HomeMy WebLinkAbout16 DISCUSSION OF SENATE BILL 54 AND PROPOSITION 47MEETING DATE
TO
FROM
Correction to
AGENDA REPORT
SEPTEMBER 4, 2018
JEFFREY C. PARKER, CITY MANAGER
MATT WEST, ASSISTANT CITY MANAGER
DAVID KENDIG, CITY ATTORNEY
Agenda Item
Reviewed:
City Manager
Finance Director
SUBJECT: CORRECTION; DISCUSSION OF SENATE BILL 54 AND PROPOSITION
47
There is a typographic error in the staff report regarding the above -referenced item. The
reference to the increase in Part 1 Crimes after implementation of Proposition 47 should
state that there were 2,401 Part 1 Crimes reported, not 2,041. With that correction, the
first full paragraph on the third page of the staff report will read as follows:
"In the three years prior to the implementation of Proposition 47 (from 2012-2014),
Tustin averaged 2,079 Part 1 Crimes reported per year. In the three years after
implementation of Proposition 47 (during which many criminal sentences were
reduced from felonies to misdemeanors) (2015-2017) Tustin averaged 2,401 Part
1 Crimes reported each year, reflecting a 15.5% increase in Part 1 Crimes reported
since the implementation of Proposition 47."
1340658.2
Agenda Item 16
Revied
AGENDA REPORT City Man
Cit Manager
Finance Director A
MEETING DATE: SEPTEMBER 4, 2018
TO: JEFFREY C. PARKER, CITY MANAGER
FROM: MATT WEST, ASSISTANT CITY MANAGER
DAVID KENDIG, CITY ATTORNEY
SUBJECT: DISCUSSION OF SENATE BILL 54 AND PROPOSITION 47
SUMMARY:
Discuss SB 54 and Proposition 47 and provide direction.
RECOMMENDATION:
1. Approve and authorize the Mayor to sign Resolution Number 18-66 reaffirming
the City's March 22, 2017 letter of opposition to SB 54; and
2. Approve and authorize the Mayor to sign Resolution Number 18-67 declaring the
City's support to repeal Proposition 47 (the "Reduced Penalties for Some Crimes
Initiative").
FISCAL IMPACT:
The recommended actions would have no fiscal impact. Other options discussed below
could have varying fiscal impacts. The options to approve a minute order, adopt a resolution
or to receive and file this staff report would have no fiscal impact. Filing an amicus brief in,
or intervening as a party to, already -pending lawsuits would involve expenditures for legal
fees in uncertain amounts, estimated at: $20,000 to prepare and file an amicus brief; $5,000
to review, prepare and file a joinder in an existing amicus brief (assuming one is consistent
with the City's position); or $100,000 to intervene as a party to an existing lawsuit, through
trial, excluding appeals.
CORRELATION TO THE STRATEGIC PLAN:
Tustin's Strategic Plan Goal B: Public Safety and Protection calls for the City to "Ensure
Tustin is an attractive, safe and well maintained community in which people feel pride."
Goal D calls for the City to "Foster strong relationships within the community and to
provide leadership within the region."
1341391.1
Agenda Report: SB 54 and Proposition 47
September 4, 2018
Page 2
3«:, -OW. ON 0117_\ Z 17-967141,6M101TF
I. Summary of SB 54. SB 54, sometimes referred to as the "sanctuary state law" or the
California Values Act ("CVA") became effective on January 1, 2018. The key part of this
legislation is codified at Government Code section 7284 et seq. In general, SB 54 was
intended to limit the involvement of state and local law enforcement agencies in federal
immigration enforcement efforts. As to the CVA in particular, the Legislature declared the
following purposes: "to ensure effective policing, to protect the safety, well-being, and
constitutional rights of the people of California, and to direct the state's limited resources
to matters of greatest concern to state and local governments." [Cal. Govt. Code § 7284.
2(f).]
