Existing law authorizes the county board of supervisors on behalf of the sheriff, and the legislative body of any city on behalf of the chief of police, to contract to provide supplemental law enforcement services to private schools, private colleges, or private universities on an occasional or ongoing basis. Existing law also requires full reimbursement to the county or city for its actual costs in providing these services. Existing law requires, prior to contracting for these ongoing services to be provided to a private school, private college, or private university, that the board of supervisors or legislative body, as applicable, discuss the contract and the legal requirements of those contracts at a duly noticed public hearing. Existing law also specifies that certain public university and college police departments certified by the Commission on Peace Officer Standards and Training are not prevented from entering into agreements with private schools, private colleges, or private universities to provide law enforcement services.

This bill would create a private schools law enforcement grant program to be administered by the Board of State and Community Corrections. The bill would require the board to award grants to local law enforcement agencies to provide supplemental law enforcement services to private schools, as provided. The bill would appropriate $10,000,000 from the General Fund to the Controller for allocation to local governmental entities for the provision of supplemental law enforcement services to private schools, private colleges, or private universities pursuant to the provision described above. board for these purposes.

Existing law authorizes the county board of supervisors on behalf of the sheriff, and the legislative body of any city on behalf of the chief of police, to contract to provide supplemental law enforcement services to private schools, private colleges, or private universities on an occasional or ongoing basis. Existing law also requires full reimbursement to the county or city for its actual costs in providing these services. Existing law requires, prior to contracting for these ongoing services to be provided to a private school, private college, or private university, that the board of supervisors or legislative body, as applicable, discuss the contract and the legal requirements of those contracts at a duly noticed public hearing. Existing law also specifies that certain public university and college police departments certified by the Commission on Peace Officer Standards and Training are not prevented from entering into agreements with private schools, private colleges, or private universities to provide law enforcement services.

This bill would appropriate $10,000,000 from the General Fund to the Controller for allocation to local governmental entities for the provision of supplemental law enforcement services to private schools, private colleges, or private universities pursuant to the provision described above.

Date of Hearing: April 5, 2017

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Lorena Gonzalez Fletcher, Chair

ABPCA Bill Id:AB 927

Author:(Levine) – As Amended Ver:March 23, 2017

Urgency: No State Mandated Local Program: No Reimbursable: No

SUMMARY:

This bill creates a GF supported grant program to pay for supplemental law enforcement services at private schools. Specifically, this bill:

1. Appropriates $10 million from the GF to the Board of State and Community Corrections (BSCC) to establish a law enforcement grant program to provide supplemental law enforcement services to private schools.
2. Requires BSCC to develop guidelines for the program that establish an application process and application criteria, and directs the BSCC, in evaluating and awarding grants, to consider certain factors.
3. Makes any city or county law enforcement agency, including a city police department, or a county sheriff’s office, eligible to apply for a grant.
4. Restricts the grant program to the purpose of supporting local law enforcement agencies that provide supplemental law enforcement services to private schools in their jurisdictions, with priority to those agencies that identify a heightened risk of violence, hate crimes, or other criminal activity to specific private schools, or to the students, teachers, parents, or staff at those schools.

FISCAL EFFECT:

1. $10 million GF appropriation.
2. Administrative costs to BSCC in the hundreds of thousands of dollars to develop program guidelines, evaluate applications, and monitor progress of awarded grants.
3. GF cost pressure in future years to the extent it is a priority to provide ongoing grant funding, as opposed to one-time grants.

COMMENTS:

1. Purpose. This bill would create a grant program, using GF monies to pay for supplemental law enforcement services at private schools. According to the author, the bill would keep children who attend private schools safe and protect them from fear of hate crimes and anxiety about the recent increase of hate crimes.
2. Need for Supplemental Law Enforcement is Unclear. There has not been a comprehensive study of the need for supplemental law enforcement services at private schools. Local law enforcement agencies generally are trained and prepared to respond to crimes and other incidents as part of their regular duties. At this time it is unclear whether law enforcement agencies in the state lack the resources necessary to provide an appropriate level of service to private schools in their jurisdiction. Without a better understanding of the potential problem, it unclear to what extent supplemental law enforcement services are needed and whether this bill would provide too much funding or not enough funding. In addition, this bill provides a one-time appropriation of funds to create a new program, however, it is unclear whether the provision of supplemental law enforcement services as envisioned in this bill would be temporary or would require additional funds in the future to provide ongoing services.
3. Private Schools Typically Not Funded by State. Private schools typically are funded by tuition, donations, and other private sources. Because private schools do not generally receive state funding, they are not subject to the same restrictions and requirements as public schools. While this bill would not give funding directly to private schools it would fund local law enforcement to provide services to benefit private schools. This has the effect of transferring some costs associated with private schools to the state.

