not only a Third World problem. In
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2010, 174 prostitution cases referred to the
department involved girls under the age of 18.
Another 2,351 involved 18-to-24-year-olds. Statistics
paint a grim picture of poverty and troubled family
lives." With the pervasive use of the Internet and
public transportation, children can be bought and sold
across state and international borders with ease.
This is our modern day form of slavery [that] inflicts
life-long psychological, emotional and physical
damage.
SB 982 will enable prosecutors to obtain felony
convictions for persons who solicit sex from minors,
including minors who are 16 or 17. Specifically, SB
982 will make it an alternate felony-misdemeanor,
punishable by a felony jail term of 16 months, 2 years
or 3 years, or a misdemeanor jail term, for anyone who
seeks to procure or procures the sexual services of a
juvenile prostitute. A repeated conviction will be a
straight felony. SB 982 sends a strong message that
prostitution of children at any age in California will
be met with the just and serious punishment that fits
the crime.
2. References to "Procuring the Sexual Services of a Prostitute"
in the Bill and Existing Law
Existing law provides that it is a misdemeanor to solicit, agree
to engage in, or engage in an act of prostitution. An act of
prostitution includes any lewd act between persons for money or
other consideration. This bill amends a Penal Code section
(261.9) that requires imposition of a fine of up to $25,000 if
the defendant is convicted "procuring or attempting to procure
the sexual services of a prostitute in violation of subdivision
(b) of [Penal Code] Section 647 " where the "prostitute" was
under the age of 18. The use of the term "procure" is confusing
in the context of purchasing sex acts. To procure has been used
over time to refer to hiring another person to obtain the
services of a prostitute or placing a person in a house of
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prostitution. That is, procurement is used in the context of
pimping,<1> pandering and related conduct. (Pen. Code ��
266-266a.) A statute intended to punish purchasers of sex acts
that is phrased in terms of procuring prostitution is subject to
challenge as unconstitutionally vague, meaning an average person
cannot understand what the statute prohibits. (Lanzetta v. New
Jersey (1939) 306 U.S. 451, 453; People v. McCoy (2002) 27
Cal.4th 601, 634.)
To eliminate confusion and ambiguity in the statute amended by
this bill, the bill was recently amended to specifically and
separately define a crime committed by the person who purchased
or offered to purchase sex from a minor. The bill essentially
creates a felony for a person who affirmatively seeks commercial
sex from a minor. The amendments make the same changes to the
existing provisions authorizing a court to impose a $25,000
special fine on a person who offers to purchase or purchases a
commercial sex act from a minor.
However, as amended on April 9, 2014, the bill does not appear
to include circumstances where the defendant agreed to engage in
an act of prostitution, but did not make the initial
solicitations. Where a minor solicits the adult defendant, the
defendant would only be guilty of the crime defined by this bill
if he actually followed through and engaged in a lewd act with
the minor in exchange for money.
SHOULD THE BILL BE AMENDED TO INCLUDE CASES WHERE THE DEFENDANT
AGREED TO ENGAGE IN AN ACT OF PROSTITUTION WITH A MINOR, BUT DID
NOT MAKE THE INITIAL SOLICITATION?
3. No Requirement that the Defendant Knew or Should have Known
that the Person Solicited for Commercial Sex was a Minor
Scienter
This bill states that where the defendant is convicted engaging
in or offering to engage in an act of prostitution with a minor,
the defendant is guilty of an alternate felony-misdemeanor. The
---------------------------
<1> The statutory definition of pimping is deriving income from
the earnings of a prostitute. (Pen. Code � 266h.)
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crime is a straight felony in repeated convictions.
The bill does not appear to require that the defendant knew, or
should have known, that the prostitute involved in the incident
was a minor. A defendant who was not intending to purchase sex
specifically from a minor could engage with a 16 or 17-year-old
minor who appeared to be an adult. In such circumstances, a
defendant would not have intended to exploit minors or known
that he was exploiting a minor for sexual services.
The bill could be amended to include an element that the
defendant knew or should have known that the person with whom
the defendant engaged in or agreed to engage in an act of
prostitution was a minor, or that the defendant intended to
engage in an act of prostitution with a minor.