The CVA regulates the activities of state and local law enforcement agencies. The
legislation generally prohibits California law enforcement agencies from doing all of the
following:
a) Inquiring into an individual's immigration status. Detaining an individual based on
a federal Immigration and Customs Enforcement ("ICE") request that the law
enforcement agency maintain custody beyond the person' s release eligibility to
facilitate transfer to ICE.
b) Providing information about an individual' s release date unless the information
either is: i) publicly available; or (ii) in response to an immigration authority's
notification request and involves an individual who has been convicted of a
designated crime' or who is registered on the California Sex and Arson Registry.
c) Providing personal information about an individual, such as a home or work
address, unless the information is publicly available.
d) Making or participating in an arrest based on a civil immigration warrant.
e) Participating in certain border patrol activities, including warrantless searches.
f) Performing the functions of an immigration officer.
g) Placing peace officers under the supervision of federal agencies.
h) Employing peace officers who have been deputized as special federal officers or
special federal deputies for purposes of immigration enforcement.
i) Using immigration authorities as interpreters for law enforcement matters relating
to individuals in custody.
j) Transferring an individual to immigration authorities unless authorized by a judge
or unless the individual has been convicted of a designated crime.
k) Providing office space exclusively dedicated for immigration authorities for use
1) within a city or county law enforcement facility.
m) Contracting with the Federal Government to house federal detainees.
1 The list of designated crimes includes: assault; battery; burglary; driving under the
influence of alcohol or drugs; child abuse; elder abuse; felony drug possession or trafficking;
gang -related offenses; rape; and unlawful possession or use of a weapon.
1341391.1
Agenda Report: SB 54 and Proposition 47
September 4, 2018
Page 3
There are several exceptions to the CVA's prohibitions. The exceptions include
authorization for a California law enforcement agency to respond to a request for
information about an individual's criminal history, as accessed through the California Law
Enforcement Telecommunications System. They also include authorization for an agency
to participate in joint law enforcement task forces with the Federal Government if (i) the
task force' s primary purpose is not immigration enforcement, (ii) the enforcement or
investigative duties are primarily related to a violation that is unrelated to immigration
enforcement, and (iii) participation in the task force does not violate a local law or policy.
The City's Statement of Opposition to SB 54.
The Tustin City Council considered SB 54 when it was a pending bill on March 21, 2017,
and unanimously directed the Mayor to send a letter of opposition to the legislation on
March 22, 2017. Thus, the City of Tustin voiced its position on SB 54 early on, and well
before the issue gained such heightened public notoriety. A copy of the City's letter
opposing SB 54 is attached as Exhibit 1.
The Effect of SB 54 on Tustin Police Department Operations.
SB 54 has not had a significant impact on Police Department operations in part because
Tustin police officers are neither trained for, nor cross -designated by the Federal
government to enforce immigration laws. In addition, the City does not operate a jail, only
a holding facility. Those arrested for serious crimes are booked into the County Jail, which
is operated by the Orange County Sheriff's Department. And the City continues to enforce
judicial immigration arrest warrants, just as it did prior to the implementation of SB 54.
II. Proposition 47
Proposition 47 (the "Reduced Penalties for Some Crimes Initiative") was enacted in
November 2014. That initiative reduced certain crimes from felonies to misdemeanors
and authorized re -sentencing for those serving a prison sentence for any of the offenses
that the initiative reduced to misdemeanors. The result has been the early release from
prison of thousands of individuals who had been convicted of certain felonies but who's
crimes were retroactively reduced to misdemeanors.
III. Comparison of Crime Rates in Tustin After SB 54 and Proposition 47.
The term "crime rate" refers to the ratio of crimes in an area to the population in that area.
The types of crimes which are tracked are referred to as "Part 1 Crimes". Those crimes
include the most serious violations, including murder, robbery, rape, theft, aggravated
assault, etc. The City has experienced ebbs and flows in its crime rates over time due to
a number of factors.
In the seven months prior to the implementation of SB 54 (e.g., July -December 2017),
Tustin had 1,039 reported Part 1 Crimes. In the seven months after the implementation
1341391.1
Agenda Report: SB 54 and Proposition 47
September 4, 2018
Page 4
of SB 54 (the period from January - June 2018), Tustin had 910 reported Part 1 Crimes,
or a 12.42% decrease in Part 1 Crimes since the implementation of SB 54.
In the three years prior to the implementation of Proposition 47 (from 2012-2014), Tustin
averaged 2,079 Part 1 Crimes reported per year. In the three years after implementation
of Proposition 47 (and during which many criminal sentences were reduced from felonies
to misdemeanors) (2015-2017) Tustin averaged 2.041 Part 1 Crimes reported each year,
reflecting a 15.5% increase in Part 1 Crimes reported since the implementation of
Proposition 47.
While the adverse effect of Proposition 47 on the Part 1 crime rate is fairly evident over
the three years, the effect of SB 54 is less clear given the much smaller sample size of
data examined. Based solely on the existing data, however, the Part 1 Crime rate in
Tustin has actually declined since SB 54 was implemented, not risen.
