BILL ANALYSIS                                                                                                                                                                                                    �







                      SENATE COMMITTEE ON PUBLIC SAFETY
                            Senator Loni Hancock, Chair              S
                             2013-2014 Regular Session               B

                                                                     1
                                                                     2
                                                                     5
          SB 1255 (Cannella)                                         5
          As Introduced February 20, 2014 
          Hearing date:  April 29, 2014
          Penal Code
          JM:mc

                             VIOLATION OF PRIVACY RIGHTS:

                  POSTING SEXUAL IMAGES  OF ANOTHER WITHOUT CONSENT  


                                       HISTORY

          Source:  Author

          Prior Legislation: SB 255 (Cannella) - Ch. 466, Stats. 2013
                       AB 665 (Torres) - Ch. 658, Stats. 2011
                       AB 182 (Ackerman) - Ch. 231, Stats. 1999

          Support: California State Sheriffs' Association; Crime Victims  
                   United of California; California Police Chiefs  
                   Association; California Partnership to End Domestic  
                   Violence

          Opposition:American Civil Liberties Union


                                        KEY ISSUES
           
          SHOULD DISTRIBUTION WITHOUT CONSENT OF AN IMAGE OF AN INTIMATE BODY  
          PART OR SEXUAL ACT OF ANOTHER IDENTIFIABLE PERSON BE A MISDEMEANOR?

          SHOULD STATUTES INVOLVING SEARCH WARRANTS, FORFEITURE AND  




                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageB

          DETERMINATION OF THE PLACE OF TRIAL FOR A CRIME COMMITTED IN  
          MULTIPLE JURISDICTIONS BE APPLIED TO UNAUTHORIZED DISTRIBUTION OF AN  
          INTIMATE IMAGE?


                                       PURPOSE

          The purpose of this bill is to 1) provide that the distribution  
          of an image of another, identifiable person's intimate body  
          part, or an image of the person engaged in a sexual act, without  
          consent of the person depicted, is a misdemeanor; 2) provide for  
          confiscation of the offending image or similar images; 3)  
          provide for forfeiture of electronic devices used to commit the  
          crime; 4) authorize search warrants for evidence of the crime;  
          and 5 ) apply the procedures for determining venue for a  
          multiple county identity theft crime to cases where the  
          unauthorized distribution of an intimate image involved acts  
          occurring in different counties. 
          
           Existing law  includes the crime of making a credible threat of  
          death or great bodily injury, which includes the following  
          elements: The defendant made the threat "verbally," in writing  
          or by means of an electronic communication device and with the  
          intent that it be taken as a threat; and it appears that that  
          the defendant had the means and intent to carry out the threat  
          such that the victim was placed in sustained fear for his own  
          safety or that of his immediate family.  This crime is an  
          alternate felony-misdemeanor, punishable by a jail term of up to  
          one year, a fine of up to $1000, or both, or by imprisonment in  
          a state prison for 16 months, 2 years or 3 years and a fine of  
          up to $10,000.  (Pen. Code � 422.)

           Existing law  defines the crime of "stalking" as repeatedly  
          harassing or following another person in conjunction with the  
          making of a credible threat against that person or his or her  
          immediate family.  Stalking is an alternate felony-misdemeanor  
          punishable by up to one year in the county jail and/or a fine of  
          up to $1000, or by imprisonment in state prison for 16 months, 2  
          or 3 years, and/or a fine of up to $10,000.  (Pen. Code �  
          646.9.)




                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageC

           
          Existing law  provides that every person who, with intent to  
          annoy, telephones or makes contact by means of an electronic  
          communication device with another and addresses to or about the  
          other person any obscene language, or addresses to the other  
          person any threat to inflict injury to the person or property of  
          the person addressed or any member of his or her family is  
          guilty of a misdemeanor.  The statute does not apply to  
          communication made in good faith.  (Pen. Code 
          � 653m, subd. (a).)