SHOULD THE BILL INCLUDE A REQUIREMENT THAT THE DEFENDANT KNEW OR
SHOULD HAVE KNOWN THAT THE OTHER PERSON INVOLVED IN A
PROSTITUTION OFFENSE WAS A MINOR?
Cases where the Adult Defendant Intended to Purchase Sex from a
Minor, but was Dealing with a Law Enforcement Decoy
The other circumstances left unaddressed by this bill is a case
where the defendant actually intended to purchase sex from a
minor, believed he solicited or agreed to pay for sex with a
minor, but did not do so. Defendants are often arrested in
prostitution offenses in law enforcement stings in which a law
enforcement officer poses as a prostitute. Where the defendant
clearly intended to purchase sex from a minor and believed he
was doing so, but was actually negotiating with a
young-appearing adult police decoy, he would not be guilty under
the provisions of this bill as drafted.
This issue would most often arise in prostitution sting cases
carried out through the Internet. Arguably, a man who regularly
uses the Internet to seek out juvenile prostitutes is much more
dangerous and culpable than a man who, perhaps on a single
occasion, drove through a stroll area and solicited or was
solicited by a young prostitute, especially where the prostitute
does not appear to be a minor.
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SHOULD THE BILL BE AMENDED TO APPLY TO CASES WHERE THE DEFENDANT
INTENDED TO PURCHASE SEX FROM A MINOR, BELIEVED HE WAS DEALING
WITH A MINOR, BUT ACTUALLY DEALT WITH A POLICE DECOY?
4. Soliciting an Act of Prostitution from a Minor or Engaging in
an Act of Prostitution with a Minor Constitutes an Attempted
or Completed Sex Crime
Minors cannot consent to sexual acts. Soliciting sexual
intercourse or other defined sex acts from a minor would
constitute attempted sex crimes.
Any sexually motivated touching of a child under the age of 14
years is a felony, punished by a prison term of three, six or
eight years. Sexually motivated touching of a minor who is 14
or 15 years old by a person at least 10 years older than the
minor is an alternate felony misdemeanor form of lewd conduct,
with a felony prison term of one, two or three years.<2> (Pen.
Code � 288, subd. (c).) Soliciting an act of prostitution from a
minor under the age of 16, as it includes the intent to engage
in sexual conduct and some act toward realizing that intent,
would generally constitute an attempt<3> to commit lewd conduct,
punished by a prison term of 18 months, three years or four
years. (Pen. Code � 288, subd. (b).)
In cases where a defendant's conduct in seeking out a juvenile
for prostitution constitutes a completed or and attempted sex
crime, the defendant could be convicted of both the attempted or
completed sex crime and a prostitution offense, although he
could not likely be punished for both crimes. A conviction for
both crimes would more accurately reflect the person's conduct
and criminal history.
WOULD AN AGREEMENT TO PURCHASE SEX FROM A MINOR, OR AN EXCHANGE
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<2> Generally, the prison "triad" is 16 months, two years or
three years, if a more specific penalty is not stated in the
governing statute.
<3> The punishment for an attempted crime, with certain specific
exceptions, is one-half the punishment for the completed crime.
(Pen. Code � 664.)
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OF MONEY OR OTHER THING OF VALUE FROM A MINOR, CONSTITUTE AN
ATTEMPTED OR COMPLETED SEX CRIME?
5. Studies and Profiles of Commercially Sexually Exploited Youth
Recent years have seen a great increase in concerns about minors
- generally girls - engaged in commercial sex activities.
Organized, coerced trafficking has received the most attention.
Sex trafficking has been described as sexual slavery.
Trafficked minors are isolated, controlled by and made dependent
on their exploiters, and can even be perversely loyal because of
the manufactured dependency.<4>
However, a 2008 study by the John Jay College of Criminal
Justice<5> and the Center for Court Innovation<6> found that
most of the minors engaging in commercial sex in New York City
are homeless or runaway minors who engage in "survival sex" to
obtain small amounts of money for food and other necessities.
Many of these CSEC - commercially sexually exploited children -
are gay, lesbian and transgender youth who left unsupportive
families and communities. The study authors were surprised to
find that most of CSEC were recruited or initiated into survival
sex by their peers, with no involvement by adult pimps. The
John Jay study reported that many CSEC were simply approached on
the street by would-be customers, without any solicitation by
the CSEC. Also surprising, there were as many male CSEC as
female in New York City.