IV. Pending Litigation
A. U.S.A. v. State of California. On March 6, 2018, the Federal Government filed
a federal lawsuit against the State of California challenging the validity of SB 54 and other
legislation. Concerning the CVA, this lawsuit contends that the restrictions on state and
local cooperation with federal officials are an obstacle to the Federal Government's
enforcement of immigration laws; that they discriminate against federal immigration
enforcement; and that they violate a federal immigration statute. On July 5, 2018, Federal
District Court Judge John Mendez issued an Order on the Federal Government's Motion
for Preliminary Injunction that rejected the Federal Government's arguments challenging
SB 54. The Federal Court concluded that SB 54 does not violate Federal law nor the
Federal Constitution because Federal law does not, and cannot Constitutionally
commandeer State and local police departments to enforce Federal immigration law, and
found that declining to assist Federal authorities enforce immigration laws in some
situations (as SB 54 does) is not the same as impeding Federal enforcement of Federal
laws.
B. City of Huntington Beach v. State of California On April 4, 2018, the City of
Huntington Beach filed a state court lawsuit against the State of California challenging the
validity of SB 54. This lawsuit asserts that the CVA is an unconstitutional interference with
charter cities' authority over municipal affairs. The lawsuit also contends that the
legislation unconstitutionally impairs Huntington Beach's contractual relationship with the
Federal Government.
C. Los Alamitos Community United v. City of Los Alamitos On April 16, 2018, the
Los Alamitos City Council adopted Ordinance No. 2018-03 declaring that the City of Los
Alamitos "exempted itself' from the CVA. The next day a community association, a local
reverend, and a resident jointly filed a state court lawsuit against the City of Los Alamitos
challenging the validity of the ordinance. The plaintiffs are being represented by the
American Civil Liberties Union and the National Day Laborer Organizing Network. This
1341391.1
Agenda Report: SB 54 and Proposition 47
September 4, 2018
Page 5
lawsuit asserts that the ordinance is preempted by state law. The lawsuit also contends
that a local official cannot, without a court having determined that a statute is
unconstitutional, deliberately refuse to enforce the statute because he or she believes
that the statute is unconstitutional.
V. Options for City Council Consideration
If the City Council desires to take a position regarding SB 54 (and/or Proposition 47), then
there are a variety of options available. Among the options are the following:
A. Adopt Minute Order Expressing Position. Adoption of a minute order or
Resolution expressing opposition to or support for SB 54 and/or Proposition 47 would
allow the City Council to memorialize its position. A minute order may include, for
instance, the Council directing a letter of support to the Federal Government and the State
of California encouraging cooperation among all federal, state, and local law enforcement
agencies.
B. Direct Staff to Prepare a Resolution Expressing Position Directing staff to
prepare a resolution expressing opposition to or support for SB 54 and/or Proposition 47
would allow the City Council to memorialize its position in a way that is more formal than
a minute order. Such a resolution would be placed on a future agenda for consideration
by the City Council.
C. Adopt a Resolution Reaffirming the City's Opposition as Expressed in the City's
Letter of March 22, 2017. As summarized above, the City Council approved its opposition
to SB 54 while the legislation was pending. The City Council could adopt a Resolution
reaffirming its March 22 letter. A possible form for such a Resolution is attached as
Exhibit 2.
D. Adopt a Resolution to Support Repeal of Proposition 47. If the City Council
wishes to register opposition to Proposition 47, the City Council could also adopt a
Resolution in the form attached as Exhibit 3.
E. File, or Join in, an Amicus Brief. Filing an amicus brief would allow the City
Council to express opposition to or support for SB 54 in a way that would be considered
by a court. An amicus brief, informally known as a "friend of the court" brief, is a way of
presenting legal arguments to a court without being an active participant in litigation.
Numerous states, counties, cities, and interest groups have already filed amicus briefs in
the federal court litigation, and it is possible to file a brief that "joins" in a brief submitted
by a different entity. An appeal to the Ninth Circuit Court of Appeals will present another
amicus brief opportunity. Both of the state court cases are in the early stage and there
will be an amicus brief opportunity in each. Filing an amicus brief would involve attorney
fees to prepare the brief, though the amount could be reduced (but not eliminated) if the
City filed a brief joining in whole or in part with another entity's brief.