Analysis Prepared by: Jessica Peters / APPR. / (916) 319-2081

Date of Hearing:

ASSEMBLY COMMITTEE ON

, Chair

ABPCA Bill Id: (

Author:) – As Ver:

As Proposed to be Amended

SUBJECT:

KEY ISSUE: SHOULD THE STATE OF CALIFORNIA PROVIDE A GRANT PROGRAM, USING PUBLIC MONEY, FROM THE STATE’S GENERAL FUND, THAT WOULD PAY FOR SUPPLEMENTAL LAW ENFORCEMENT SERVICES AT PRIVATE SCHOOLS?

SYNOPSIS

This bill seeks to create a grant program, using public funds from the state’s General Fund, to pay for supplemental law enforcement services at private schools. The bill is necessary, according to the author, in order to keep children (who attend private schools) safe and to protect them from fear of hate crimes and anxiety about the recent increase of hate crimes. According to the author, several states and the federal government provide public funding to private schools, specifically for supplemental law enforcement services. The programs operate in at least three states: Pennsylvania, New Jersey. The bill’s proposal to create a grant program that would fund supplemental law enforcement services at private schools builds on recently enacted and somewhat controversial legislation that expanded the authority for the use of supplemental law enforcement services to private schools, colleges, and universities and further expanded the ability of Level 1 reserve peace officers to provide those services. SB 872 (Hall) Chapter 362, Statutes of 2016, allowed Level 1 reserve peace officers to provide contracted services at private schools, colleges and universities--on an occasional or ongoing basis--as long as the county or city and the private institution mutually agree.

The bill as currently in print makes several legislative findings suggesting that the bill is primarily concerned with funding security at religious schools, not just private schools. Although the author has proposed to remove these findings from the bill, the background material provided by the author to the Committee, and all the letters of support, focus almost entirely on attacks on religious schools. These constitute part of the legislative history and must be considered in any constitutional analysis of the bill. As explained in detail in this analysis, this history raises some troubling First Amendment concerns: even though the bill applies to all private schools, most private schools are religious schools, and the legislative history makes it clear that the bill is primarily concerned with religious schools. Ultimately, it is irrelevant that some portion of the private schools covered by the bill will be secular, because a substantial number of the private schools were religious schools and therefore the subsidy would entail government support of, and potential entanglement with, religion. Fittingly, perhaps, the bill is supported by numerous religiously affiliated schools. It is opposed by the ACLU, which notes the negative consequences of additional law enforcement interactions with students in school settings; and Root & Rebound, which alleges that the bill will not “serve to protect and improve the health and safety of all members of California Communities.”

SUMMARY: Seeks to create a grant program, using public funds from the state’s General Fund, to pay for supplemental law enforcement services at private schools. Specifically, this bill:

1. Appropriates the sum of ten million dollars ($10,000,000) from the state’s General Fund to the Board of State and Community Corrections to establish a law enforcement grant program for the provision of supplemental law enforcement services to private schools.
2. Creates a private schools law enforcement grant program to be administered by the Board of State and Community Corrections.
3. Provides that the Board shall award grants to local law enforcement agencies to provide supplemental law enforcement services to private schools.
4. Requires the Board to develop guidelines for the program that establish an application process and application criteria and direct the Board, in evaluating and awarding grants, to consider the following factors:
   1. The number of private schools in the jurisdiction.
   2. The number of prior incidents at private schools in the jurisdiction that required a local law enforcement response.
   3. The number of prior incidents at private schools in the jurisdiction when, according to the applicant, local law enforcement resources were inadequate and additional law enforcement resources were required to supplement those resources in order to adequately protect public safety.
5. Makes any city or county law enforcement agency, including a city police department, or a county sheriff’s office, eligible to apply for a grant.
6. Restricts the grant program to the purpose of supporting local law enforcement agencies that provide supplemental law enforcement services to private schools in their jurisdictions, with priority to those agencies that identify a heightened risk of violence, hate crimes, or other criminal activity to specific private schools, or to the students, teachers, parents, or staff at those schools.
7. Requires any supplemental law enforcement services that are provided pursuant to the grant program to comply with the requirements of paragraph (4) of subdivision (a) of Section 53069.8 of the Government Code.