           Existing law  provides that every person who makes repeated  
          telephone calls or makes repeated contacts by means of an  
          electronic communication device with intent to annoy another  
          person at his or her residence is guilty of a misdemeanor.  The  
          crime does not include an element that a conversation took place  
          in the telephone call or electronic contact. The statute does  
          not apply to communication made in good faith.  (Pen. Code �  
          653m, subd. (b).)
           
          Existing law  provides that every person who makes repeated  
          telephone calls or makes repeated contact by means of an  
          electronic communication device with the intent to annoy another  
          person at his or her place of work is guilty of a misdemeanor  
          punishable by a fine of not more than $1000, by imprisonment in  
          a county jail for not more than one year, or by both that fine  
          and imprisonment.  Nothing in this subdivision shall apply to  
          telephone calls or electronic contacts made in good faith.  This  
          subdivision applies only if one or both of the following  
          circumstances exist:

                 There is a temporary restraining order, an injunction,  
               or any other court order, or any combination of these court  
               orders in effect prohibiting the behavior described in this  
               section.
                 The person makes repeated telephone calls or contact by  
               means of an electronic communication device with the intent  
               to annoy another person at his or her place of work,  
               totaling more than 10 times in a 24-hour period, whether or  
               not conversation ensues from the call or contact, and the  




                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageD

               calls or contacts are made to the workplace of an adult or  
               emancipated minor who is a spouse, former spouse,  
               cohabitant, former cohabitant, or person with whom the  
               person has a child or has had, or is having, a dating or  
               engagement relationship.  (Pen. Code � 653m, subd. (c).)

           Existing law  provides that a court may issue an ex parte order  
          enjoining a party from molesting, attacking, striking, stalking,  
          threatening, sexually assaulting, battering, harassing,  
          telephoning, destroying, contacting, coming within a specified  
          distance of, or disturbing the peace of the other party.  Upon a  
          showing of good cause, the order may cover another named family  
          or household members.  (Fam. Code � 6320.)  Any willful  
          violation of such an order is contempt of court, a misdemeanor,  
          with a maximum jail term of one year, a fine of up to $1000, or  
          both.  (Pen. Code 
          � 166, subd. (c).)

           Existing law  provides that any person who willfully disobeys any  
          court order is guilty of contempt of court, a misdemeanor,  
          punishable by up to six months in the county jail, a fine of up  
          to $1000, or both.  (Pen. Code � 16, subd. (a)(4).)
           
          Existing law  provides that every person who, with intent to  
          place another person in reasonable fear for his or her safety,  
          or the safety of the other person's immediate family, by means  
          of an electronic communication device, and without consent of  
          the other person, and for the purpose of causing that other  
          person unwanted physical contact, injury, or harassment, by a  
          third party, electronically distributes, publishes, e-mails,  
          hyperlinks, or makes available for downloading, personal  
          identifying information, including, but not limited to, a  
          digital image of another person, or an electronic message of a  
          harassing nature about another person, is guilty of a  
          misdemeanor punishable by up to one year in the county jail, by  
          a fine of not more than one thousand dollars ($1000), or by both  
          that fine and imprisonment.  (Pen. Code � 653.2, subd. (a).)

           Existing law  defines the term "electronic communication device"  
          to include, but not be limited to telephones, cellular phones,  




                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageE

          computers, Internet Web pages or sites, Internet phones, hybrid  
          cellular/Internet/wireless devices, personal digital assistants  
          (PDA), video recorders, fax machines, or pagers.  "Electronic  
          communication" has the same meaning as the term is defined in  
          Section 2510 (12) of Title 18 of the United States Code.  (Pen.  
          Code � 653.2, subd.  (b).)