1341391.1
Agenda Report: SB 54 and Proposition 47
September 4, 2018
Page 6
F. Intervene in a Lawsuit. Intervening in a lawsuit would allow the City Council to
express opposition to or support for SB 54 in a way that would make the City of Tustin an
active participant in the litigation. The cost of this option would be significantly higher
than the other options.
G. Receive and File Report. Given the many issues surrounding SB 54, including
the varying levels of support and opposition to the it among the City's communities, and
the Federal District's Court's determination upholding the Constitutionality of the CVA, the
City Council may wish to consider taking no position on the controversy until the courts
determine the validity of the law and instead receive and file this report.
Exhibits:
1. March 22, 2017 Letter Opposing SB 54
2. Proposed Resolution Reaffirming the City's Letter of March 22, 2017 Opposing SB
54
3. Proposed Resolution Declaring the City's Support to Repeal Proposition 47 (the
"Reduced Penalties for Some Crimes Initiative")
4. City FAQ: "Clarifying the Record Regarding Tustin and SB 54"
1341391.1
EXHIBIT 1
Office of the City Council
March 22, 2017
Honorable Kevin de Leon
California State Senate
California State Capitol
Sacramento, CA 95814
RE: Senate Bill 54 (Oppose as amended 3/6/17)
Senate President Pro Tempore de Leon:
The City of Tustin regrets to inform you of our opposition to Senate Bill (SB) 54, which would
limit California law enforcement from using agency or department moneys, facilities, property,
equipment, or personnel to investigate, interrogate, detain, detect, or arrest persons for
inn -migration enforcement purposes. Although immigration enforcement is not the duty of state
or local law enforcement, these restrictions will have negative consequences and threaten to
create safety concerns within our communities.
Public safety is the primary concern of local law enforcement, not immigration. Legally,
California's law enforcement agencies lack the authority and jurisdiction to enforce federal
immigration law. Beyond the legal limitations, any attempt by local law enforcement to target
non -criminals for immigration violations would only erode public trust and curtail the ability of
our departments to carry out their primary mission. Because community relationships are so
important, the California Police Chiefs Association has a track record of standing behind
California's large immigrant community, which includes supporting legislation to allow
undocumented immigrants to obtain a driver license, and shield victims of human trafficking
from deportation. However, there are instances when providing public safety entails partnering
with federal law enforcement agencies, including immigration enforcement.
Consistent with existing state laws and current department procedures, we strongly believe that
undocumented immigrants who commit violent and serious offenses against members of our
community should be subject to the immigration laws of this country. By doing so, we prevent
dangerous individuals from creating more victims - including within our own immigrant
communities. As such, our departments routinely engage with federal law enforcement
agencies - including Immigration and Customs Enforcement (ICE) and Homeland Security
Investigations (HSI) - for the purpose of eliminating drugs, violence, and crime from our
streets.
Mayor Dr. Allan Bernstein • Mayor Pro Tem Al Murray • Rebecca "Beckie" Gomez • Charles E. "Chuck" Puckett • Letitia Clark
300 Centennial Way, Tustin, CA 92780 0 (714) 573-3010 • www.tustinca.org
Honorable Kevin de Leon
March 22, 2027
Page 2
Currently, local law enforcement agencies have the discretion to partner with ICE or HSI, and
do so through targeted operations to apprehend identified criminals. For example, ICE may
request tactical support from a local police department during an operation to arrest members
of a gang or drug cartel for civil or criminal immigration violations. Additionally, local law
enforcement also engages in federal joint task forces with various federal law enforcement
agencies, including ICE and HSI. These task forces all focus on organized crime, human
trafficking and national security; however, immigration enforcement often plays a role in
carrying out those missions. For instance, if during a joint investigation into a drug trafficking
operation, HSI or ICE identifies one of the suspects as an individual with an immigration
violation, the task force may use that violation to apprehend that suspect. In those such
instances, it is typical for local law enforcement to supply information, resources, or even
manpower to physically assist in making the arrest. In every case, these are fluid and dynamic
partnerships that require constant communication.
SB 54 creates roadblocks, hurdles, and ambiguity when it comes to local law enforcement's
participation in any of the examples above. Under the proposed Government Code Section
7284.6(b)(2), SB 54 does appear to exempt local law enforcement agencies who are
"(p)articipating in a joint law enforcement task force, so long as the purpose of the joint law
enforcement task force is not innrnigration enforcement" However, what this section does not
clearly elucidate what "the purpose" of the task force would be considered.