EXISTING LAW:

1. Provides, pursuant to the California Constitution, that “maximizing the educational opportunities and protecting the health and safety” of students in California is a responsibility of the State of California. (Cal. Const., Art. I, sec. 7, subd. (a).)
2. Authorizes the board of supervisors of any county to contract on behalf of the sheriff of that county, and the legislative body of any city may contract on behalf of the chief of police of that city, to provide supplemental law enforcement services to a number of private individuals and entities, including “Private schools, private colleges, or private universities on an occasional or ongoing basis.” (Gov. Code 53069.8 (a)(4). All further statutory references are to the Government Code, unless otherwise indicated.)
3. Requires contracts entered into pursuant to 2), above, to provide for full reimbursement to the county or city of the actual costs of providing those services, as determined by the county auditor or auditor-controller, or by the city, as the case may be. (Section 53069.8 (b).)
4. Requires the services to be rendered by regularly appointed full-time peace officers, including reserve peace officers and any other peace officers who are authorized to exercise the powers of a peace officer, upon mutual agreement between the provider and the private school, private college, or private university. (Section 53069.8 (c)(1).)
5. Allows services provided in connection with special events or occurrences to be rendered by Level I reserve peace officers who are authorized to exercise the powers of a peace officer, if there are no regularly appointed full-time peace officers available to fill the positions as required in the contract. (Section 53069.8 (c)(1).)
6. Prohibits the contracting for law enforcement services from reducing the normal and regular ongoing service that the county, agency of the county, or city otherwise would provide. (Section 53069.8 (f).)
7. Requires that prior to contracting for ongoing services under 2), above, the board of supervisors or legislative body, as applicable, to discuss the contract and the requirements above at a duly noticed public hearing. (Section 53069.8 (g).)
8. Allows a school police department that is appointed pursuant to provisions of the Education Code, and certified by the Commission on Peace Officer Standards and Training, to enter into agreements with private schools, private colleges, or private universities to provide law enforcement services. (Section 53069.8 (h).)

FISCAL EFFECT: As currently in print this bill is keyed fiscal.

COMMENTS: This bill seeks to create a grant program, using public funds from the state’s General Fund, to pay for supplemental law enforcement services at private schools. The bill is necessary, according to the author, in order to keep children (who attend private schools) safe and to protect them from fear of hate crimes and anxiety about the recent increase of hate crimes:

Children should not be sent to school in fear. California can stand up to protect centers of learning of all faiths from hate crimes. AB 927 will provide funding to enhance security at schools so students and their parents can feel safe and focus on learning.

Public funding for private school security in other states and from the federal government. According to the author, several states and the federal government provide public funding to private schools, specifically for supplemental law enforcement services. The programs operate in at least three states: Pennsylvania, New Jersey, and New York. The author provides the following examples

• Pennsylvania School Police Officer Grant Program

Pennsylvania’s Office for Safe Schools operates a program where private schools can apply for $40,000 grant to hire a school police officer. Schools must hire the school police officer through a state-approved vendor, and the grant money is paid directly to the chosen vendor. Funding levels are set by the annual budget process, with $1.6 million available in the 2016-2017 school year; of that, grants were awarded to three private school, all of which are Jewish schools.

• New Jersey “Secure Schools for All Children Act”

New Jersey provides private schools $75 per student to spend on security services, equipment, and technology. Each year, private schools contact their school districts and request their preferred security services or equipment, and the school districts then purchase those services on behalf of the private schools. The funding amount per student will increase each year based on the inflation rate.

• New York State Nonpublic School Security Funding Program

The New York State Education Department reimburses private schools for a portion of their security personnel, training, and equipment expenses. This program – and its funding level – is re-approved each year during the budget process. The amount each school is receives depends on enrollment and the amount appropriated in the budget process – $15 million (or about $32.6 per student) was approved in the 2017-18 budget.

• New York City Nonpublic School Security Guard Program

New York City reimburses private schools the cost of hiring a number of security guards, with reimbursement levels based on school enrollment (see chart below) and the prevailing wage of NYC security guards (roughly $39,603 per guard in 2016). Schools must hire guards through a city-approved vendor. The law establishes a funding floor of $19.8 million per school year, and the City Council may add funding on a year-by-year basis through the budget process.