           Existing law  provides that a person who has "suffered  
          harassment" may seek a temporary restraining order and an  
          injunction to prevent such harassment.  "Harassment" is defined  
          thus:  
               [U]nlawful violence, a credible threat of violence, or  
               a knowing and willful course of conduct directed at a  
               specific person that seriously alarms, annoys, or  
               harasses the person, and that serves no legitimate  
               purpose.  The course of conduct must be such as would  
               cause a reasonable person to suffer substantial  
               emotional distress, and must actually cause  
               substantial emotional distress to the plaintiff.   
               (Code. Civ. Proc. � 527.6.)

          Production, Distribution and Possession of Child Pornography and  
          Obscene Material
           
          Existing law  provides that every person who sends, brings,  
          possesses, prepares, publishes, produces, duplicates or prints  
          any obscene matter depicting a person under the age of l8 years  
          engaging in or simulating sexual conduct, with the intent to  
          distribute, exhibit, or exchange such material, is guilty of  
          either a misdemeanor or a felony, punishable by imprisonment in  
          the county jail up to one year or in the state prison for 16  
          months, 2 or 3 years and a fine not to exceed $10,000.  (Pen.  
          Code � 311.1.)

           Existing law  specifies that every person who sends, brings,  
          possesses, prepares, publishes, produces, duplicates or prints  
          any obscene matter depicting a person under the age of l8 years  
          engaging in or simulating sexual conduct for commercial purposes  
          is guilty of a felony, punishable by imprisonment in the state  
          prison for two, three, or six years and a fine up to $100,000.   




                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageF

          (Pen. Code � 311.2, subd. (b).)

           Existing law  provides that any person who hires or uses a minor  
          to assist in the preparation or distribution of obscene matter  
          is guilty of a misdemeanor.  If the person has a prior  
          conviction, the crime is a felony.  (Pen. Code � 311.4, subd.  
          (a).)

           Existing law  provides that any person who hires or uses a minor  
          to assist in the possession, preparation or distribution of  
          obscene matter for commercial purposes is guilty of a felony,  
          punishable by imprisonment in the state prison for three, six,  
          or eight years.  (Pen. Code � 311.4, subd. (b).)

           Existing law  authorizes issuance of a search warrant in  
          specified circumstances, usually involving evidence of a felony.  
           (Pen. Code � 1524.)

           This bill  provides that "any person who intentionally  
          distributes by any means the image of another identifiable  
          person, whose intimate body part or parts are either uncovered  
          or visible through less than fully opaque clothing or who is  
          engaged in a sexual act, without the consent of the [person]  
          depicted" is guilty of a misdemeanor, punishable by imprisonment  
          in a county jail for up to six months, a fine of up to $1,000,  
          or both.

                 This bill includes the following relevant definitions:

                  o         "Intimate body part" means any portion of the  
                    genitals, and in the case of a female, any portion of  
                    the breasts below the top of the areola.
                  o         "Sexual act" means sexual intercourse,  
                    including genital, anal, or oral sex, or physical  
                    contact with another person's intimate body part or  
                    parts

                 The following conduct does not constitute commission of  
               this crime:





                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageG

                  o         Distribution made in the course of reporting  
                    an unlawful activity.
                  o         Distribution "made in compliance with a  
                    subpoena or other court order for use in a legal  
                    proceeding."  
                  o         Distribution of an image captured in a public  
                    or commercial setting where the person depicted  
                    voluntarily exposed his or her intimate body part or  
                    parts or voluntarily engaged in a sexual act.
                  o         Distribution made in the course of a lawful  
                    public proceeding.  

           This bill  provides that the proper jurisdiction or venue -  
          county of trial - for prosecution of this offense includes the  
          following counties:

                 The county "in which the offense occurred,"
                 The county in which the victim resided "at the time the  
               offense was committed," or 
                 The county in which the "intimate image was used for an  
               illegal purpose."

           This bill  provides that where multiple offenses of unauthorized  
          distribution of an intimate image, involving the same defendant  
          or defendants and the same intimate image "belonging to the one  
          person," or involving the same defendant or defendants in one  
          scheme or "substantially similar activity" occur in multiple  
          jurisdictions, any of those jurisdictions is a proper  
          jurisdiction for all of the offenses.  

