BILL ANALYSIS SB 277 Page 1 Date of Hearing: June 28, 2005 Counsel: Kathleen Ragan ASSEMBLY COMMITTEE ON PUBLIC SAFETY Mark Leno, Chair SB 277 (Battin) - As Amended: June 13, 2005 FOR VOTE ONLY SUMMARY : Prohibits the placement of any parolee who upon release must register as a sex offender, within one and one-half miles of any public park, day care, preschool, or public or private school, including Kindergarten and Grades 1 through 12 inclusive. Specifically, this bill : 1)Prohibits the California Department of Corrections (CDC) from placing persons released on parole and who must register as sex offenders within one and one-half miles of any pubic park, day care, preschool, or public or private school, including any or all of Kindergarten and Grades 1 to 12, inclusive. 2)Prohibits an inmate released on parole who must register as a sex offender from residing, for the duration of his or her parole, within one and one-half miles of any pubic park, day care, preschool, or public or private school, including any or all of Kindergarten and Grades 1 to 12, inclusive. 3)Requires CDC to notify by mail, at least 60 days prior to the scheduled release date from prison of an inmate required to register as a sex offender, the sheriff or chief of police, or both in the community in which the person was convicted. 4)Requires CDC to notify by mail, at least 60 days prior to the scheduled release date from prison of an inmate required to register as a sex offender, the sheriff or chief of police, or both in the community in which the person is scheduled to be released on parole, or released following a period of confinement pursuant to a parole revocation without a new commitment. EXISTING LAW : SB 277 Page 2 1)States that except as otherwise provided, an inmate who is released on parole shall be returned to the county that was the last legal residence of the inmate prior to his or her incarceration. [Penal Code Section 3003(a).] 2)States that an inmate who is released on parole for any violation of child molestation or continuous sexual abuse of a child shall not be placed or reside, for the duration of his or her period of parole, within one-quarter mile of any public or private school including any or all of Kindergarten and Grades 1 to 8, inclusive. [Penal Code Section 3003(g).] 3)States that "last legal residence" shall not be construed to mean the county wherein the inmate committed an offense while confined in a state prison or local jail facility, or while confined for treatment in a state hospital. [Penal Code Section 3003(a).] 4)Provides that an inmate may be returned to a county other than that of his or her last legal residence if that would be in the best interests of the public. [Penal Code Section 3003(b).] 5)States that if the inmate is released on parole to another county, the paroling authority shall place its reasons in writing and include these reasons in the required notice to the sheriff or chief of police of that county, as specified. [Penal Code Sections 3003(b) and 3058.6.] 6)Sets forth the factors the paroling authority shall consider in making its placement decision, and states that the greatest weight to the protection of the victim and the safety of the community. These factors include: a) The need to protect the life or safety of a victim, the parolee, a witness or any other person; b) Public concern that would reduce the chance that the inmate's parole would be successfully completed; c) The verified existence of a work offer or an educational or vocational training program; d) The existence of family in another county with whom the SB 277 Page 3 inmate has maintained strong ties and whose support would increase the chance that the inmate's parole would be successfully completed; and, e) The lack of necessary outpatient treatment programs for parolees receiving specified treatment. 7)Provides that the CDC, in determining an out of county placement, shall give priority to the safety of the community and any witnesses and victims. [Penal Code Section 3003(c).] 8)States that specified identifying information shall be provided by CDC to local law enforcement agencies regarding a paroled inmate who is released into their jurisdictions. [Penal Code Section 3003(e).] 9)Provides that an inmate released on parole shall not be returned to a location within 35 miles of the actual residence of the victim of, or a witness to, a violent felony, as defined. [Penal Code Section 3003(f).] 10)Requires the paroling authority to give consideration to the equitable distribution of parolees and the proportion of out-of-county commitments from a county compared to the number of commitments from that county when making parole decisions. [Penal Code Section 3003(i).] 11)Allows an inmate to be paroled to another state pursuant to any other law. [Penal Code Section 3003(j).] 12)Prohibits parolees who are required to register as sex offenders from residing, during the period of parole, in any single-family dwelling with any other person required to register as a sex offender unless those persons are related by blood, marriage, or adoption. States that a "single family dwelling" does not include a residential facility that serves six or fewer persons. (Penal Code Section 3003.5.) 13)Provides that parolees deemed to pose a high risk to the public of committing violent sex crimes shall be placed on intensive and specialized parole supervision caseload. [Penal Code Section 3005(a).] 14)States that subject to the appropriation of funds, the CDC may implement a plan of relapse prevention treatment to reduce SB 277 Page 4 the recidivism of high-risk sex offenders and study the effects on recidivism, with a final report due to the Legislature by January 1, 2006. Further provides that this section shall remain in effect only until July 1, 2006 unless a later enacted statute is enacted before July 1, 2006 that deletes or extends that date. [Penal Code Section 3005(b).] 15)Requires the CDC to provide specified information to local law enforcement 15 days before the scheduled release date of a person required to register as a sex offender, and to notify local law enforcement within 36 hours of learning of any changes to the scheduled release date or any of the information required to be provided. (Penal Code Section 290.6.) 16)Establishes a three-tiered Internet Web site to notify the public of specified information regarding certain registered sex offenders. (Penal Code Section 290.46.) 17)Provides that the Internet Web site include the specific home addresses for specified registered sex offenders. [Penal Code Section 290.46(b).] 18)Provides that the Internet Web site include the community of residence and zip code, rather than specific residence addresses, for other specified sex offenders. [Penal Code Section 290.46(c).] 19)Allows a law enforcement agency to provide specified information about registered sex offenders as necessary to protect the public, to specified public and private institutions and other community members at risk. [Penal Code Section 290.45(a)(1).] 