In addition, the State of New York recently announced a new $25 million grant program to boost safety and security at New York’s schools and day care centers at risk of hate crimes or attacks because of their ideology, beliefs or mission. The grant program will provide funding for additional security training needs, cameras and state-of-the-art technology, door-hardening, improved lighting and other related security upgrades. (https://www.governor.ny.gov/news/governor-cuomo-announces-new-actions-combat-hate-crimes-and-anti-semitism-across-new-york-state) However, unlike the other programs above, there is no indication that the grants are available only to private schools.

Finally, according to the author, the Department of Homeland Security provides grants to public and private schools to assist with disaster and emergency preparedness. According to the author, California has matched such funds in the past.

Background about supplemental security services provided to private individuals and entities, including private schools, colleges, and universities. Counties and cities were first granted authority to provide supplemental law enforcement services to private individuals or entities in 1982, when the Legislature allowed counties and cities to provide these services under contract to preserve the peace at special events or occurrences that happen on an occasional basis. This authority was apparently granted for the Los Angeles Summer Olympics. These services were required to be provided by regularly appointed full-time peace officers.

This authority was substantially expanded by SB 1313 (Margett), Chapter 224, Statutes of 2002. SB 1313 added two new private groups for which counties or cities may provide supplemental law enforcement services: 1) Private nonprofit corporations that are recipients of federal, state, county, or local government low-income housing funds or grants (codified as Section 53069.8 (a)(1)); and, 2) Private entities at critical facilities, defined as any building, structure, or complex that, in the event of a disaster, poses a threat to public safety, including, but not limited to, airports, oil refineries, and nuclear and conventional fuel power plants (codified as Section 53069.8 (a)(3)). SB 1313 also allowed these two new categories of contracts to occur on an ongoing basis, rather than being limited to an occasional basis.

AB 2164 (La Suer), Chapter 87, Statutes of 2006, allowed all of these services to be provided by Level I reserve peace officers if no regularly appointed full-time peace officers were available to fill the positions as required by the contract. The Senate Public Safety Committee, in its analysis of AB 2164, quoted an Opinion by the California Attorney General about this issue in 1985:

When the police act, then, they perform public governmental functions that are fundamental to the principal purpose of any representative government, to wit, the protection of the people. And when they act, they do so on behalf and in the name of the people. In short, they and other law enforcement agencies act as the people's representatives in the enforcement of the people's laws, and the duty they own in that regard is to the public generally (within a respective territorial jurisdiction) and not to any particular segment or person. An assault or theft works the same duty on the police whether the victim be prince or pauper. . . .The sale of police services is not only antithetical to the notion of a public law enforcement function, but it also violates sound public policy, expressed in Penal Code Section 70, subdivision (a), by making law enforcement services subservient to those who would pay for them. . . .The influence of such payments is as potentially corrupting on city or county officials deploying their police forces as it is on the actions of the individual officers, and time and again we have inveighed against it as providing fertile field for a possible conflict of interest. Inevitably too, such payments lead to the concentration of police services for those who make the payments and a diminution of police services for the rest of the community. The end result would be a system of law enforcement which could not rightly be called a public service. (68 Op. Atty. Gen. Cal. 175 (1985) [Emphasis added and citations omitted].)

Just last year, the Legislature expanded the use of supplemental law enforcement services to private schools, colleges, and universities in Senate Bill 872 (Hall) Chapter 362, Statutes of 2016 and further expanded the ability of Level 1 reserve peace officers to provide those services. Prior to SB 872 becoming law, most contracts for supplemental law enforcement services were required to be fulfilled with regularly appointed full-time peace officers, as explained above. Also, there was only one exception that allowed Level 1 reserve peace officers to provide supplemental law enforcement services prior to SB 872 becoming law: at special events or occurrences that happen on an occasional basis, if no regularly appointed full-time peace officers were available; and contracts for ongoing services were limited to regularly appointed full-time peace officers. SB 872 allowed Level 1 reserve peace officers to provide contracted services at private schools, colleges and universities--on an occasional or ongoing basis--as long as the county or city and the private institution mutually agree.

According to the Assembly Local Government Committee’s analysis of SB 872, the California Association of Private School Organizations (CAPSO), which represents K-12 non-profit private educational institutions, had concerns about SB 872 and—perhaps most importantly for purposes of this bill—saw no evidence of the need for supplemental law enforcement services on the campuses of private schools:

We are concerned that the opportunity to offer law enforcement services through a contract can introduce a financial incentive that might induce a law enforcement agency to delay, reduce, or withhold the normal and regular ongoing services to which all Californians are entitled. Moreover, our Public Policy Committee is unaware of any CAPSO-affiliated private K-12 school that is currently seeking additional law enforcement services that are not already permissible under existing law.