The intent of SB 54 is to prevent local law enforcement from ANY immigration enforcement, so
it is Unclear whether 7284.6(b)(2) distinguishes the overall purpose of the federal -state
collaboration from the incidental operations that may be utilized to achieve that purpose. In the
task force example from above, it is unclear whether "the purpose" would be considered
reducing drug trafficking (the overall mission), or immigration enforcement (the operation). If
the latter, it is also unclear what reduced role local law enforcement would have to take in the
task force would we be forced to simply recuse ourselves from making the physical arrest, or
would we be forced to sever all ties with the operation at that point, including blocking any
information sharing? Moreover, during a collaboration with ICE to serve a criminal warrant,
local police should not be liable if ICE makes any additional detentions after the discovery of an
immigration violation. Again, in this example, it would be unclear how local law enforcement
should limit their participation, In total, the task force exemption does not adequately protect
our ability to maintain these partnerships, even when the focus is on major crimes.
An equal, if not greater concern, is the unintended consequence SB 54 will have by preventing
ICE from conducting immigration enforcement operations in our jail facilities. Currently, jails in
California may allow ICE access to specified inmates, but the state agency overseeing the jail
must provide those inmates with a notification of their rights. Under SB 54, ICE will no longer
be allowed access to our jails for immigration enforcement purposes. As a result, ICE will be
forced to carry out more field operations in our communities. Even during targeted
Honorable Kevin de Leon
March 22, 2017
Page 3
immigration operations, this will result in more collateral detentions - where undocumented
individuals at the scene of an arrest and were not the initial targets are detained by ICE. These
collateral detentions often cause the most confusion and fear amongst our immigrant
communities, and any increase is likely to cause additional problems. Furthermore, forcing ICE
to make public arrests does not actually prevent detentions, but instead only increases the
likelihood of escalated situations that may lead to dangerous encounters in our neighborhoods.
Although SB 54 does allow state prisons and jails to notify the Federal Bureau of Investigations
of the release date of violent felons, or those in custody with violent felony priors, that does not
include those who may have multiple significant misdemeanors - such as spousal abuse or
child endangerment - and it still limits our ability to make the transfer in a safe custodial
setting. Clearly, the cost of removing
ICE from our jails, where they can focus solely on convicted criminals, does not outweigh any
perceived benefits to our immigrant communities.
California law enforcement agencies have no intention, or desire, to become the primary
enforcers of federal immigration law. Even under ongoing federal changes, local police will
keep doing what local police do best - partnering with our community members to ensure
everyone is protected. The City of Tustin does recognize that there is a balance that needs to be
struck on immigration enforcement - one that takes the focus away from those not posing a
threat, and allows law enforcement to expend resources protecting our communities from those
with ill -intent. Unfortunately, SB 54 will make it more difficult to work with our federal law
enforcement partners in apprehending dangerous criminals, and threatens to create more fear
in our communities by forcing federal immigration operations out of our jails and into our
communities. For those reasons, The City of Tustin must oppose SB 54.
Thank you for your consideration.
Thank
Dr. Allan Bernstein
Mayor
City of Tustin
EXHIBIT 2
RESOLUTION NO. 18-66
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
TUSTIN, CALIFORNIA, REAFFIRMING THE CITY'S MARCH
22, 2017 LETTER OF OPPOSITION TO SB 54
WHEREAS, the members of the City of Tustin City Council have taken an oath to
support and defend the Constitution of the United States and the Constitution of the State
of California; and
WHEREAS, the State of California has enacted Senate Bill 54, which the
Legislature calls the California Values Act ("SB 54"); and
WHEREAS, on March 21, 2017, prior to the enactment of SB 54, the City Council
of the City of Tustin unanimously directed that a letter opposing the proposed law be sent
to the State Legislature; and
WHEREAS, on March 22, 2017, the Mayor of the City of Tustin dispatched a letter
to the President Pro Tempore of the State Senate voicing the City's opposition to SB 54.
A copy of that letter is attached hereto as Exhibit A; and
WHEREAS the City Council finds that among its key priorities is protecting the
safety of the public from those who commit violent crimes and other serious offenses, and
that undocumented immigrants who commit such crimes should be subject to Federal
immigration laws.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF TUSTIN, DOES
RESOLVE, DECLARE, DETERMINE AND ORDER that the City Council hereby reaffirms
its March 22, 2017 letter opposing SB 54.