Rachel Aviv's December 2012<7> profile of homeless young people
in the New Yorker magazine noted the results of the John Jay
study and then carefully documented the daily lives of a number
---------------------------
<4> Rachel Lloyd, Girls Like Us, pp.153-159, Harper Collins,
2011.)
<5> https://www.ncjrs.gov/pdffiles1/nij/grants/225083.pdf, pp.
48-49. 32-102.
<6> http://www.courtinnovation.org/ - The New York Court System
research agency, with national and international consulting
project.
<7>
http://www.newyorker.com/reporting/2012/12/10/121210fa_fact_aviv?
currentPage=all&pink=HhM7xT
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of homeless young people on the New York City streets. They
often form loose communities for support. They sometimes shared
repeat sex customers and money earned from commercial sex,
technically acting as pimps for each other. Adults who purchase
sex from CSEC are certainly aware that they are taking advantage
of these children. Some men use violence against the homeless
young people.
Aviv's profile documented that living on the streets and
engaging in survival sex is perilous. The rate of HIV among
homeless youth is triple that of the general population. Hunger
and illness are common and many show symptoms of psychiatric
disorders. And there is the prospect of becoming chronically or
permanently homeless. Aviv wrote: "Samantha and Ryan were
both terrified of becoming 'lifers.' They saw the signs in
their friends, who stopped trying to get job interviews, missed
appointments with caseworkers, and cycled in and out of
psychiatric hospitals or rehab centers, becoming accustomed to
people telling them what to do and when."
6. Girls Courts and other Programs for Minors Engaged in
Prostitution
The New Yorker profile noted above described a patchwork of
services that are not coordinated or comprehensive. As the CSEC
told Aviv, they are constantly in danger of becoming "lifers" on
the street, with the attendant harms of that life. The John Jay
study may not reflect the populations of CSEC in cities and
areas other than New York. However, the study does indicate
that relying on enforcement of laws against human trafficking
and pimping to address CSEC problems will still leave
substantial numbers of minors on the street and exploited for
sexual commerce.
Collaborative Courts
There has been a growing awareness of the value of special
juvenile courts for the girls found to be involved in commercial
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sex.<8> These courts have been implemented in Alameda County
and Los Angeles is expanding a pilot program. It has been
argued that treating juvenile prostitution as a crime problem
does little or nothing to address the underlying circumstances
that bring minors to engage in commercial sex.
Special collaborative courts can organize and monitor
supervision and treatment of CSEC girls. Special STAR
(Succeeding through Achievement and Resilience) courts have been
implemented in Los Angeles as a pilot project that is reportedly
being expanded.<9> Alameda County has established an extensive
Girls Court. New York has created a network of 11 Human
Trafficking Intervention Courts for juveniles who are at least
16 years old.<10>
It appears that collaborative courts for minors caught up in
sexual commerce have focused almost exclusively on girls.
However, the John Jay study and the New Yorker investigative
article indicate that there are a substantial number of boys and
transgender youth who are CSEC.
Arguably, collaborative courts should be organized or designed
to handle whatever populations of CSEC are present in the
community of the court or courts.
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<8>
http://www.nytimes.com/2014/01/29/us/a-courts-all-hands-approach-
aids-girls-most-at-risk.html?_r=0
<9> http://file.lacounty.gov/bos/supdocs/70403.pdf
<10>
http://www.nytimes.com/2014/01/29/us/a-courts-all-hands-approach-
aids-girls-most-at-risk.html?_r=0
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Comprehensive Programs for Commercially Sexually Exploited Youth
The Center for Court Innovation participated in a project and
study for addressing and ameliorating the problems of homeless
and exploited youth. The project encountered setbacks and
limitations and identified effective strategies.<11>
Effective strategies were identified and implemented:
o Consistent, coordinated and adequately funded
prosecution strategies targeting exploiters;
o Comprehensive and coordinated and funded
programs for CSEC, especially housing and appropriate
counseling and intervention; and,
o Sustained prevention programs, including a
need for research on effective programs.
Setbacks and limitations:
o inconsistent leadership;
o insufficient data; and,
o outside pressures pulling participating
agencies away.
***************
---------------------------
<11>
http://www.courtinnovation.org/sites/default/files/CSEC_NYC_Volum
e2.pdf