Despite these concerns, SB 872 was approved by the Legislature and signed into law by the Governor. CAPSO has not weighed in on this bill, but the Committee has no evidence that their opinion—there is no evidence to support the need for supplemental law enforcement services on the campuses of private schools—has changed.

First Amendment Concerns. Section I of the bill in print, which is proposed to be omitted by the author, makes several legislative findings. These findings suggest that the bill is primarily concerned with funding security at religious schools, not just private schools. For example, the findings claim that terror groups are "targeting Christians and Jews because of their faith. Many Islamic schools and Muslims are now being threatened because of the actions of terror groups abroad." The findings go on to assert that this "state of affairs threatens religious institutions and schools, and puts them at an increased risk due to the effect of ongoing conflicts in the world." [Emphasis added.] In short, it appears that the request for additional security funding at private schools is primarily motivated by concern for security at private religious schools. Although the author has proposed to remove these findings from the bill, the background material provided by the author to the Committee, and all the letters of support, focus almost entirely on attacks on religious schools. These constitute part of the legislative history and must be considered in any constitutional analysis of the bill.

The Establishment Clause. The two religion clauses of the First Amendment, as applied to the states by the Fourteenth Amendment, prohibit any government actor – federal, state, or local – from enacting or enforcing any law "respecting the establishment of religion, or prohibiting the free exercise thereof." The “establishment” and “free exercise,” as has often been noted, bear an uneasy relationship to each other. Most likely, the Establishment clause was originally intended to prevent the newly-created national government from establishing an official national church, akin to the Church of England. Over time, however, the Establishment clause expanded to mean not only that the government may not establish an official religion, but also to prevent government from taking any actions that support or favor one religion over another, or that favor religion over non-religion. Similarly, the Free Exercise clause originally meant that government could not persecute a person for practicing his or her religion, but overtime has come to mean that government shall not “burden” the right to practice one’s religion or discriminate against a person because of his or her religion.

The tension between the two clauses could be seen in one of the most important religion clauses cases of the twentieth century. In Everson v. Board of Education (1947) the U.S. Supreme Court was asked to decide whether a statute that subsidized transportation costs of students who were enrolled in private schools could be offered to students attending religious schools. On the one hand, to provide the subsidy to the parents of religious students could violate the Establishment clause by using public money to aid religious students, parents, and schools. On the other hand, to deny benefits to religious school parents that were available to non-religious private school parents could violate the Free Exercise clause by discriminating against, or placing an unequal burden on, religious students and schools. Recognizing the competing demands of the establishment and free exercise clauses, a divided Court upheld the statute by a 5-4 vote. The state could not, the Court reasoned, deny a government benefit to a religious group if the benefit were available to all other similarly situated groups. To do so would be religious discrimination and therefore violate the Free Exercise clause. The Court noted, for example, that a tax-supported fire department could not refuse to respond to a fire at a private school just because it was a religious school. Religious people, after all, are tax-payers as well, and they pay school taxes whether their children attend a public school or not. (Everson v. Board of Education (1947) 330 U.S. 1.)

To the extent that it creates a special fund that will be used only at private schools, this bill creates an interesting twist on the Everson fact pattern. In this bill, the question is not whether a religious institution may be excluded from an otherwise generally available government benefit. To the contrary, the question is whether a government benefit may be used only at private schools, keeping in mind that most private schools are religious schools. A critical test of this question came before the U.S. Supreme Court in Lemon v. Kurtzman (1971). In that consolidated case, the U.S. Supreme Court considered the constitutionality of a Pennsylvania statute that provided financial support to private schools by reimbursing teacher salaries, textbooks, and other educational materials. A Rhode Island statute directly supplemented the salaries of certain private school teachers. Facially, both statutes applied to private schools, religious or secular; however, in each state most of the subsidy went to religious schools. The Court looked beyond the seeming neutrality on the face of the statute and treated the case as implicating the religion clauses of the First Amendment. The mere fact that some of the private schools are secular rather than religious schools is not enough to ward off a First Amendment challenge. (Lemon v. Kurtzman (1971) 403 U.S. 602.) This point is highly relevant for this bill, because even though the bill applies to all private schools, most private schools are religious schools, and the legislative history makes it clear that the bill is primarily concerned with religious schools.