20)Provides that prisoners on parole are under the legal custody of the CDC and are subject at any time to be taken back within the enclosure of the prison. (Penal Code Section 3056.) FISCAL EFFECT : Unknown COMMENTS : 1)Author's Statement : According to the author, "This bill would expand state law to ensure that neighborhoods receive adequate SB 277 Page 5 notice and protection from paroled sexual predators. [This bill] requires the State Board of Parole to give local law enforcement a 60-day notice of all convicted Megan's Law registrants who are to be paroled into their jurisdiction. "[This bill] also prohibits any [parolee required to register as a sex offender] from being placed within one and one-half mile of a public park, day care, pre-school, or public or private school. This restriction currently only applies to child molesters convicted under [specified Penal Code Sections] and is limited to a one-quarter mile of public and private schools." 2)Background : According to background information supplied by the author, a high-risk sex offender was paroled into a community care facility located 1.1 miles from an elementary school located on a major road artery on which three other schools and more than 2,500 students are located. Following this placement, the Riverside County Board of Supervisors passed Ordinance Number 841 in response. The ordinance makes a number of demands on the CDC and establishes "significant restrictions on sex offenders in unincorporated areas of the county." According to the author, this ordinance is "unfortunately likely unconstitutional because a county cannot preempt state law. As a result, most law enforcement agencies believe the ordinance will be unenforceable." 3)Re-Integration of Formerly Incarcerated Persons into Society : According to "A Civil Rights Task: Removing Barriers to Employment of Ex-Convicts", University of San Francisco Law Review (2004) 38 U.S.F.L. Rev. 193, "Our nation faces a growing problem that cries out for careful, rational reforms. (Emphasis added.) As of June 2002, the prison and jail population exceeded two million inmates for the first time. State prisons operated between 1% and 16% above capacity and federal prisons operated 31% above capacity. The inmate population grew an average of 3.8% each year from 1995 to 2002. "This inmate population naturally turns over - in 2001, over 600,000 prisoners were released on probation or parole, or because they completed their sentences. Those released SB 277 Page 6 persons face the daunting task of integrating themselves back into the very different mainstream society and most importantly into the work world. The task of integrating the ex-offender into employment is a valuable task for society to undertake because unemployment is strongly correlated with recidivism. Unfortunately, there are many laws and ordinances that prohibit ex-offenders from certain categories of employment, thus impeding that facet of the rehabilitation process. "A very important question [is:] . . . should traditional civil rights organizations, concerned with improving the conditions for black Americans, begin to treat this problem as one that is in urgent need of law reform? If so, what resistances will such organizations meet, and what strategies are appropriate responses? "By the mid-1990's, approximately one-half of the inmates nation-wide were African-American despite the fact that blacks were only 13% of the total population. Additionally, the overwhelming bulk of inmates were male as opposed to female. The blocking of ex-convicts from employment is thus, very much, a 'black' problem." Laws that are facially neutral but have a racially disparate impact violate the equal protection clause of the constitution. [ Wang v. Hoffman , 694 F. 2d 1146 (9th Circuit 1980.), citing Green v. Missouri Pacific Railroad Co., 523 F. 2d 1290, 1295 (8th Circuit 1985).] According to No Second Chance , a publication of the Human Rights Watch, United States courts have recognized "the obvious fact that criminal records screening has a disparate impact on racial and ethnic minorities." [See, e.g., Green v. Missouri Pacific Railroad , supra.] No Second Chance also points out that there is striking data from certain states and the first state listed is California. ( No Second Chance , page 85.) "Only 7% of the state's population, African Americans account for 20% of all felony arrest and 31% of the prison population in California," citing Three Strikes: The New Apartheid , Center on Juvenile and Criminal Justice (1996). Arguably, the plight facing sex offender registrants is even more severe that the overall difficulties imposed upon people released from prison for other crimes. If barring former inmates from employment is the critical problem addressed in University of California, San Francisco, law review article, SB 277 Page 7 supra, the nature of that problem is compounded many times by the restrictions proposed by this bill on housing of parolee sex offenders. The location of housing, the availability of public transportation, and a stable living environment are inextricably interrelated with finding and maintaining employment. This is a serious public safety issue as the lack of employment has been cited as a factor in recidivism, as has the lack of a stable living environment. By banishing sex offender parolees to discrete colonies far from schools, parks, daycare, etc., this bill also proposes to banish them to what are likely remote locations lacking suitable, or any, employment opportunities, sufficient affordable housing, and available mass transit. Thus, this bill proposes to make their successful reintegration into society far less likely and the likelihood of recidivism greater. Given the serious consequences implicit in the sex offender registration and related laws, is it good policy to enact piecemeal legislation in reaction to the release of a single parolee one mile from a school? (According to background information provided by the author's office, this bill was introduced in reaction to the release of a single parolee into a group home in Mead Valley.) Or, as suggested by the above-cited law review article and by a member of this Committee at a previous hearing, should a comprehensive, careful, and rational approach be adopted as to any revisions to California's sex offender registration and related laws? 4)Parolees Required to Register as a Sex Offender : According to CDC, there are approximately 9,000 parolees under supervision in California who are required to register as a sex offender. Of this number, approximately 3,000 had been convicted of offenses related to lewd acts with a child. Although the provisions of this bill apply to the entire universe of sex offender parolees, the prohibitions in this bill and the author's statement tend to indicate that it is the registrants who committed offenses against children who are the specific target of this bill. Yet, this bill includes all of the parolee sex offender registrants on parole and prohibits them from residing within one and one-half miles from schools, parks, day care centers, pre-schools, etc. Is there a rational basis for applying such SB 277 Page 8 a strict exclusionary housing policy to parolees who have never molested or abused a child? A related question could be raised as to the more than 600 rapists on parole. Should the law reflect equal concern for all vulnerable victims of sexual crimes? For example, should there be an analogous prohibition against rapists residing within one and one-half miles of any women's clothing stores, any obstetrician/gynecologist's office, women's