           This bill  provides that where a charge of unauthorized  
          distribution of an intimate image occurring in multiple  
          jurisdictions is filed in one county, the court shall hold a  
          hearing to determine in which county the case should proceed, or  
          where one or more counts should be severed and tried in another  
          jurisdiction.  The district attorney in the county of filing  
          shall present that the district attorney in each county where  
          the case could be tried has agreed that the case should proceed  
          in the county of filing.





                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageH

           This bill  provides that where the action is filed in the county  
          of the victim's residence and there is no other basis for filing  
          in that jurisdiction, the court shall determine whether that  
          county, and not the county where the crime occurred or the image  
          was used for an illegal purpose, is the proper place for trial.   
          The court shall consider the rights of the parties, the access  
          of the parties to evidence, witness convenience and the  
          interests of justice.

           This bill  provides that an image distributed so as to violate  
          the ban on nonconsensual distribution of intimate body parts or  
          sexual activity shall be subject to court-ordered forfeiture and  
          destruction.


           This bill  provides that a computer or telecommunications device  
          used in the crime of nonconsensual distribution of an image of  
          an intimate body part or sexual conduct is subject to  
          forfeiture.  The property shall be given to the holder of a  
          security interest, to the victim for restitution and  
          "compensatory damages," to the prosecuting agency, specified  
          governmental entities or charitable organizations.  The property  
          may be sold and the proceeds distributed in a manner similar or  
          equivalent to distribution of the actual property.

           This bill  authorizes issuance of a warrant for any item that  
          tends to show that non-consensual distribution of another  
          person's intimate body part or sexual activity has occurred or  
          is occurring.


                    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.   




                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageI


          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  
          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  




                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageJ

          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  
          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  




                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageK

               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.






                                      COMMENTS

          1.  Need for This Bill  

          According to the author:

               The distribution of a sexually explicit image an  
               individual has taken of another, identifiable person  
               while in a private setting without the subject's  
               consent is prohibited under current law.  However, it  
               is silent as to images a person may have taken of  
               themselves and which were subsequently distributed by  
               others without his or her consent.  

               Current law also requires that the victim must suffer  
                                                                    serious emotional distress for the statute to be  
               enforceable.  An unintended side effect of this  
               provision, victims have been reluctant to come forward  
               since they fear the embarrassment that may follow  
               testifying against their offender and making their  
               identities public in a criminal court setting.





                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageL

          2.  Vagueness and Related Issues   

          Vagueness and Overbreadth Generally 
          
          Both the United States and California Constitutions guarantee  
          that no person shall be deprived of life, liberty, or property  
          without due process of law.  Due process requires "a reasonable  
          degree of certainty in legislation, especially in the criminal  
          law ?"  (In re Newbern (1960) 53 Cal.2d  
          786, 792.)  "[A] penal statute must define the criminal offense  
          with sufficient definiteness that ordinary people can understand  
          what conduct is prohibited and in a manner that does not  
          encourage arbitrary and discriminatory enforcement."  (Kolender  
          v. Lawson (1983) 461 U.S. 352, 357.)  A statute is overbroad  
          where it defines innocuous or innocent activity as criminal.    
          "The overbreadth doctrine provides that a governmental purpose  
          to control or prevent activities constitutionally subject to  
          state regulation may not be achieved by means which sweep  
          unnecessarily broadly and thereby invade the area of protected  
          freedoms." (Williams v. Garcetti (1993) 5 Cal.4th 561, 577,  
          citation and internal quotation marks omitted.)

          Many of the terms and provisions in this bill defining the new  
          or expanded crime of unauthorized distribution of an intimate  
          image could be challenged as vague and overbroad.  Overall, it  
          appears that defining the offense largely by the nature of the  
          image - rather than the protected interest distribution the  
          image violates - is particularly problematic.  Specific examples  
          of terms that could be challenged as vague or overbroad follow:

          "Not Fully Opaque Clothing"
          
          This bill, and existing law, make it a misdemeanor to, without  
          consent of the person depicted, electronically distribute an  
          image of another person's intimate body part - including where  
          the body part is covered by "less than fully opaque clothing."   
          Neither existing law nor the bill provides guidance or certainty  
          to determine what constitutes "less than fully opaque clothing."  
           The term appears to have no special meaning in the law, and  
          thus the term would be given its ordinary, dictionary meaning of  




                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageM

          "impenetrable to light" or "not translucent."<1>  As using the  
          term not translucent would result in a confusing double  
          negative, the likely meaning would be anything not fully  
          impenetrable to light.  Very many items of commonly worn women's  
          clothing are not fully impenetrable to light.  Few fabrics -  
          blackout curtains for example - are fully impenetrable to light.  
           The less than fully opaque nature of clothing might not be  
          apparent until the person steps out into sunlight, or could  
          depend on the angle and source of ambient light.  The term could  
          thus be challenged as vague and overbroad.

          IS THE TERM "LESS THAN FULLY OPAQUE CLOTHING" VAGUE AND OVERLY  
          BROAD?

          Application of the Defense that the Depicted Person "Voluntarily  
          Exposed" an Intimate Body Part or Engaged in a Sexual Act in a  
          Public or Commercial Setting 
          
          This bill provides that the crime at issue is not committed if  
          the defendant distributed an image in which the person depicted  
          voluntarily, in a public or commercial setting, exposed an  
          intimate body part or engaged in a sexual act.  This concept  
          could also be challenged as vague and overbroad.  Does the  
          person have to specifically intend to expose an intimate body  
          part?  Does a person voluntarily expose an intimate body part  
          where she or he consciously does an act during which the body  
          part is exposed?  How does someone "involuntarily" engage in a  
          sex act in a public place?

          A more basic question is what constitutes a public place?  For  
          example if a couple finds a place in Capitol Park that appears  
          to be hidden from view, but another person surreptitiously  
          follows the couple, and the couple engages in sexual activity,  
          would distribution of an image of the conduct not violate the  
          crime defined by this bill?  

          This provision raises other questions and produces other  
          anomalous results.  For example, what is a commercial setting?   

          ---------------------------
          <1> http://www.merriam-webster.com/dictionary/opaque,  
          http://dictionary.reference.com/browse/opaque.



                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageN

          If a woman had boudoir photos taken to give to her husband or  
          boyfriend, or to preserve a record of her appearance, is that a  
          commercial setting or image, such that any distribution of those  
          images would not be covered by this bill?

          Application of the Term "Sexual Act"

          The bill provides that a "[s]exual act means sexual intercourse,  
          including genital, anal or oral sex, or physical contact with  
          another person's intimate body part or parts."  This definition  
          may be difficult to comprehend and apply.  It appears to use  
          "intercourse" as a very general term, not consistent with other  
          criminal law provisions.  Sexual intercourse in other provisions  
          of law means penetration of a woman's vagina by a man's penis.   
          It would not generally be interpreted as meaning "genital, anal  
          or oral sex."  The terms "genital, anal or oral sex" are  
          colloquial, vague and otherwise not found in statute.   
          California law refers to sodomy as the copulation of the anus of  
          one person by the penis of another and "oral copulation" as the  
          copulation of the mouth of one person with the genitals or anus  
          of another.

          Further, it may not be adequately clear what constitutes  
          "physical contact with another person's intimate body part or  
          parts."  Does this mean contact with bare skin?  The phrase  
          could conceivably include physical contact with a woman's  
          breasts through a hug.  It could include a photo of person  
          getting hit or kicked in the groin.

          IS THE TERM "SEXUAL ACT" IN THIS BILL VAGUE OR AMBIGUOUS?

          3.  Forfeiture Provision is Overly Broad  

          The bill provides that an "image described" in the crime defined  
          by this bill is subject to forfeiture.  The image described in  
          the crime provision is that of an intimate body part or sexual  
          act.  However, the crime involves distributing the image without  
          consent.  An image of an intimate body part of sexual act is not  
          illegal or contraband, per se.  In contrast, the child  
          pornography images covered by the forfeiture provision in  




                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageO

          existing law are illegal per se.  No one has a right to possess  
          an image of children engaged in sexual conduct, regardless of  
          whether he is convicted of a child pornography crime or not.   
          The forfeiture provision in this bill would allow prosecutors to  
          require a defendant to forfeit an image he had a legal right to  
          possess.  It would appear that to be valid, the forfeiture  
          provision would need to apply to an image that was illegally  
          distributed within the meaning of the crime at issue.
          
          4.  The Bill does not include an Element that the Person Depicted  
            Suffer any Harm or Misfortune  

          Issue of Harm to the Victim Generally

          A crime includes mens rea - a wrongful intent or state of mind -  
          and an actus reus - a wrongful act.<2> The crime defined in this  
          bill essentially requires little or no wrongful intent or  
          knowledge.  Nor does it include a showing of harm to a victim.   
          The essence of the crime is distribution of sexually themed  
          images without consent.  It thus appears the harm caused by the  
          offense is either the sexual nature of the image, per se, or the  
          distribution of the image without consent.

          The use or control of an object without consent - in contrast  
          with some contact with the body of the victim - appears to  
          involve a property right of some kind - including, perhaps, an  
          intellectual property interest such as copyright.  That is,  
          nature of the image is not harmful, but distribution harms the  
          victim's right to control use or distribution of the image.

          Efforts to Obviate Testimony by or Identification of the Victim
          
          From discussions with the author's office, it appears that an  
          ---------------------------
          <2> Generally speaking, in most crimes, the harm is to an  
          individual victim, although a person is subject to criminal  
          punishment because an intentional or knowing harm against one  
          person is a moral violation against the people of a state.  The  
          causing of financial or physical harm to another is also the  
          basis for a private, civil action by a plaintiff to obtain  
          individual compensation from the defendant who caused the harm.



                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageP

          element of harm to the person depicted was excluded in an  
          attempt to avoid the need to have the victim testify.  That goal  
          would be very difficult to achieve.  The lack of consent to  
          distribution and an agreement that the image shall remain  
          private are elements of the crime that must be established  
          beyond a reasonable doubt in open court.  (In re Winship (1970)  
          397 U.S. 358.)<3>  A defendant has a 6th Amendment right to  
          confront the witnesses who would establish that the image was  
          distributed without consent, despite an agreement or  
          understanding that the image remain private.  If the prosecutor  
          tried to establish lack of consent by a statement made by the  
          victim to a police officer or any other person, that statement  
          is inadmissible hearsay.  If consent were somehow made an  
          affirmative defense, the defendant would call the victim as a  
          witness to establish the consent.

           5.  Comparison with Strict Liability Crimes  

          As the crime defined in the bill does not include an element of  
          wrongful intent or knowledge, the crime is similar to a strict  
          liability crime.  (In re Jennings (2004) 34 Cal.4th 254.)   
          Strict liability crimes typically concern health and welfare  
          matters - contaminated food for example.  Because strict  
          liability crimes include no element of intent, knowledge or even  
          criminal negligence, strict liability crimes are typically no  
          more than misdemeanors, often with relatively small fines and no  
          jail time.  Strict liability crimes are said to be strictly  
          regulatory, and should not even damage the defendant's  
          reputation.  (In re Jennings, supra, 34 Cal.4th at pp. 266-269.)  
            

          6.  First Amendment Issues  

          Content Based Restrictions
          
          If the harm in this crime is to society from the distribution of  
          sexual or sexually themed images, that raises significant First  
          Amendment issues.  As such, the bill criminalizes a form of  

          ---------------------------
          <3> Each element of a crime must be proved beyond a reasonable  
          doubt, or the defendant must be acquitted.



                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageQ

          expression, which is included within the definition of speech.   
          (Texas v. Johnson (1989) 491 U.S. 397.)  "If there is a bedrock  
          principle underlying the First Amendment, it is that the  
          government may not prohibit the expression of an idea simply  
          because society finds the idea itself offensive or  
          disagreeable."  (Id, at p. 414.)

          Unless a particularly narrow exception applies, protection of  
          expression under the First Amendment is not limited to certain  
          subjects or ideas.  A restriction on the "content" of  
          expression, as distinguished from the time, place and manner of  
          expressions is presumptively invalid.  A content-based  
          restriction on expressive conduct is subject to "strict  
          scrutiny" and must promote a "compelling state interest" by the  
          "least restrictive means" to achieve the compelling interest.   
          (Sable Communications v. FCC (1989) 492 U.S. 115, 126.)  

          A content-based restriction on expression will be struck down as  
          invalid on its face if it prohibits clearly protected speech, in  
          addition to conduct that may validly be prohibited.  Such a law  
          is said to be unconstitutionally "overbroad."  (U.S. v. Stevens  
          (2010) 130 S.Ct. 1577, 1587.)  Stevens struck down a federal  
          statute that criminalized the sale or possession of "depictions  
          of animal cruelty," in order to prohibit fetishistic "crush  
          videos" of the killing of animals for sexual gratification.  The  
          Supreme Court found that the statute was overbroad in that it  
          might reach videos depicting hunting, arguably inhumane  
          treatment of livestock, or activities legal in some  
          jurisdictions but not others, such as cockfighting.  (Id, at pp.  
          1588-1592.)   

          Nevertheless, some kinds of speech are not protected.  These  
          include true threats and obscenity.  However, in light of the  
          United States Supreme Court's decisions in cases involving  
          freedom of sexual speech on the Internet (Reno v. ACLU (1997)  
          521 U.S. 844) and the infamous crush videos obscenity case noted  
          above, it is highly unlikely that the Supreme Court would find  
          images depicting sexual acts and intimate body parts of adults  
          to be obscene.





                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageR

          Some hybrid theory or principle establishing that prohibition of  
          non-consensual distribution of otherwise protected speech does  
          not violate the First Amendment would appear to be quite novel.   
          Full examination of the issues raised by such a theory would  
          require a great deal of study, research and debate, well beyond  
          that normally allotted to committee analysis of a bill.  

          Finally, the First Amendment most strongly prohibits laws that  
          limit or burden political speech.  (Burson v. Freeman (1992) 504  
          U.S. 191; Perry Ed. Assn. v. Perry Local Educators' Assn. (1983)  
          460 U.S. 37, 45.)  It appears that non-consensual distribution  
          of sexual images generally does not involve political speech.   
          However, there are very notable exceptions.  The widely  
          distributed naked images of Anthony Weiner were largely  
          political speech, in the sense that the images supported  
          arguments that Weiner lacked good judgment and lacked veracity,  
          as he had denied taking and sending the images.  However,  
          non-consensual distribution of naked images of Mr. Weiner would  
          appear to violate the crime defined in this bill.  False  
          identities were used by activists to target Weiner.<4>  Any  
          person prosecuted for such a crime would certainly mount a First  
          Amendment defense.  The issues at play in such a case would be  
          complex. The courts could find that the First Amendment rights  
          of a person distributing such photos of a politician would  
          outweigh any expectation of privacy a politician would have as  
          to images shared with a person who is not a family member or  
          long-time associate.

          Contrast with Violation of Privacy Rights
          
          It does appear that non-consensual distribution of intimate  
          images can be prohibited or punished if that conduct violates  
          the constitutionally protected image of privacy.  The California  
          Constitution (Art. I, �1) includes a specific right to privacy.   
          The United States Constitution includes an implicit right to  
          privacy in the penumbra of the explicit Bill of Rights.   
          ---------------------------
          <4>  
          http://www.nytimes.com/2011/06/18/nyregion/fake-identities-were-u 
          sed-on-twitter-to-get-information-on-weiner.html?ref=anthonydwein 
          er&_r=0.



                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageS

          (Griswold v. Connecticut (1965) 381 U.S. 479.)  Reliance on the  
          right of a person to enforce an agreement or understanding that  
          an intimate image remain private and not distributed would avoid  
          a host of constitutional and statutory construction issues  
          discussed above.







































                                                                     (More)











          7.  Search Warrant Issues  

          This bill authorizes issuance of a search warrant to obtain  
          evidence of non-consensual distribution of an intimate image.   
          Most warrants are issued for the seizure of evidence of a  
          felony.  The warrant provision in this bill raises the issue of  
          whether the interest in prosecuting people for distribution of  
          sexual images is comparable to the interest in prosecuting  
          felons.  Another critical issue is whether evidence of this  
          crime would be reasonably available without a search warrant. 

          8.   Forfeiture and Confiscation Issues  

          This bill authorizes forfeiture of equipment and property used  
          in non-consensual distribution of intimate images.  The bill  
          also authorizes confiscation of offending images.  How could one  
          determine if all of the images have been confiscated?  One of  
          the major harms of cyber revenge is that the image is  
          uncontrollable. 

          In practice, computer forfeiture is an additional punishment,  
          not prevention of a future crime.  The convicted defendant could  
          easily obtain another computer.

          It appears that better results would flow from putting the  
          defendant on probation with the condition that he destroy all  
          images used in the crime and that he not obtain others.  He  
          could be monitored on probation and his probation revoked if he  
          violated probation conditions.

          COULD A DEFENDANT PLACED ON PROBATION BE MONITORED TO ENSURE  
          COMPLIANCE WITH ORDERS THAT HE DESTROY IMPROPERLY DISTRIBUTED  
          IMAGES AND THAT HE NOT USE ELECTRONIC EQUIPMENT IMROPERLY?

          9.  Suggested Amendments to Address the Issues Raised by this Bill  

          The following amendments would appear to define a crime that is  
          validly based on protection of a right to privacy under  
          California law, as opposed to an example of non-protected  




                                                                     (More)







                                                         SB 1255 (Cannella)
                                                                      PageU

          speech.  Further, it appears to avoid many issues of vagueness  
          and overbreadth.  The author's office has indicated the author  
          would accept the amendments:


               (4) (A) Any person who intentionally distributes the  
               image of the intimate body part or parts of another  
               identifiable person, under circumstances where the  
               persons agree or understand that the image shall  
               remain private, and where the person distributing the  
               image knows or should know that distribution of the  
               image will cause serious emotional distress, and where  
               the person depicted suffers such distress.  

               (B)  A person intentionally distributes an image where  
               he or she personally distributes the image, or  
               arranges, specifically requests, or intentionally  
               causes another person to distribute the image.

               (C) As used in this paragraph, intimate body part  
               means any portion of the genitals, the anus, and in  
               the case of a female, also includes any portion of the  
               breasts below the top of the areola, that is either  
               uncovered or clearly visible through clothing.

               (D) Nothing in this subdivision precludes punishment  
               under any section of law providing for greater  
               punishment.

               (E) Where any person is granted probation for a  
               conviction under this subdivision, it shall be a  
               condition of probation that the person destroy any  
               physical image and permanently delete any digital  
               image involved in the offense or that could be the  
               basis of a prosecution under this subdivision if  
               distributed.  

               (F)  The court may impose any reasonable condition of  
               probation limiting or restricting the person's use of  
               any device for the creation, storage or distribution  












                                                         SB 1255 (Cannella)
                                                                      PageV

               of digital images.


          SHOULD THESE AMENDMENTS BE ADOPTED?