ELWYN A. MURRAY
Mayor
�rr��5
ERICA N. YASUDA
City Clerk
Resolution No. 18-66
Page 1 of 3
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) SS
CITY OF TUSTIN )
I, Erica N. Yasuda, City Clerk and ex -officio Clerk of the City Council of the City of Tustin,
California, do hereby certify that the whole number of the members of the City Council of
the City of Tustin is five; that the above and foregoing Resolution No. 18-66 was duly passed
and adopted at a regular meeting of the Tustin City Council, held on the 4th day of
September, 2018, by the following vote:
COUNCILMEMBER AYES:
COUNCILMEMBER NOES:
COUNCILMEMBER ABSTAINED:
COUNCILMEMBER ABSENT:
ERICA N. YASUDA
City Clerk
Resolution No. 18-66
Page 2 of 3
Exhibit A
Letter Dated March 22, 2017 Opposing SB 54
Resolution No. 18-66
Page 3 of 3
EXHIBIT A
Office of the City Council
March 22, 2017
Honorable Kevin de Leon
California State Senate
California State Capitol
Sacramento, CA 95814
RE: Senate Bill 54 (Oppose as amended 3/6/17)
Senate President Pro Tempore de Leon:
The City of Tustin regrets to inform you of our opposition to Senate Bill (SB) 54, which would
limit California law enforcement from using agency or department moneys, facilities, property,
equipment, or personnel to investigate, interrogate, detain, detect, or arrest persons for
immigration enforcement purposes. Although immigration enforcement is not the duty of state
or local law enforcement, these restrictions will have negative consequences and threaten to
create safety concerns within our communities.
Public safety is the primary concern of local law enforcement, not immigration. Legally,
California's law enforcement agencies lack the authority and jurisdiction to enforce federal
immigration law. Beyond the legal limitations, any attempt by local law enforcement to target
non -criminals for immigration violations would only erode public trust and curtail the ability of
our departments to carry out their primary mission. Because community relationships are so
important, the California Police Chiefs Association has a track record of standing behind
California's large immigrant community, which includes supporting legislation to allow
undocumented immigrants to obtain a driver license, and shield victims of human trafficking
from deportation. However, there are instances when providing public safety entails partnering
with federal law enforcement agencies, including immigration enforcement.
Consistent with existing state laws and current department procedures, we strongly believe that
undocumented immigrants who commit violent and serious offenses against members of our
community should be subject to the immigration laws of this country. By doing so, we prevent
dangerous individuals from creating more victims - including within our own immigrant
communities. As such, our departments routinely engage with federal law enforcement
agencies - including Immigration and Customs Enforcement (ICE) and Homeland Security
Investigations (HSI) - for the purpose of eliminating drugs, violence, and crime from our
streets.
Mayor Dr. Allan Bernstein • Mayor Pro Tem Al Munn -ay • Rebecca "Beckie" Gomez • Charles E. "Chuck" Puckett • Letitia Clark
300 Centennial Way, Tustin, CA 92780 a (714) 573-3010 9 www tustima.org
Honorable Kevin de Leon
March 22, 2017
Page 2
Currently, local law enforcement agencies have the discretion to partner with ICE or HSI, and
do so through targeted operations to apprehend identified criminals. For example, ICE may
request tactical support from a local police department during an operation to arrest members
of a gang or drug cartel for civil or criminal immigration violations, Additionally, local law
enforcement also engages in federal joint task forces with various federal law enforcement
agencies, including ICE and HSI. These task forces all focus on organized crime, human
trafficking and national security however, immigration enforcement often plays a role in
carrying out those missions. For instance, if during a joint investigation into a drug trafficking
operation, HSI or ICE identifies one of the suspects as an individual with an immigration
violation, the task force may use that violation to apprehend that suspect. In those such
instances, it is typical for local law enforcement to supply information, resources, or even
manpower to physically assist in making the arrest. In every case, these are fluid and dynamic
partnerships that require constant communication.
SB 54 creates roadblocks, hurdles, and ambiguity when it comes to local law enforcement's
participation in any of the examples above. Under the proposed Government Code Section
7284.6(b)(2), SB 54 does appear to exempt local law enforcement agencies who are
"(p)articipating in a joint law enforcement task force, so long as the purpose of the joint law
enforcement task force is not immigration enforcement" However, what this section does not
clearly elucidate what "the purpose" of the task force would be considered.
The intent of SB 54 is to prevent local law enforcement from ANY immigration enforcement, so
it is unclear whether 7284.6(b)(2) distinguishes the overall purpose of the federal -state
collaboration from the incidental operations that may be utilized to achieve that purpose. In the
task force example from above, it is unclear whether "the purpose" would be considered
reducing drug trafficking (the overall mission), or immigration enforcement (the operation). If
the latter, it is also unclear what reduced role local law enforcement would have to take in the
task force - would we be forced to simply recuse ourselves from making the physical arrest, or
would we be forced to sever all ties with the operation at that point, including blocking any
information sharing? Moreover, during a collaboration with ICE to serve a criminal warrant,
local police should not be liable if ICE makes any additional detentions after the discovery of an
immigration violation. Again, in this example, it would be unclear how local law enforcement
should limit their participation. In total, the task force exemption does not adequately protect
our ability to maintain these partnerships, even when the focus is on major crimes.
An equal, if not greater concern, is the unintended consequence SB 54 will have by preventing
ICE from conducting immigration enforcement operations in our jail facilities. Currently, jails in
California may allow ICE access to specified inmates, but the state agency overseeing the jail
must provide those inmates with a notification of their rights. Under SB 54, ICE will no longer
be allowed access to our jails for immigration enforcement purposes. As a result, ICE will be
forced to carry out more field operations in our communities. Even during targeted
Honorable Kevin de Leon
March 22, 2017
Page 3
immigration operations, this will result in more collateral detentions - where undocumented
individuals at the scene of an arrest and were not the initial targets are detained by ICE. These
collateral detentions often cause the most confusion and fear amongst our immigrant
communities, and any increase is likely to cause additional problems. Furthermore, forcing ICE
to make public arrests does not actually prevent detentions, but instead only increases the
likelihood of escalated situations that may lead to dangerous encounters in our neighborhoods.
Although SB 54 does allow state prisons and jails to notify the Federal Bureau of Investigations
of the release date of violent felons, or those in custody with violent felony priors, that does not
include those who may have multiple significant misdemeanors - such as spousal abuse or
child endangerment - and it still limits our ability to make the transfer in a safe custodial
setting. Clearly, the cost of removing
ICE from our jails, where they can focus solely on convicted criminals, does not outweigh any
perceived benefits to our immigrant communities.
California law enforcement agencies have no intention, or desire, to become the primary
enforcers of federal immigration law. Even under ongoing federal changes, local police will
keep doing what local police do best - partnering with our community members to ensure
everyone is protected. The City of Tustin does recognize that there is a balance that needs to be
struck on immigration enforcement - one that takes the focus away from those not posing a
threat, and allows law enforcement to expend resources protecting our communities from those
with ill -intent. Unfortunately, SB 54 will make it more difficult to work with our federal law
enforcement partners in apprehending dangerous criminals, and threatens to create more fear
in our communities by forcing federal immigration operations out of our jails and into our
communities. For those reasons, The City of Tustin must oppose SB 54.
Thank you for your consideration.
Thank
Dr. Allan Bernstein
Mayor
City of Tustin
EXHIBIT 3
RESOLUTION NO. 18-67
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
TUSTIN, CALIFORNIA, DECLARING THE CITY'S
SUPPORT TO REPEAL PROPOSITION 47
WHEREAS, Proposition 47 (entitled the "Reduced Penalties for Some Crimes
Initiative") was enacted by the voters in November 2014; and
WHEREAS, Proposition 47 reduced certain crimes from felonies to misdemeanors
and authorized re -sentencing for those then serving a prison sentence for any of the
offenses that the initiative reduced to misdemeanors; and
WHEREAS, one result of the enactment of Proposition 47 has been the early
release from prisons throughout the state of thousands of individuals who had been
convicted of certain felonies but whose crimes were retroactively reduced to
misdemeanors; and
WHEREAS, in the three years prior to the implementation of Proposition 47 (2012-
2014), the average number of Part I crimes reported in Tustin was 2,079 per year; and
WHEREAS, in the three years after implementation of Proposition 47 (2015-2017)
the average number of Part 1 Crimes reported in Tustin averaged 2,401, reflecting a
15.5% increase in those crimes reported since the implementation of Proposition 47; and
WHEREAS the City Council finds that among its key priorities is protecting the
safety of the public from those who commit violent crimes and other serious offenses, and
that the earlier release of criminals as a result of Proposition 47 increases the risk of crime
in communities throughout California, including Tustin.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF TUSTIN, DOES
RESOLVE, DECLARE, DETERMINE AND ORDER that the City Council supports the
repeal of Proposition 47.
ELWYN A. MURRAY
Mayor
ATTEST:
ERICA N. YASUDA
City Clerk
Resolution No. 18-67
Page 1 of 2
1341638.1
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) SS
CITY OF TUSTIN )
I, Erica N. Yasuda, City Clerk and ex -officio Clerk of the City Council of the City of Tustin,
California, do hereby certify that the whole number of the members of the City Council of
the City of Tustin is five; that the above and foregoing Resolution No. 18-67 was duly passed
and adopted at a regular meeting of the Tustin City Council, held on the 4th day of
September, 2018, by the following vote:
COUNCILMEMBER AYES:
COUNCILMEMBER NOES:
COUNCILMEMBER ABSTAINED:
COUNCILMEMBER ABSENT:
ERICA N. YASUDA
City Clerk
Resolution No. 18-67
Page 2 of 2
1341638.1
EXHIBIT 4
Clarifying the Record Regarding Tustin and SB 54
Q: 'Why doesn't the Tustin City Council declare its opposition to SB 54?
A. The Tustin City Council has already declared its unanimous opposition to SB 54,
in a 2017 public meeting of the Council, and in a public letter sent to the State
Legislature.
Q: Is the City's letter opposing SB 54 being kept secret?
A. No, the letter is and always has been shared publicly, and the public can view it
here: [insert link]
Q: Is the City of Tustin a "sanctuary city"?
A. No. The Tustin City Council has never declared Tustin to be a sanctuary city.
Q. Has SB 54 had any practical impact on the ways in which the Tustin Police
Department protects the residents and businesses in the City?
A. No.
Q: Doesn't SB 54 affect who the Tustin Police Department notifies when it releases
inmates from jail?
A. Tustin doesn't operate a jail and is not involved in the process of releasing
inmates from jail. The Tustin Police Department books inmates into the County
jail system operated by Orange County Sheriff. The Orange County Sheriff, in
turn, publishes on the Internet the information on all inmates who are scheduled
to be released, regardless of their immigration status. Federal officials have full
access to that public information online.
Q. Does Tustin coordinate with Federal authorities (including immigration authorities)
about gangs, murderers, rapists and other serious felons?
A. Yes, SB 54 does not prevent coordination with Federal immigration or other law
enforcement authorities about gangs or others convicted of murder, rape or other
serious felonies. Tustin Police officers continue to communicate with all relevant
Federal agencies in the same manner they always have to protect the public, and
the Tustin Police Department will continue to participate in coordinated law
enforcement raids cracking down on gangs and other felons even if legal or illegal
immigrants may be involved.
Q. If Tustin doesn't declare its opposition to SB 54, will law -breaking immigrants flock
to Tustin?
A. Tustin has declared its opposition to SB 54, and Tustin continues to enforce the
laws protecting its residents and businesses in the same manner it did before SB
54 was adopted. Individuals who break the law and endanger the public, whether
they are immigrants or not, will find no sanctuary in Tustin.
Q. Does the Tustin City Council support the United States Constitution?
A. Absolutely! Each Council member supports the U.S. Constitution and has sworn
the following oath as required by California law:
"I, , do solemnly swear (or affirm) that I will support and
defend the Constitution of the United States and the Constitution of the
State of California against all enemies, foreign and domestic; that I will
bear true faith and allegiance to the Constitution of the United States and
the Constitution of the State of California; that I take this obligation freely,
without any mental reservation or purpose of evasion; and that I will well
and faithfully discharge the duties upon which I am about to enter."
Q: Doesn't that oath mean the City must fight every State law that may be preempted by
the Federal Constitution or Federal law?
A. No, the Tustin City Council has already unanimously declared its opposition to SB
54 in a public meeting and in writing, and supporting and defending the
Constitution does not require the City to go further by spending Tustin's limited
taxpayer dollars on litigation whenever a State law may be inconsistent with a
Federal law. Must cities expend limited public resources fighting the legalization
of cannabis in California, for instance, simply because that law may be
inconsistent with Federal law? No. SB 54 is already being aggressively
challenged in Federal Court in Fresno by the Federal Government and other well -
funded organizations. As explained above, SB 54 does not affect how Tustin's
Police Department goes about protecting the public and enforcing the law in
Tustin, and Tustin prefers to invest its law enforcement funds and resources here
at home, in support of that continuing commitment to public safety.