fitness centers, convents, etc.? The female victims of these rapists might argue that as similarly-situated victims of a violent sex crime they deserve the same considerations given to child victims by this bill. 5)Is This Bill Workable ? If all sex offenders on parole, regardless of the crime requiring registration, were precluded from living within one and one-half miles of a school, preschool, day care, and public park, it would be virtually impossible for sex offenders to live in most urban areas and arguably most suburban areas as well. For example, under the provisions of this bill, no sex offender registrant parolees could be placed, or reside, within the City and County of San Francisco. Maps of other suburban cities indicate that most of their areas are excluded merely by extending the distance from schools; when public parks, day care centers and preschools are factored into the equation, it appears that most urban and suburban areas will be zones in which no sex offender on parole may reside. To the extent that there may be areas in cities that are not within one and one-half miles of a school, a preschool, a day care center or a park, those areas would most likely be in industrial parts of the city. It is unclear that even highly industrialized areas of cities do not have some land dedicated as park area. Such a residency restriction would lead to massive clustering of sex offenders in particular, identifiable areas, where medical and psychological services are not readily available. In the alternative, this residency restriction would require sex offenders to live in unpopulated rural areas, which would lead to the same problems of clustering and unavailability of services. 6)Location of Schools : According to the California Department SB 277 Page 9 of Education, in urban areas densely populated with multifamily apartments, schools may be designed to serve a one square mile attendance area. The school district may have schools located 1.5 to 2.5 miles apart if the residences are single-family homes. Assuming that the area had no parks, day care centers, or pre-schools, it is possible that the location of schools would allow for small "corridors" or "clusters" between the schools into which urban-placed sex offender parolees could be concentrated if available housing could be found. This bill is applicable to all public and private schools, Kindergarten through Grade 12, inclusive. Home schooling of children is an option increasingly chosen by many parents. Are home schools contemplated as "private" schools covered by this bill? Is there a readily available listing of addresses at which minors are being "home-schooled?" A 1996 study by the National Home Education Research Institute (NHREI) concluded that there were 1.23 million children in the United States being home schooled in the fall of 1996 and estimated that home schooling has a sustained growth rate of 15% to 20% for the last three decades. The Education Code contains other bases for exemption of minors from attendance at regular schools; e.g., exemptions for children working in the entertainment industry, children being privately tutored, etc. Would such alternate places of education be covered by the provisions of this bill? 7)Day Care Centers : Similarly, day care centers and preschools may not be clearly delineated on maps and are often located in residential areas without visible signage. While the Department of Social Services licenses child care facilities that apply for such licenses, there are also undoubtedly an unknown, and continually changing, number of unlicensed child care facilities being conducted out of residential homes. According to background information received on this bill, there are approximately 60,000 licensed child care facilities located throughout California. Of these 60,000 facilities, approximately 13,000 are child-care centers, approximately 42,000 are child-care homes, and 5,000 are county-licensed child-care homes. In order for CDC to comply with the mandates of this bill, CDC would have to obtain the addresses of the 60,000 licensed facilities, locate them on a map, and SB 277 Page 10 disseminate the information to all paroling authorities and parole agents. It is unclear how CDC could compile the same information as to the unlicensed child-care facilities being operated by individuals from their private residences. A perusal of the classified advertisements in any newspaper makes it abundantly clear that day care centers are prevalent in both urban and suburban communities. Some are licensed, and some are not licensed. Licensure status is a fluid matter; a day care center may be licensed today and go out of business for any number of reasons next week. Tracking the unlicensed, day care centers for purposes of this bill would be virtually impossible. Since this bill states that sex offender parolees may not be placed, and may not reside, within one and one-half miles of the day care centers, preschools, private schools, public schools, and public parks, what does this bill contemplate as to a parolee who is properly placed within the constraints of this bill only to have a residential day care center go into operation within one and one-half miles of the placement in the following month? A literal reading of this bill indicates that the parolee would be in violation of the provisions of this bill if he or she continued to reside in the housing designated by the paroling authority if, after the parolee has been placed, a person residing within one and one-half miles decides to start a small child-care business in his or her home. Does this bill contemplate that the burden is on the parolee to ascertain the existence of new, perhaps unlicensed, day care centers that may have recently opened? Or is the burden on the parole agent to keep abreast of such new businesses and relocate his or her affected parolees accordingly? If the parolee failed to move in such a case, would this be grounds for parole revocation and return to prison? What consequences, if any, would inure to CDC for non-compliance? 8)Public Parks : This bill contains no definition of a "public park." There are references to public parks in a number of statutes in the Government Code and Public Resources Code, although none provide a general, overall definition applicable to all law. According to the Public Park Preservation Act of 1971, "As used in this chapter, 'public park' includes only a park operated by a public agency." However, as discussed below, other sections of the Public Resources Code employ a SB 277 Page 11 broader implied definition, and the Government Code discusses public land used for recreational purposes in the same sections as public parks. (See, e.g., Government Code Section 25550 et seq.) Therefore, it can be assumed that a public park is any land owned by a governmental entity and set aside for use as a park or used for recreational activities. A public park may include private land used as a park or for egress and ingress to and from a park, as to which an easement has been granted for general use. There are 26 national parks, such as Yosemite, in California; and 278 state parks, many of which are adjacent to urban areas or residential developments. There are municipal parks of all sizes and types, such as greenbelt areas within a housing subdivision, skateboard parks, dog parks, children's parks, neighborhood parks, and land devoted to community gardening. National or state forests and wilderness areas, as well as rivers, streams, lakes, bays, tidelands, wildlife refuges, beaches, golf courses, may be considered public parks. (11 A.L.R. Fed. 556; Government Code Section 25550 et seq.) Additionally, Public Resources Code Section 5096.144 includes lands and water areas suitable for public parks, beach or recreational purposes in its discussion of places suitable for public parks including, but not limited to, areas of historical significance and areas of open space that complement park, beach, or recreational areas or which are suitable for the preservation of coastal resource values. Moreover, Government Code Section 40401 makes it clear that local governing bodies may acquire land for public squares, parks, and playgrounds; this is a matter of local, not statewide, concern. Similarly, the local governing agency may change the location of a park through local procedures. (Government Code Section 5407.2.) The above discussion seemingly leads to the inevitable conclusion that the state paroling authority, parole agents, or parolees would find it difficult if not impossible to develop and maintain accurate maps reflecting the location of all public parks. If the parole agent and the parolee are unable to determine where all public parks are located, how are they to determine whether a proposed residence is within one and one-half miles of such a park? SB 277 Page 12 Moreover, cities frequently designate formerly vacant land as a park site; there are neighborhood parks, skateboard parks, dog parks, etc, in many small California cities, as well as larger, more officially designated parks such as Golden Gate Park in San Francisco. If a parcel of privately owned land is suddenly acquired by a city in order to provide recreational opportunities to its residents, is a sex offender parolee who was placed within one and one-half miles of this parcel of land now required to move? If a community garden project sprouts on formerly vacant urban land, what relocation, if any, is required of the parolee subject to this bill? Any publicly owned land used for recreational purposes appears to fall within the broad definition of "public park." Does CDC have the resources to constantly monitor the actions of every California city council to determine what new business licenses for child care may have been issued and what formerly vacant land has now been designated as a skateboard park, a dog park, or a local neighborhood park? Does CDC have the resources, both financial and personnel, to continually move the parolees subject to this bill in order to maintain compliance with its provisions? The monitoring and relocation activities mandated by this bill would seem to consume a huge amount of parole agent resources, if indeed the relocation could be accomplished under the strictures of this bill. In general, CDC estimates that temporary hotel placement of parolees until an appropriate placement in the county of last legal residence is located costs at least $65 per day, per parolee. 9)Unconstitutionally Vague : According to a recent Ninth Circuit Court of Appeals case, "A statute is void for vagueness (and thus unconstitutional under due process) if the statute: (a) does not define the conduct it prohibits with sufficient definiteness and (b) does not establish minimal guidelines to govern law enforcement. A criminal statute cannot be so vague that men of common intelligence must necessarily guess at its meaning and differ as to its application." [ U.S. v. Wyatt , 2005 U.S. App. LEXIS 9635 (May 26, 2005).] "In determining whether a statute is void for vagueness, we also consider whether the statute defines the offense 'in such a manner that does not encourage arbitrary and discriminatory enforcement,' citing Kolender v. Lawson , 461 U.S. 352, 357 (1983). A scienter requirement can help a law escape a SB 277 Page 13 vagueness problem," citing Posters 'N' Things v. United States , 511 U.S. 513, 526 (1994). ( Wyatt, supra, at HN 7.) The provisions of this bill with respect to day care, public parks, and schools arguably, due to the lack of any definitions, do not define the prohibited areas with sufficient definiteness and may cause people of ordinary intelligence to guess as to whether an area is a public park or whether a home with a number of children is a day care center or merely a large family. Moreover, this bill provides no guidelines to law enforcement, which is of particular concern due to the wide sweep of the prohibitions - prohibitions which would affect both parole agents and parolees. Further, as discussed below, this bill fails to define the offense in such a manner that does not encourage arbitrary and discriminatory enforcement. ( Kolender, supra, at page 357.) As stated in the Wyatt case, supra, "[an] intent requirement thus limits the discretion of law enforcement and mitigates any perceived vagueness." (Id.) This bill lacks the intent requirement which "can help a law escape a vagueness problem." (Id.) It may also be written in such a way as to encourage arbitrary and discriminatory enforcement. 10)Discriminatory Enforcement : On the basis of previous study of the issue of locating sex offenders within specified distances of schools, it is apparent that there are some counties, such as San Francisco, in which there is no housing available for sex offender registrant parolees pursuant to the provisions of this bill. Maps previously provided by CDC also demonstrate there is little, if any, housing available in cities such as Cupertino, Sunnyvale, and Indio under the increased restrictions which have been proposed regarding location near schools. By adding prohibitions on location near parks, day care, and pre-schools, it seems apparent that only rural areas in the central valley's farm areas, or desert areas near Los Angeles, may be available for housing parolees required to register as sex offenders. It is not clear that such areas would be permissible housing zones under this bill due to the difficult nature of identifying the location of unlicensed day care and parks of all types. Therefore, the paroling authority will be faced with the dilemma SB 277 Page 14 of relocating the parolee from what may be a stable environment to an unknown area, outside of his or her county of last legal residence and away from the parolee's family, job, and support system, or being in non-compliance with the law. The parolee will face the same impossible choice. Sex offender registrant parolees residing in large urban areas may not attract the media and other attention received by sex offenders located in other areas of California. Does this bill invite inadvertent or passive violation of this bill's prohibitions depending upon the local community's reaction to public notification and media coverage of the parolee's residence? How likely is it that this bill would, or could, be equally enforced as to all parolees in the state required to register as sex offenders? If the provisions of this bill are not applied equally to every sex offender parolee in California, a number of additional unintended consequences arise, including the potential of discriminatory and/or arbitrary parole revocations, unequal provision of medical treatment and services, disparate racial or ethnic impacts, etc. Any of these effects could give rise to a constitutional challenge on equal protection grounds. "Group classification by legislative act will be analyzed under the strict scrutiny test if the classification infringes fundamental rights or concerns a suspect class." [ City of Cleburne v. Cleburne Living Center , 473 U.S. 432, 440 (1985).] Although sex offenders, per se, are not a suspect class, discriminatory enforcement of the provisions of this bill could impact a group of persons who do constitute, or are found to constitute, a suspect class. Additionally, any of these consequences may result in further litigation and increase the potential that an appellate court will find the sex offender registration and related statutes punitive and no longer protected by the existing judicial determinations that sex offender registration statutes are civil, regulatory schemes. [See, e.g., Smith v. Doe , 538 U.S. 84 (2003).] The provisions of this bill, and the consequences if enacted, may be so severe as to be vulnerable to attack on the factors determining a regulatory scheme, particularly those related to SB 277 Page 15 the imposition of an affirmative disability or restraint, the lack of a rational connection to a non-punitive purpose, and its excessive provisions with respect to this purpose. 11)The Kennedy v. Mendoza-Martinez Factors : In determining that sex offender registration statutes are, in general, constitutional, the United States Supreme Court identified a number of factors to be considered in determining whether the sex offender requirements were punitive in nature or merely a civil regulatory scheme. [ Smith v. Doe , 538 U.S. 84 (2003).] The factors are whether the regulatory scheme: (a) has historically been regarded as punishment, (b) imposes an affirmative disability or restraint, (c) promotes the traditional aims of punishment, (d) has a rational connection to a non-punitive purpose, or (e) is excessive with respect to this purpose. [Id., citing Kennedy v. Mendoza-Martinez , 372 U.S. 144 (1963).] Several of the factors seem particularly applicable to this bill: a) Affirmative Disability or Restraint : Does this bill impose restraints so severe as to be punitive, rather than regulatory, in nature? The sex offender registration laws have been upheld by the courts to date because they have been determined to be civil, rather than punitive, in nature. To the extent that the State enacts laws that impose severe and unreasonable restraints on sex offender registrants, it is arguable that appellate courts will find such laws unconstitutional. Does this bill, and others like it, threaten the entire Megan's Law civil regulatory scheme in California? In analyzing Alaska's sex offender registration requirements, the United States Supreme Court found that "our system does not treat dissemination of truthful information in furtherance of a legitimate governmental objective as punishment. In contrast to the colonial shaming punishments, the State does not make the publicity and the resulting stigma an integral part of the objective of the regulatory scheme. . . . The purpose and principle effect of notification are to inform the public for its own safety . . . . " (Id. at page 99.) The Supreme Court noted that the act does not restrain SB 277 Page 16 activities sex offenders may pursue but leaves them free to change jobs or residences, stating "the record in this case contains no evidence that the [sex offender registration laws] have led to substantial occupational or housing disadvantages for former sex offenders that would not otherwise have occurred through the use of routine background checks . . . . " (Id. at page 100.) The clear implication from this discussion is that to the extent the sex offender registration and public notification laws impose substantial housing disadvantages on former sex offenders, the effect of such laws might more easily be determined to be punitive rather than regulatory. To the extent that public notification of the names of sex offender registrants imposes an affirmative duty or restraint on registrants which is greater than minor or indirect, the effect is more likely to be determined punitive. If the law is determined to be punitive in nature, constitutional validity under the ex post facto provisions is called into question. [Id. at page 99, citing Kennedy v. Mendoza-Martinez , supra, at page 168 (1963).] The Smith Court concluded that "whether other constitutional objections can be raised to a mandatory reporting requirement, and how those questions might be resolved, are concerns beyond the scope of this opinion. It suffices to say the registration requirements make a valid regulatory program effective and do not impose punitive restraints in violation of the Ex Post Facto Clause." ( Smith , supra, at page 102.) b) Banishment : In Doe v. Miller , 405 F. 2d 700, 725 - 726 (April 29, 2005), 8th Circuit Court of Appeal Judge Melloy concurred in part and dissented in part as to the application of the Kennedy v. Mendoza-Martinez , supra, factors regarding a determination if a law is punitive and subject to constitutional challenge under the ex post facto clause of the United States Constitution. Judge Melloy stated that the residency restrictions at issue in Doe v. Miller did not amount to full banishment (a factor indicative of a punitive scheme), "it sufficiently resembles banishment to make this factor weigh towards finding the law punitive." (Id. at page 724.) SB 277 Page 17 In his concurring and dissenting opinion, Judge Melloy further found that the residency requirement imposed an affirmative restraint or disability and distinguished the prohibitions in the Iowa law at issue in this case and that discussed by the United States Supreme Court in Smith v. Doe , 538 U.S. 84, 92 (2003), in which the offenders "were free to change residences." Judge Melloy stated, "I would find that the affirmative disability or restraint intrinsic in the residence requirement distinguishes it from the sex offender registry in Smith and weighs in favor of finding the law punitive." ( Doe v. Miller , supra, at page 725.) c) Excessive In Relation to Its Purpose: In his further analysis of the Kennedy v. Mendoza-Martinez factors, Judge Melloy stated that the restriction "is excessive in relation to [the non-punitive purpose.] The effect of the requirement is quite dramatic: many offenders cannot live with their families and/or cannot live in their home communities because the whole community is a restricted area. This leaves offenders to live in the country or in small, prescribed areas of towns and cities that might offer no appropriate, available housing." (Id.) 12)Constitutional Challenge to This Bill : Inasmuch as the United States Supreme Court specifically discussed affirmative restraints on housing in its consideration of the constitutionality of the Alaska sex offender notification laws and also left the door open to "whether other constitutional objections can be raised to a mandatory reporting requirement," it appears likely that this bill's extreme prohibitions on all sex offenders on parole living within one and one-half miles of schools, daycare centers, parks, etc. would be subject to constitutional challenge. According to the Iowa Civil Liberties Union (ICLU) plans to seek review of the Doe v. Miller decision by the entire 8th Circuit Court of Appeal in hopes of obtaining a reversal. The ICLU newsletter states "in the meantime, sex offenders across the state are preparing to pull up stakes and leave their registered residences." (ICLU, The Defender , June 2005.) Pending further constitutional challenges, sex offenders have not been declared by the courts to be a protected class. To date, their rights to be free from burdens placed upon them by various states have not been declared to be fundamental rights. Both protected classes and violations of fundamental SB 277 Page 18 rights are reviewed by appellate courts under the "strict scrutiny" test, and such laws are upheld only when narrowly tailored to serve a compelling state interest. [ Doe v. Moore , 2005 U.S. App. LEXIS 10354 (11th Circuit June 6, 2005), citing Reno v. Flores , 507 U.S. 292, 302 (1993).] The United States Supreme Court has recognized that fundamental rights include those guaranteed by the Constitution's Bill of Rights as well as certain liberty and privacy interests implicit in the due process clause and the penumbra of constitutional rights. These special liberty interests include "the right to marry, to have children, to direct the education and upbringing of one's children, to marital privacy, to use contraception, to bodily integrity, and to abortion." [ Doe v. Moore , supra, citing Washington v. Glicksburg , 521 U.S. 702, 720 (1997).] In enunciating new fundamental rights, courts must determine whether the asserted right is "one of those fundamental rights and liberties which are, objectively, deeply rooted in this nation's history and tradition, and implicit in the concept of ordered liberty, such that neither liberty nor justice would exist if they were sacrificed." ( Williams v. Attorney General of Alabama , 378 F. 3d 11232, 1239, citing Glucksberg, supra.) At present, however, case law indicates that laws regulating sex offenders are not subject to the constitutional strict scrutiny test, but to the far less stringent rational basis test. Would the prohibitions on residency during parole withstand review under the rational basis test? Under the rational basis test, courts inquire whether the statute is "rationally related to legitimate government interests." ( Glucksburg , supra at page 728.) It could be argued that there is no rational basis for the assumption that the prohibitions of this bill in any way protect children in particular or the public at large. Although this bill prohibits the sex offender parolees from residing near schools, parks, etc., it does nothing to prevent such sex offenders from being in the areas where the schools, parks, day care, etc., are located. In fact, although the parolee could not under the provisions of this bill live within one and one-half miles of a public park, that same sex offender parolee could legally spend seven days per week sitting in the same park or walking near that same school. SB 277 Page 19 Is this bill based on the flawed premise that strangers perpetrate child molestation at or around schools and parks? There is no indication that a one and one-half mile buffer zone around schools, parks, day care centers, etc., would actually protect children. Unfortunately, child molestation usually occurs within the home of a relative or friend. According to the federal bureau of Justice Statistics, "in almost one-half the [molestation] cases [leading to conviction] the abuser is a parent or relative." (Sarah Glazer, 'Punishing Sex Offenders,' CQ Researcher, Vol. 6, No. 2, p. 28, January 12, 1996.) Would the severe prohibitions and restrictions of this bill survive scrutiny under the rational basis test? Is there a rational basis to effectively banish 9,000 parolees to discrete colonies where no one but other sex offenders live and where they are unlikely to be able to avail themselves of the treatment and services they need. Will parole agents be able to effectively monitor and supervise their parolees under such circumstances? Does this bill have the practical effect of driving parolees required to register as sex offenders underground to a life in which they are unable to comply with the terms and conditions of their parole and unlikely to continue to register as required? 13)Laws in Other States : According to a recent Illinois appellate case, there are 13 states that have enacted some form of residency restrictions for sex offenders and the distance they may live from specified locations populated by children. ( People v. Leroy , 2005 Ill. App. LEXIS 369.) The distances range from 500 feet (Illinois) to 2,000 feet (Arkansas, Iowa, Oklahoma and Alabama.) The other states are California (one-quarter mile); Florida, Georgia, Kentucky, Louisiana, Ohio, and Tennessee (1,000 feet); and Oregon (unspecified distance). There is a statutory mandate that the CDC shall develop criteria that it may consider in placement of parolees; such criteria should include generally prohibiting residency near locations where children are the primary users and the bases for authorizing exceptions. (Oregon Revised Statutes, Section 144.642.) Each of these states has restrictions far less severe than those SB 277 Page 20 proposed by this bill. For example, Ohio's law is restricted to schools and provides for injunctive relief if sought. (Ohio Revised Statutes Section 2950.031.) Oklahoma's law is also restricted to schools and specifies misdemeanor penalties for violations. (57 Oklahoma Statutes Section 590.) Several of the other states' laws attempt to deal with some of the vagueness issues raised by this bill. For example, Kentucky specifies precisely how the measurement of 1,000 feet is to be taken: "The measurement shall be taken in a straight line from the nearest wall of the school to the nearest wall of the registrant's place of residence." (KRS Section 17.495.) Similarly, Georgia specifies how the distance is to be calculated (outer boundary to outer boundary of residence). (Official Code of Georgia Annotated, Section 42 -1 -13.) The Georgia law also includes a scienter (knowledge) element. An important consideration is that these states are not all lifetime registration states. Alabama's registration period is 15 years unless an aggravated offense; Iowa's is 10 years, except for violent offenses; Arkansas is 15 years and lifetime for violent offenses; Florida is 20 years; Georgia is 10 years, except for sexually violent predators; Kentucky is 10 years, and lifetime for repeat offenders; Louisiana is 10 years, except for violent offenses; Ohio is 20 years, with lifetime registration only for specified offenses; Oklahoma is 10 years, with lifetime registration for repeat offenders; Oregon is 10 years with lifetime for sexually violent predators; and Tennessee is 10 years, with lifetime registration for repeat offenders. There are other significant differences as well. California requires all convicted sex offenders to register for their lifetimes and does not conduct any risk assessment as to their recidivism propensity. Arkansas, Iowa, Oklahoma, and Tennessee do conduct a risk assessment. Therefore, the impact of the severe restrictions imposed by this bill would be far greater in California, which has more sex offender registrants and undoubtedly more sex offenders on parole than any other state. 14)Impact on Public Safety : It is entirely possible that rather than increasing the safety of the public, this bill could have the unintended consequence of negatively impacting the safety SB 277 Page 21 of California's citizens. If a portion of a community could be found that had no schools, day care centers, preschools and parks within one and one-half miles, sex offender parolees would be clustered in such an area. The clustering of sex offenders is discouraged by existing law for a reason. It is possible if not likely that such clustering would decrease, rather than enhance, public safety, particularly to the extent that the permissive areas of residence are likely to be remote and lack the necessary medical and psychological treatment and services recommended for rehabilitation of such offenders. According to No Second Chance , published by the Human Rights Watch in 2004, "Exclusionary housing policies constitute one of the most significant barriers to re-entry [of formerly incarcerated persons into society.] Excluded from public housing, they often end up swelling the ranks of the homeless, become inhabitants of grimy and unsafe transient hotels and motels, or crowd into the homes of relatives and friends. None of these options is conducive to the development of stable, productive lives for former prisoners or their children." (Id. at page 16.) The Human Rights Watch Publication further states that "people who are inadequately housed, especially those living on the streets or in homeless shelters, are at a higher risk for communicable diseases such as HIV and tuberculosis," citing Housing and HIV: Drug and Sex Risk Behaviors , by Angela Aidala and Jay Cross, Center for Applied Health, Mailman School of Public Health, Columbia University. (Id at page 42.) "Existing mental health conditions are exacerbated by the stress of rejection and housing instability." (Id.) "Recidivism becomes a self-fulfilling prophecy when offenders are released from incarceration with scant survival options. [E]xclusionary policies need to be changed not just because it is the humane thing to do but because it's the smart, public safety thing to do." (Id. at page 43.) 15)The Impact of Sex Offender Residence Restrictions : In an article published in the International Journal of Offender Therapy and Comparative Criminology, Vol. 49, pp. 168 - 178, "The Impact of Sex Offender Registration Restrictions: 1,000 Feet From Danger Or One Step From Absurd?", it was stated, "Several states have enacted public policies that prohibit sex offenders who have abused children from living within close SB 277 Page 22 proximity to a school, park, day care center, or school bus stop. The purpose of this exploratory study was to describe the impact of residence restrictions on sex offender re-integration and to better understand sex offenders' perceptions of these laws. A survey of 135 sex offenders in Florida was conducted. Most of the molesters who responded to the survey indicated that housing restrictions increased isolation, created financial and emotional stress, and led to decreased stability. Respondents also indicated that they did not perceive residence restrictions as helpful in risk management and, in fact, reported that such restrictions may inadvertently increase triggers for re-offense." The title of the above article seems particularly apt. Is the Legislature's piecemeal approach to regulating registered sex offenders truly "one step from the absurd?" On June 13, 2005, the Salt Lake Tribune newspaper published an article, "Neighborhood in Texas to be Sex Offender-Fee." The article begins by stating "the sales pitch for this planned subdivision goes beyond the usual vision of attractive homes and amenities - homeowners will be required to pass criminal background checks and no convicted sex offenders will be allowed." The subdivision described is being developed by a real estate development company which will require home builders to agree to conduct background checks on home buyers and any juveniles expected to live in the homes. They could be penalized if they even unknowingly sell to a convicted sex offender according to the article. Further, "residents will face penalties if they allow a convicted sex offender to live in their homes and will be responsible for checking the backgrounds of potential buyers if they sell." The development company "promises to buy a home back for 85%" of the appraised value if builders sell to a sex offender or if an owner or a resident is convicted of a sex offense. Are these and similar restrictions a further step toward a sex offender registry system that is punitive, not civil, in nature and thus open once again to constitutional challenge? 16)California Registered Sex Offenders : According to a CCOSO report, "Using the Internet to Provide Passive Community Notification About Registered Sex Offenders", "Because California has been requiring certain sex offenders to SB 277 Page 23 register since the mid 1940's, far longer than any other state, California's cumulative total of registered sex offenders is much larger, both in absolute numbers and proportionately, than the total for any other state." According to the report, approximately one out of every 180 adult males in California could be posted on the Internet as sex offenders. As of May 2003 (citing Department of Justice Statistics), the report states there were 100,501 registered sex offenders in California. Of that number, 1,836 were classified as "high risk" and 82,190 as "serious." It is those two groups who are subject to the current Internet notification system. A third group of registered sex offenders were convicted of crimes not currently subject to public notification. According to CCOSO, of the high risk and serious groups, 55,902 were living in the community, 14,556 had returned to jail or prison, 10,800 had left California, and 2,768 had been deported. Altogether, 70,458 California residents (almost all of them adult males) are subject to notification under the present system. According to the CCOSO report, approximately one of every 123 adult males in California is a registered sex offender, although some of these have left California or failed to re-register as required. The CCOSO report notes that in addition to the registered sex offenders, there is a potentially large number of additional individuals who are also impacted by Internet notification and related actions, including parents, children, siblings, other relatives, employers, landlords, associates, etc. By prohibiting all sex offender parolees from living in so many areas of California, this bill affects a much larger group of innocent persons, such as their spouses, domestic partners, and minor children. According to the CCOSO report, "Widespread notification is making it increasingly difficult for registrants to find housing. This tends to drive them into poorer neighborhoods, where more dysfunctional families tend to live. Children from these families are more easily victimized than children in more affluent, better organized neighborhoods. The Third National Incidence Study of Child Abuse and Neglect showed that children living below the poverty line are 18 times as likely to be sexually abused as children living at or above SB 277 Page 24 the median income. ["National Incidence Study on Child Abuse and Neglect", Department of Health and Human Services, Administration for Children and Families, National Center on Child Abuse and Neglect (1996).] 17)Arguments in Support : The Peace Officers Research Association (PORAC) states they represent 58,600 rank and file peace officers and 710 local peace officer associations and are "writing to inform you of their support for SB 277 (Battin) relating to sex offenders." 18)Arguments in Opposition : a) The California Attorneys for Criminal Justice state, "It is difficult to imagine if any such property or residence exists in California. Most cities have schools in much smaller circumscribed areas than one and one-half miles. This bill would effectively tell [sex offender] registrants that they have to sell their homes, move out of their apartments or say goodbye to their family members and move out of California. "Although it may be applauded by some citizens, it is fundamentally unfair. . . . Any problems that exist with registrants living in our communities need to be addressed with a more carefully tailored solution than that proposed by [this] bill." b) The California Public Defenders Association (CPDA) state: i) The bill is superfluous; the Board of Prison Terms "already is authorized to give paramount consideration to the protection of the victim and the safety of the community in making parole placements; ii) "Parole officers already have the authority to set special conditions of parole which may impose additional conditions on a parolee such as mandating that the parolee stay at least 100 yards away from places where children congregate (schools, parks, playgrounds, video arcades, swimming pools, etc.) iii) This bill curtails the discretion of the Board of Prison Terms, which should be able to evaluate inmates on SB 277 Page 25 a case-by-case basis. "An inmate convicted of molesting adolescent girls probably is not a risk to an all-boys' K - 8 school. An inmate who is in a wheelchair or otherwise incapacitated is unlikely to be a risk to a school within the one and one-half mile radius." iv) This bill further retards and prevents the rehabilitation of sex offenders, who "need to be reintegrated into the community in order to successfully complete [parole]. Banishing them to a commercial or industrial ghetto retards that process. It makes more sense to mainline sex offenders while they are under the most intense parole supervision rather than after they have completed parole and are not subject to supervision." v) This bill presents practical problems which include the following: (1) "In order to implement the proposed legislation, CDC would have to re-examine every placement and determine if it is beyond the one and one-half mile perimeter. This would mean additional costs to house parolees who were moved from their family homes or placements to stay in motels or other locations until new facilities could be rented or constructed. (2) "For parolees who had succeeded in obtaining employment or training, such uprooting could lead to the loss of those opportunities. Loss of income could quickly lead to homelessness, creating additional problems of supervising sex offenders. (3) "The one and one-half mile prohibition would make it almost impossible to return any sex offender registrant parolees to their county of origin. All such San Francisco County parolees would have to be placed elsewhere. (4) "The community notification provisions of this bill would guarantee that CDC would be in the same position as the Department of Mental Health (DMH) is placed whenever they try to place a person who has been released [from civil commitment.] If CDC cannot SB 277 Page 26 find appropriate placements, will the parolees be forced to stay in prison? Then they would be released without any supervision." c) The American Civil Liberties Union states, "This bill represents an unnecessary and unworkable expansion of existing law. Current law already prohibits a person in this category from living within one-quarter mile of a school. There is no indication that a wider buffer zone around schools is necessary or will do anything to actually protect children. "The unfortunate reality is that child molestation usually occurs within the home of a relative or friend. (Emphasis added.) According to the federal Bureau of Justice Statistics (BJS), 'in almost one-half the [molestation] cases [leading to conviction] the abuser is a parent or relative.' (Sarah Glazer, Punishing Sex Offenders , CQ Researcher, Vol. 6, No. 2, page 28, January 12, 1996.) "Further, extending the law to childcare facilities and parks would be impractical to administer. With the proliferation of childcare centers, both licensed and not, it would be very difficult to know with any degree of certainty whether any particular location were more than one and one-half miles from a childcare facility. Unlike a school, a childcare facility may be impossible to distinguish from the outside, lacking signs or other distinguishing characteristics. Moreover, expanding current law to include additional locations, such as parks, will make it virtually impossible for placement of parolees in many parts of California." 19)Related Legislation : a) AB 35 (Spitzer) proposed to add addresses, employer names and addresses and specified vehicle information to the Megan's Law Internet web site. AB 35 failed passage in this Committee, was granted reconsideration, failed passage again, and was returned to the Chief Clerk of the Assembly. b) AB 438 (Parra) proposes to allow the eviction of registered sex offenders from rental housing. AB 438 failed passage in this Committee, was granted reconsideration, and has not yet been reheard. SB 277 Page 27 c) SB 43 (Battin) proposes to add specified child pornography offenses to the Megan's Law Internet Web site. SB 43 failed passage in this Committee, has been granted reconsideration, and is set to be reheard on June 28, 2005. d) AB 1422 (Bogh) imposes specified notice and other requirements regarding sex offender registrants living in long term care facilities. AB 1422 is being held on the Assembly Appropriations Committee's Suspense File. e) AB 240 (Bermudez) prohibits sex offenders on parole from being placed within one-quarter mile of a school with grades Kindergarten through Grade 12, inclusive. AB 240 is pending hearing by the Senate Appropriations Committee. f) AB 1323 (Vargas) is a technical clean-up bill following the posting of the Megan's Law information on the Internet site maintained by the Department of Justice. AB 1323 is pending hearing by the Senate Public Safety Committee. g) AB 1844 (Cohn) extends the period of parole for specified sex offenders to 10 years. AB 1844 was held in the Assembly Appropriations Committee. 20)Prior Legislation : AB 488 (Parra), Chapter 745, Statutes of 2004, developed a three-tiered system of making the names and specified addresses or location information as to registered sex offenders available to the public on the Internet. REGISTERED SUPPORT / OPPOSITION : Support Peace Officers Research Association of California Opposition American Civil Liberties Union California Attorneys for Criminal Justice California Public Defenders Association Analysis Prepared by : Kathleen Ragan / PUB. S. / (916) 319-3744 SB 277 Page 28