Lemon v. Kurtzman is best known for developing the three-part "Lemon Test." Under that test, any statute or policy that provides direct or indirect tax-funded benefits to a religious school – or for that matter any religious institution – must meet the following criteria: (1) it must have a secular legislative purpose; (2) its principal effect must be one that neither advances nor inhibits religion; and (3) it must not foster an excessive government entanglement with religion.

As in most cases involving the religion clauses, applying this test is not a simple matter. For example, does AB 927 have a "secular legislative purpose?" First, as noted above, the fact that the substantive language does not mention religion does not mean that it has a secular purpose. When attempting to discern a purpose, the Court must necessarily look beyond the four corners of the statute to the legislative history. This bill’s findings and declarations, the author's statements, and the letters of support all suggest that this measure is primarily intended to protect private religious schools. On the one hand, the author could argue that even though the fund will benefit religious schools, it will nonetheless be used for the secular purpose of protecting students and promoting public safety. On the other hand, it is difficult to say that a fund used primarily if not exclusively at private religious schools, and not at all at public schools, has a truly secular purpose. After all, if the secular purpose is to protect students and promote public safety, then why would it be used only at private schools? Surely the kinds of attacks described by the author could take place in both public and private schools.

The second prong of the Lemon Test asks if the principal effect of the statute or policy either advances or inhibits religion. To be sure, protecting students from hate violence does not "advance" religion in the sense or promoting or endorsing religion generally or favoring one religion or religious idea over another. However, by limiting the supplemental funds to only private schools, the bill favors private religious (and private secular) schools over public schools. As in the case of any subsidy, this bill will advance the position of private religious schools. In the absence of a subsidy, a religious school would need to hire private security, using funds that could otherwise be used to advance the religious mission of the school. It is by no means obvious whether a court would find this subsidy more like the subsidy upheld in Everson, or more like the subsidies invalidated in Lemon.

Finally, the third prong of the Lemon Test asks if the statute or policy will create "excessive government entanglement" with religion. This bill certainly will create some degree of "entanglement." Whether it is "excessive" is another matter. That the funds do not go directly to the private schools but rather to public law enforcement agencies works in favor of the bill on this prong. If the local law enforcement agency retains complete discretion on how and where money is spent, then perhaps there would not be "excessive" entanglement with religion. On the other hand, there will necessarily be discussions, and perhaps even negotiations, with private religious schools about the level of service provided.

For a subsidy to survive constitutional scrutiny, it must satisfy all three prongs of the Lemon Test. The above analysis assumes, supported by existing case law, that a court will look beyond the words of the statute to its legislative history. Moreover, it does not matter that some portion of the private schools covered by the bill will be secular, because in Lemon the Court noted that a substantial number of the private schools were religious schools and therefore the subsidy would entail government support of, and potential entanglement with, religion.

Finally, even if the statute created by this bill is constitutional – and it may well be – there is still the question of whether this well-intentioned bill advances well-reasoned policy. The author's background information, for example, justifies this measure by citing reports that hate crimes have increased since the election of President Donald Trump. While some of these attacks have occurred in religious centers and schools, many more have not. For example, the author cites a report by the Southern Poverty Law Center (SPLC) documenting 867 hate crime incidents since the election. However, it is not clear how many of these attacks – even those that targeted religious groups – took place at private schools. The SPLC study found that 23% of the attacks came against African-American and another 14% were targeted at the LGBT community. If the heightened rhetoric associated with the President spurs more hate violence, as the author claims, there is no reason to believe that the violence will be directed primarily at private schools. Jewish, Muslim, African-American, Latino, Asian-American, undocumented immigrants, and LGBT students are just as likely to attend a public school as they are to attend a private school. Indeed, if the current climate generates more cultural, racial, and religious conflict, we might expect more attacks and violence at public schools because they are generally more culturally, racially, and religiously diverse than private schools. Therefore, it could be argued that a grant program should be available to public, as well as private, schools.

REGISTERED SUPPORT / OPPOSITION:

Support

Agudath Israel of California

Emek Hebrew Academy

Gindi Maimonides Academy

Islamic Center of Mill Valley

Orthodox Union Advocacy Center

Valley Torah High School

Yavneh Hebrew Academy

Yeshiva Rav Isacsohn Academy

Yula Boys High School

Opposition

American Civil Liberties Union of California

Root & Rebound

Analysis Prepared by: