Existing law makes it a crime to refuse or fail to leave land real property, or structures belonging to, or lawfully occupied by, another and not open to the general public, upon being requested to leave by a peace officer or the owner, as specified.

This bill would state that it is the intent of the Legislature to enact legislation to address trespassing on private property, as specified.

Date of Hearing:

Counsel: Ilan Zur

ASSEMBLY COMMITTEE ON PUBLIC SAFETY

Nick Schultz, Chair

ABPCA Bill Id:AB 1097

Author:(Ávila Farías) – As Amended Ver:March 17, 2025

SUMMARY:

Makes it a misdemeanor for a person to enter upon private property within 48 hours of the owner requesting that person to leave the premises or having received an order of exclusion from a tribal government. Specifically, this bill:

1. Makes it a misdemeanor, punishable by a county jail term of up to six months, a fine of up to $1,000 or both, to enter private property or Indian lands, including contiguous land, real property, private businesses, or structures belonging to the same owner, whether or nor not generally open to the public, within 48 hours of having been requested by the owner, operator, or agent of the premises to leave the premises or after receiving an order of exclusion from a tribal government.
2. States that a federally recognized Indian tribe may enter into an agreement with a law enforcement agency for services to enforce an order of exclusion issued pursuant to the above.
3. Expands the misdemeanor trespass crime of entering upon private property, whether or not generally open to the public, after having being informed by a peace officer at the request of the owner or the owners agent, that the peace officer is acting at the request of the owner, that the property is not open to the particular person, or failing to leave the property after being asked to leave the property, as specified, as follows:
   1. Clarifies this applies to entering upon Indian Lands.
   2. Specifies that this trespass crime applies to private businesses.
   3. Specifies that in the case of Indian lands or private property on Indian lands, that the person who may inform an individual that the property is not open to that particular person, may be a peace officer or a tribal police officer.
   4. Specifies that in the case of Indian lands, the peace officer or tribal officer may inform the individual that they are acting at the request of the tribe.
4. Defines the below terms as follows:
   1. “Federally recognized Indian tribe” means any Indian or Alaska Native tribe, band, nation, pueblo, village or community that the Secretary of the Interior acknowledges to exist as an Indian tribe.
   2. “Indian lands” means all land within the limits of any Indian reservation under the jurisdiction of the United States notwithstanding the issuance of any patent, and, including rights-of-way running through the reservation, all dependent Indian communities within the borders of the U.S. whether within the original or subsequently acquired territory thereof, and whether within or without the limits of a state, and all Indian allotments, the Indian titles to which have not been extinguished, including rights-of-way running through the same.
   3. “Order of exclusion” means a written order issued by a tribal government of a federally recognized Indian tribe prohibiting a person from entering the tribe’s Indian lands.
   4. “Tribal government” means a council, or its designated agency under tribal law that is primarily responsible for carrying out the federally recognized Indian tribe’s inherent sovereign power of self-governance and for controlling internal relations and territorial management.
5. Clarifies that the trespass crime of entering upon lands or buildings owed by another person without the license of the owner or legal occupant, where there are signs forbidding trespass displayed, and if are cattle, goats, pigs, sheep, fowl, or other animal being raised, bred, fed, or held on those lands for the purpose of food for human consumption, also applies to entering Indian lands, as defined.
6. Clarifies that the trespass crime of entering lands, whether unenclosed or enclosed by fence, for the purpose of injuring property or property rights or with the intention of interfering with, obstructing, or injuring a lawful business or occupation carried on by the owner of the land, the owner’s agent, or the person in lawful possession, also applies to entering Indian lands, as defined.

EXISTING FEDERAL LAW:

1. States that California has jurisdiction over offenses committed by or against Indians in Indian Country to the same extent that the State has jurisdiction over offenses committed elsewhere in the State. (18 U.S.C. § 1162.)
2. Provides that the criminal laws of California shall have the same force and effect within Indian country as they have elsewhere within the State. (Ibid.)
3. Authorizes tribal courts to exercise special tribal criminal jurisdiction over all people, concurrent with the criminal jurisdiction of the federal government and the state, for specified crimes, including, assault of tribal justice personnel, child violence, dating violence, domestic violence, obstruction of justice, sexual violence, sex trafficking, stalking, and a violation of a protective order. A tribe may not exercise this special jurisdiction if neither the defendant nor the victim is Indian. (25 U.S.C § 1304.)
   

EXISTING STATE LAW:

1. Provides that to improve the implementation of concurrent criminal jurisdiction on California Indian lands, the DOJ shall provide technical assistance to local law enforcement agencies that have Indian lands within or abutting their jurisdictions, and to tribal governments with Indian lands, including those with and without tribal law enforcement agencies, as specified. (Pen. Code, § 11070, subd. (a).)
2. Authorizes a law enforcement agency or court of a tribe to apply to the Attorney General for access to the California Law Enforcement Telecommunications System. (Gov. Code, § 15168, subd. (b).)
3. Allows cities and counties to enter into a contract with an Indian tribe to provide police or sheriff protection services for the Indian tribe either solely on Indian lands, or on the Indian lands and territory adjacent to those Indian lands. (Gov. Code, § 54981.7)
   
4. States that any person designated by a tribe, who is deputized or appointed by the county sheriff, is a peace officer, if the person and the person has completed the basic Commission on Peace Officer Standards and Training course. The authority of a peace officer pursuant to this subdivision includes the full powers and duties of a peace officer as specified in the above paragraph. (Pen. Code, § 830.6, subd. (b).)
5. Generally punishes trespass as a misdemeanor, punishable by a county jail term of up to six months, a fine of up to $1,000 or both. (Pen. Code, §§ 19, 602.)
6. Makes it a misdemeanor to willfully commit trespass by entering upon private property, including contiguous land, real property, or structures thereon belonging to the same owner, whether or not generally open to the public after: 1) having been informed by a peace officer at the request of the owner, their agent, or person in lawful possession, and upon being informed by the peace officer that the officer is acting at the request of the owner, their agent, or person in lawful possession, that the property is not open to the particular person; or 2) refusing or failing to leave the property upon being asked to leave the property, subject to the following:
   1. This crime applies only to a person who has been convicted of a crime committed upon the particular private property.
   2. A single notification or request to the person described above shall be valid and enforceable unless and until rescinded by the owner, the owner’s agent, or the person in lawful possession of the property.
   3. Where the person has been convicted of a violent felony, that notification or request applies without time limitation, if the person has been convicted of any other felony, this applies for no more than five years from the date of conviction, where the person has been convicted of a misdemeanor, this applies for no more than two years from the date of conviction, and where the person was convicted for an infraction, as specified, this applies for no more than one year from the date of conviction. (Pen. Code, §602, subd. (t).)
   4. Establishes numerous other trespass crimes, as specified. (Pen. Code, §602, subds. (a)-(y).
7. Provides that any person who intentionally interferes with any lawful business or occupation carried on by the owner or agent of a business establishment open to the public, by obstructing or intimidating those attempting to carry on business, or their customers, and who refuses to leave the premises of the business establishment after being requested to leave by the owner or the owner’s agent, or by a peace officer acting at the request of the owner or owner’s agent, is guilty of a misdemeanor, punishable by imprisonment in a county jail for up to 90 days, or by a fine of up to four hundred dollars ($400), or by both that imprisonment and fine, although this shall not apply to the following persons:
   1. Any person engaged in lawful labor union activities that are permitted to be carried out on the property by state or federal law.
   2. Any person on the premises who is engaging in activities protected by the California Constitution or the United States Constitution. (Pen. Code, § 602.1, subd. (c).)
      

FISCAL EFFECT:

Unknown

COMMENTS:

1. Author's Statement: According to the author, "Unfortunately, the seclusion tribes have learned to live with and the peace that they fought so long to obtain, has become threatened by trespassers. Additionally, this geographical seclusion has made it difficult to sustain an adequate number of law enforcement personnel to protect the lands. Trespassing on Indian lands places a significant safety risk on tribal families.

While California has existing law within California Penal Code Section 602 to protect against trespassing, this section of law does not explicitly include Indian lands as those protected under this statute. AB 1079 clarifies that federally recognized Indian Tribal lands are considered areas where trespassing would constitute a misdemeanor.”

1. Effect of this Bill: California’s primary trespass statute – Penal Code section 602 – has nearly an entire alphabet of subdivisions. (Pen. Code, 602.) Most of the subdivisions in Section 602 define separate crimes, typically each with slightly different elements than the other subdivisions. (Ibid.) Trespass is generally a misdemeanor, though California law does include a felony for aggravated trespass. (Pen. Code, § 602 subds. (k) & (l). For misdemeanor trespass, the penalty is up to six months of jail time or up to a $1,000 fine, or both. (Pen. Code, §§ 19, 602.)

Most relevant here is subdivision (t) which makes it a misdemeanor to willfully enter private property, including contiguous land, real property, or structures thereon, regardless of whether the land is generally open to the public after: 1) being informed by a peace officer at the request of the owner that the officer is acting at the request of the owner and that the property is not open to the particular person; or 2) refusing or failing to leave the property upon being asked to leave the property by the officer. (Pen. Code, §602, subd. (t)(1).).

This only applies to a person who has been convicted of a crime committed upon the particular private property. (Pen. Code, §602, subd. (t)(2).). Further, the notification by a peace officer, on behalf of an owner, that the property is not open to a particular person or a request for that person to leave the property, is valid and enforceable until rescinded by the owner, their agent, or the person in lawful possession of the property. (Pen. Code, §603, subd. (t)(3).) The amount of time that the notification or request remains in effect depends on the severity of the underlying crime. Where the person was convicted of a violent felony, that notification or request applies without time limitation, while if the person was convicted of any other felony, this applies for no more than five years from the date of conviction. (Pen. Code, §602, subd. (t)(4).). Additionally, if the person was convicted of a misdemeanor, this applies for no more than two years from the date of conviction. (Ibid.) If the person was convicted for an infraction, as specified, this applies for no more than one year from the date of conviction. (Ibid.)

AB 1097 would make several changes to California trespass law. First, it would create a new trespass misdemeanor, punishable by a county jail term of up to six months, a fine of up to $1,000 or both. (Pen. Code, §§ 19.) Specifically, it would make it a misdemeanor to enter private property or Indian lands, including contiguous land, real property, private businesses, or structures belonging to the same owner, whether or nor not generally open to the public, within 48 hours of having been requested by the owner, operator, or agent of the premises to leave the premises or after receiving an order of exclusion from a tribal government. Second, it would authorize a federally recognized Indian tribe to enter into an agreement with a law enforcement agency for services to enforce an order of exclusion issued pursuant to the above crime.

Third, it proposes to broaden the misdemeanor trespass crime of entering upon private property, whether or not generally open to the public, after having being informed by a peace officer at the request of the owner or the owners agent, that the peace officer is acting at the request of the owner, that the property is not open to the particular person, or failing to leave the property after being asked to leave the property, as specified, as follows:

• 1. Clarifies this applies to entering upon Indian Lands.
  2. Specifies that this trespass crime applies to private businesses.
  3. Specifies that in the case of Indian lands or private property on Indian lands, that the person who may inform an individual that the property is not open to that particular person, may be a peace officer or a tribal police officer.
  4. Specifies that in the case of Indian lands, the peace officer or tribal officer may inform the individual that they are acting at the request of the tribe.

1. California Criminal Trespass Laws Apply on Tribal Land: Under Public Law 280 (1953), California has jurisdiction over offenses committed by or against Indians in Indian Country to the same extent that the State has jurisdiction over offenses committed elsewhere in the State. (18 U.S.C. § 1162.) California’s criminal laws have the same force and effect within Indian country as they have elsewhere within the State. (Ibid.) In other words, the criminal laws of California, including criminal trespass laws, extend to Indian lands within the state.
   

Accordingly prosecutors and law enforcement may enforce criminal trespasses on Indian lands to the same extent they can enforce criminal trespass on property not located on Indian land. Given that Public Law 280 created concurrent jurisdiction over criminal offenses committed by or against Indians within Indian Country, tribal police may also enforce certain crimes on Indian land. Specifically, if the offender is non-Indian, and the victim is non-Indian or Indian or it is a victimless crime the state generally has exclusive jurisdiction. (Draper v. United States (1896) 164 U.S. 240). Alternatively, if the offender is Indian, and the victim is Indian or non-Indian, there is concurrent state and tribal jurisdiction, exclusive of the federal government. (Indian Civil Rights Act, 25 U.S.C. § 1301.) Lastly, if the offender is Indian, and it is a victimless crime, there is concurrent state and tribal jurisdiction, exclusive of the federal government. (Ibid.) Given that trespass is generally a victimless crime, tribal police already have the authority to enforce trespass violations where the offender is Indian, irrespective of involvement of state or local law enforcement.

Additionally, Indian governments seeking to prohibit persons from entering tribal land while under an order of exclusion may already do so. In Duro v. Reina, the Supreme Court addressed the authority of tribal law enforcement to detain non-Indians: [T]ribes also possess their traditional and undisputed power to exclude persons whom they deem to be undesirable from tribal lands []… Tribal law enforcement authorities have the power to restrain those who disturb public order on the reservation, and [] if necessary, to eject them. Where jurisdiction to try and punish an offender rests outside the tribe, tribal officers may exercise [] their power to detain the offender and transport him to the proper authorities. (Duro v. Reina (1990) 495 U.S. 676, 696.)

In sum, local, state and tribal law enforcement have the authority to enforce criminal trespass violations on Indian Lands, making the need to create a new trespass crime, and mechanism to enforce that crime, unclear.

1. Authorizing State and Local Law Enforcement to Enforce Tribal Orders: State and local law enforcement officers have authority to enforce public offenses. (Pen. Code, § 836, subd. (a).) A crime or public offense “is an act committed or omitted in violation of a law forbidding or commanding it” and include felonies, misdemeanors, and infractions (Pen. Code, § 15) (emphasis added) Accordingly, a peace officer may arrest a person pursuant to a warrant, or without a warrant if: 1) officer has probable cause to believe a person committed a public offense in the officer’s presence; 2) a person arrested has committed a felony, although not in the officer’s presence; or 3) the officer has probable cause to believe that the person to be arrested has committed a felony. (Ibid.)

Violating a tribe’s order of exclusion, in and of itself, is not a public offense. As such, law enforcement officers may not have the authority to enforce the orders. This issue was specifically addressed in a 1997 Attorney General Opinion that answered the question of what action a county sheriff could take to enforce an order of exclusion issued by a tribal council of an Indian tribe. (80 Ops. Cal. Atty. Gen. 46 (1997).) Preliminarily, the Attorney General reiterated that California’s criminal statutes, including trespass statutes, apply to Indian reservations within the state. (Id. at p. 5). The opinion further stated that “[t]ribal code provisions and orders, on the other hand, do not constitute the criminal laws of the state and have no force and effect elsewhere within California…[and] are not enforceable by a county sheriff either within or without the reservation.” (Ibid.) (emphasis added) Accordingly, the Attorney General held that because the tribal order of exclusion did not meet all the elements of the criminal trespass statute at issue, “a violation of the exclusion order in question would not per se satisfy the descriptive elements of a criminal trespass…; thus, a sheriff would not be authorized to enforce the issuance of such an order.” (Id. at p. 4).

This bill would make it a misdemeanor to enter upon specified tribal land within 48 hours after receiving an order of exclusion from a tribal government, and would authorize a tribe to enter into an agreement with a law enforcement agency to enforce such an order of exclusion.

This would give California state and local law enforcement officials the authority to enter sovereign Indian land, to arrest a person and to prosecute that person in a California superior court for misdemeanor trespass—simply because the person violated a tribal order that has does not have any force of law in the State of California. This is contrary to prior Attorney General guidance and inconsistent with the longstanding criminal enforcement authority established in California law. If enacted, this statute may be vulnerable to a legal challenge.

1. Argument in Support: According to California Civil Liberties Advocacy, “AB 1097 is a long-overdue clarification of state law under the framework of Public Law 280, which delegates certain criminal jurisdiction to the state in Indian country. While existing California law penalizes various forms of trespass on private property, it has lacked clarity regarding Indian lands, leaving enforcement inconsistent and leaving tribal governments without practical recourse in cases of repeat trespassers—even after criminal activity has occurred. This bill closes that gap.

“Affirming Tribal Sovereignty

“Most importantly, AB 1097 properly recognizes the inherent sovereign authority of federally recognized tribes to regulate access to their lands, issue exclusion orders, and partner with local law enforcement agencies on a voluntary basis to enforce those orders. This is not only a matter of criminal law but also a fundamental affirmation of tribal self-determination and territorial integrity. In a time when Indigenous communities still face challenges to their jurisdiction and dignity, AB 1097 represents a thoughtful step toward parity and respect.

“Protecting Due Process and Civil Liberties

“Importantly, AB 1097 builds upon existing due process protections by extending California’s current limitations on trespass enforcement to Indian lands. Under existing law, enhanced trespass penalties apply only to individuals who have committed a prior criminal offense on the same property, with enforceability limited by time—ranging from one year for infractions to five years for felonies, and unlimited for violent felonies. This bill preserves those safeguards while clarifying that they now apply equally to Indian lands and tribal exclusion orders. By explicitly defining terms such as “Indian lands,” “order of exclusion,” and “tribal government,” AB 1097 helps ensure enforcement is targeted, consistent, and respectful of individual rights as well as tribal sovereignty.

“Advancing Civil Liberties Through Sovereignty

“As a civil liberties organization, CCLA believes property rights, the right to self-governance, and the right to safety on one’s own land are foundational liberties. These rights are no less applicable to sovereign tribal nations. AB 1097 ensures that tribal lands are treated with the same dignity and respect as any other private or governmental property under California law.”

1. Argument in Opposition: According to UNITE HERE International Union, “While we remain steadfast in support of tribal sovereignty, we remain just as steadfast in our resolve to protect the access rights granted to union organizers and employees under the Tribal Labor Relations ordinance (TLRO). To that end, we were able to support previous iterations of this bill, including SB 1160 (Hueso) in 2018, which included protections ensuring that labor organizers and employees exercising their rights to organize a union are not improperly removed from tribal lands via orders of exclusion. To that end, we request Assembly Member Avila Farias to take the same language, which is in sum and substance virtually identical to the language in SB 1160:

“If the order of exclusion pertains to a labor organization or its representatives or eligible employees engaged in otherwise lawful labor activity, the tribe shall first obtain a decision from the Tribal Labor Panel established by the tribal labor relations ordinance stating that the order of exclusion does not conflict with the tribal labor relations ordinance adopted by the tribe or with a labor contract that is applicable to the gaming facility, provided that the affected labor organization, its representatives and eligible employees shall be given notice and an opportunity to be heard by the Tribal Labor Panel before such decision is issued.

“This language was previously negotiated by UNITE HERE and tribal stakeholders in 2018. We urge Assembly Member Avila Farias to amend her bill with the same language, which balances tribal sovereignty against the need to preserver organizing rights.”

1. Related Legislation: AB 31 (Ramos), would establish a pilot program, under the direction of the DOJ and the Commission on Peace Officer Standards and Training that would grant tribal law enforcement officers, of specified tribes, state peace officer authority on Indian land and elsewhere in the state under specified circumstances. AB 31 is pending in the Assembly Appropriations suspense file.
   
2. Prior Legislation:
   1. AB 2120 (Chen), of the 2023-2024 Legislative Session, would have allowed a licensed repossession agency and its employees to enter upon real property, not open to the public and without the consent of the owner, when they are searching for collateral or repossessing collateral, and upon completing the search or repossession, leave the private property within a reasonable amount of time. AB 2120 was vetoed by the Governor.
   2. SB 468 (Seyarto), of the 2023-2024 Legislative Session, would have authorized, for the purposes of requesting assistance enforcing trespass violations, a request for peace officer assistance to continue after a change in ownership or transfer of lawful possession if the transferee notifies the relevant law enforcement or the city of the change. SB 468 was never heard in Senate Public Safety.
   3. SB 602 (Archuleta), Chapter 404, Statutes of 2023, extends the operative timeframe for trespass letters of authorization from 30 days to 12 months, as specified.
   4. AB 515 (Chen), of the 2021-2022 Legislative Session, was substantially similar to AB 2120 (Chen), of the 2023-2024 Legislative Session. AB 515 was vetoed by the Governor.
   5. AB 660 (Rubio), Chapter 381, Statutes of 2017, expands the crime of trespass on the property of a public agency.
   6. SB 1160 (Hueso), of the 2017-2018 Legislative Session, would have made entering a gaming facility on a federally recognized Indian tribe after receiving an order of exclusion from the tribal government, a misdemeanor offense. SB 1160 was never heard in Assembly Public Safety.
   7. AB 1686 (Medina), Chapter 453, Statutes of 2014, extended from six months to 12 months the time in which a property owner may authorize a peace officer to arrest a trespasser on private property, closed to the public and posted as being closed, without the owner of the property being present.
      
   8. SB 1295 (Block), Chapter 373, Statutes of 2014, extended from six months to 12 months the time in which a property owner may authorize a peace officer to arrest a trespasser on private property, closed to the public and posted as being closed, without the owner of the property being present, and provides that a request for assistance shall expire upon transfer of ownership of the property or upon change of the person in lawful possession.

REGISTERED SUPPORT / OPPOSITION:

Support

California Civil Liberties Advocacy
Rincon San Luiseno Band of Indians; the

Oppose Unless Amended

Unite Here International Union, Afl-cio

Analysis Prepared by:

Ilan Zur / PUB. S. / (916) 319-3744

Date of Hearing: April 22, 2025

Counsel: Ilan Zur

ASSEMBLY COMMITTEE ON

Nick Schultz, Chair

ABPCA Bill Id:

Author:() – As Ver:

Updated

As Proposed To Be Amended in Committee

SUMMARY:

Clarifies that California criminal trespass laws apply on Indian lands. Specifically, this bill:

1. Clarifies, for purposes of the crime of trespassing upon private property, whether or not generally open to the public, after having being informed by a peace officer, at the request of the owner, that the peace officer is acting at the request of the owner and that the property is not open to the particular person, or failing to leave the property after being asked to leave the property, that if the conduct occurs on Indian lands a peace officer includes a person designated by a Tribe that has been deputized or appointed by the county sheriff, and has completed the basic Commission on Peace Officer Standards and Training (POST) training course, and has the full powers and duties of a peace officer.
2. Clarifies that the use of the term “land” in California’s criminal trespass statutes also applies to Indian lands, which is declaratory of existing law.
3. Defines “Indian lands” as all land within the limits of any Indian reservation under the jurisdiction of the United States notwithstanding the issuance of any patent, and, including rights-of-way running through the reservation, all dependent Indian communities within the borders of the U.S. whether within the original or subsequently acquired territory thereof, and whether within or without the limits of a state, and all Indian allotments, the Indian titles to which have not been extinguished, including rights-of-way running through the same.

EXISTING FEDERAL LAW:

1. States that California has jurisdiction over offenses committed by or against Indians in Indian Country to the same extent that the State has jurisdiction over offenses committed elsewhere in the State. (18 U.S.C. § 1162.)
2. Provides that the criminal laws of California shall have the same force and effect within Indian country as they have elsewhere within the State. (Ibid.)

EXISTING STATE LAW:

1. States that any person designated by a tribe, who is deputized or appointed by the county sheriff, is a peace officer, if the person and the person has completed the basic POST training course. The authority of a peace officer pursuant to this subdivision includes the full powers and duties of a peace officer as specified in the above paragraph. (Pen. Code, § 830.6, subd. (b).)
2. Allows cities and counties to enter into a contract with an Indian tribe to provide police or sheriff protection services for the Indian tribe either solely on Indian lands, or on the Indian lands and territory adjacent to those Indian lands. (Gov. Code, § 54981.7)
   
3. Generally punishes trespass as a misdemeanor, punishable by a county jail term of up to six months, a fine of up to $1,000 or both. (Pen. Code, §§ 19, 602.)
4. Makes it a misdemeanor to willfully commit trespass by entering upon private property, including contiguous land, real property, or structures thereon belonging to the same owner, whether or not generally open to the public after: 1) having been informed by a peace officer at the request of the owner, their agent, or person in lawful possession, and upon being informed by the peace officer that the officer is acting at the request of the owner, their agent, or person in lawful possession, that the property is not open to the particular person; or 2) refusing or failing to leave the property upon being asked to leave the property, subject to the following:
   1. This crime applies only to a person who has been convicted of a crime committed upon the particular private property.
   2. A single notification or request to the person described above shall be valid and enforceable unless and until rescinded by the owner, the owner’s agent, or the person in lawful possession of the property.
   3. Where the person has been convicted of a violent felony, that notification or request applies without time limitation, if the person has been convicted of any other felony, this applies for no more than five years from the date of conviction, where the person has been convicted of a misdemeanor, this applies for no more than two years from the date of conviction, and where the person was convicted for an infraction, as specified, this applies for no more than one year from the date of conviction. (Pen. Code, §602, subd. (t).)
5. Establishes numerous other trespass crimes, as specified. (Pen. Code, §602, subds. (a)-(y).
   

FISCAL EFFECT:

Unknown

COMMENTS:

1. Author's Statement: According to the author, "Unfortunately, the seclusion tribes have learned to live with and the peace that they fought so long to obtain, has become threatened by trespassers. Additionally, this geographical seclusion has made it difficult to sustain an adequate number of law enforcement personnel to protect the lands. Trespassing on Indian lands places a significant safety risk on tribal families.

While California has existing law within California Penal Code Section 602 to protect against trespassing, this section of law does not explicitly include Indian lands as those protected under this statute. AB 1079 clarifies that federally recognized Indian Tribal lands are considered areas where trespassing would constitute a misdemeanor.”

1. Effect of this Bill: California’s primary trespass statute – Penal Code section 602 – has nearly an entire alphabet of subdivisions. (Pen. Code, 602.) Most of the subdivisions in Section 602 define separate crimes, typically each with slightly different elements than the other subdivisions. (Ibid.) Trespass is generally a misdemeanor, though California law does include a felony for aggravated trespass. (Pen. Code, § 602 subds. (k) & (l). For misdemeanor trespass, the penalty is up to six months of jail time or up to a $1,000 fine, or both. (Pen. Code, §§ 19, 602.)

Most relevant here is subdivision (t) which makes it a misdemeanor to willfully enter private property, including contiguous land, real property, or structures thereon, regardless of whether the land is generally open to the public after: 1) being informed by a peace officer at the request of the owner that the officer is acting at the request of the owner and that the property is not open to the particular person; or 2) refusing or failing to leave the property upon being asked to leave the property by the officer. (Pen. Code, §602, subd. (t)(1).).

This only applies to a person who has been convicted of a crime committed upon the particular private property. (Pen. Code, §602, subd. (t)(2).). Further, the notification by a peace officer, on behalf of an owner, that the property is not open to a particular person or a request for that person to leave the property, is valid and enforceable until rescinded by the owner, their agent, or the person in lawful possession of the property. (Pen. Code, §603, subd. (t)(3).) The amount of time that the notification or request remains in effect depends on the severity of the underlying crime. Where the person was convicted of a violent felony, that notification or request applies without time limitation, while if the person was convicted of any other felony, this applies for no more than five years from the date of conviction. (Pen. Code, §602, subd. (t)(4).). Additionally, if the person was convicted of a misdemeanor, this applies for no more than two years from the date of conviction. (Ibid.) If the person was convicted for an infraction, as specified, this applies for no more than one year from the date of conviction. (Ibid.)

This bill would clarify, for purposes of the above trespass crime, that if the conduct occurs on Indian lands, a peace officer includes a person designated by a Tribe that has been deputized or appointed by the county sheriff and has completed the basic POST training course, and has the full powers and duties of a peace officer.

Additionally, it clarifies that the use of the term “land” in specified California criminal trespass statutes includes Indian lands in California, which is declaratory of existing law.

1. California Criminal Trespass Laws Apply on Tribal Land: Under Public Law 280 (1953), California has jurisdiction over offenses committed by or against Indians in Indian Country to the same extent that the State has jurisdiction over offenses committed elsewhere in the State. (18 U.S.C. § 1162.) California’s criminal laws have the same force and effect within Indian country as they have elsewhere within the State. (Ibid.) In other words, the criminal laws of California, including criminal trespass laws, extend to Indian lands within the state.
   

Accordingly prosecutors and law enforcement may enforce criminal trespasses on Indian lands to the same extent they can enforce criminal trespass on property not located on Indian land. Given that Public Law 280 created concurrent jurisdiction over criminal offenses committed by or against Indians within Indian Country, tribal police may also enforce certain crimes on Indian land. Specifically, if the offender is non-Indian, and the victim is non-Indian or Indian or it is a victimless crime the state generally has exclusive jurisdiction. (Draper v. United States (1896) 164 U.S. 240). Alternatively, if the offender is Indian, and the victim is Indian or non-Indian, there is concurrent state and tribal jurisdiction, exclusive of the federal government. (Indian Civil Rights Act, 25 U.S.C. § 1301.) Lastly, if the offender is Indian, and it is a victimless crime, there is concurrent state and tribal jurisdiction, exclusive of the federal government. (Ibid.) Given that trespass is generally a victimless crime, tribal police already have the authority to enforce trespass violations where the offender is Indian, irrespective of involvement of state or local law enforcement.

Additionally, Indian governments seeking to prohibit persons from entering tribal land while under an order of exclusion may already do so. In Duro v. Reina, the Supreme Court addressed the authority of tribal law enforcement to detain non-Indians: [T]ribes also possess their traditional and undisputed power to exclude persons whom they deem to be undesirable from tribal lands []… Tribal law enforcement authorities have the power to restrain those who disturb public order on the reservation, and [] if necessary, to eject them. Where jurisdiction to try and punish an offender rests outside the tribe, tribal officers may exercise [] their power to detain the offender and transport him to the proper authorities. (Duro v. Reina (1990) 495 U.S. 676, 696.)

In sum, California’s criminal trespass laws already apply to Indian lands within the state, and as such, local, state and tribal law enforcement have the authority to enforce criminal trespass violations on Indian lands.

1. Argument in Support: According to California Civil Liberties Advocacy, “AB 1097 is a long-overdue clarification of state law under the framework of Public Law 280, which delegates certain criminal jurisdiction to the state in Indian country. While existing California law penalizes various forms of trespass on private property, it has lacked clarity regarding Indian lands, leaving enforcement inconsistent and leaving tribal governments without practical recourse in cases of repeat trespassers—even after criminal activity has occurred. This bill closes that gap.

“Affirming Tribal Sovereignty

“Most importantly, AB 1097 properly recognizes the inherent sovereign authority of federally recognized tribes to regulate access to their lands, issue exclusion orders, and partner with local law enforcement agencies on a voluntary basis to enforce those orders. This is not only a matter of criminal law but also a fundamental affirmation of tribal self-determination and territorial integrity. In a time when Indigenous communities still face challenges to their jurisdiction and dignity, AB 1097 represents a thoughtful step toward parity and respect.

“Protecting Due Process and Civil Liberties

“Importantly, AB 1097 builds upon existing due process protections by extending California’s current limitations on trespass enforcement to Indian lands. Under existing law, enhanced trespass penalties apply only to individuals who have committed a prior criminal offense on the same property, with enforceability limited by time—ranging from one year for infractions to five years for felonies, and unlimited for violent felonies. This bill preserves those safeguards while clarifying that they now apply equally to Indian lands and tribal exclusion orders. By explicitly defining terms such as “Indian lands,” “order of exclusion,” and “tribal government,” AB 1097 helps ensure enforcement is targeted, consistent, and respectful of individual rights as well as tribal sovereignty.

“Advancing Civil Liberties Through Sovereignty

“As a civil liberties organization, CCLA believes property rights, the right to self-governance, and the right to safety on one’s own land are foundational liberties. These rights are no less applicable to sovereign tribal nations. AB 1097 ensures that tribal lands are treated with the same dignity and respect as any other private or governmental property under California law.”

1. Argument in Opposition: According to UNITE HERE International Union, “While we remain steadfast in support of tribal sovereignty, we remain just as steadfast in our resolve to protect the access rights granted to union organizers and employees under the Tribal Labor Relations ordinance (TLRO). To that end, we were able to support previous iterations of this bill, including SB 1160 (Hueso) in 2018, which included protections ensuring that labor organizers and employees exercising their rights to organize a union are not improperly removed from tribal lands via orders of exclusion. To that end, we request Assembly Member Avila Farias to take the same language, which is in sum and substance virtually identical to the language in SB 1160:

“If the order of exclusion pertains to a labor organization or its representatives or eligible employees engaged in otherwise lawful labor activity, the tribe shall first obtain a decision from the Tribal Labor Panel established by the tribal labor relations ordinance stating that the order of exclusion does not conflict with the tribal labor relations ordinance adopted by the tribe or with a labor contract that is applicable to the gaming facility, provided that the affected labor organization, its representatives and eligible employees shall be given notice and an opportunity to be heard by the Tribal Labor Panel before such decision is issued.

“This language was previously negotiated by UNITE HERE and tribal stakeholders in 2018. We urge Assembly Member Avila Farias to amend her bill with the same language, which balances tribal sovereignty against the need to preserver organizing rights.”

1. Related Legislation: AB 31 (Ramos), would establish a pilot program, under the direction of the DOJ and the Commission on Peace Officer Standards and Training that would grant tribal law enforcement officers, of specified tribes, state peace officer authority on Indian land and elsewhere in the state under specified circumstances. AB 31 is pending in the Assembly Appropriations suspense file.
   
2. Prior Legislation:
   1. AB 2120 (Chen), of the 2023-2024 Legislative Session, would have allowed a licensed repossession agency and its employees to enter upon real property, not open to the public and without the consent of the owner, when they are searching for collateral or repossessing collateral, and upon completing the search or repossession, leave the private property within a reasonable amount of time. AB 2120 was vetoed by the Governor.
   2. SB 468 (Seyarto), of the 2023-2024 Legislative Session, would have authorized, for the purposes of requesting assistance enforcing trespass violations, a request for peace officer assistance to continue after a change in ownership or transfer of lawful possession if the transferee notifies the relevant law enforcement or the city of the change. SB 468 was never heard in Senate Public Safety.
   3. SB 602 (Archuleta), Chapter 404, Statutes of 2023, extends the operative timeframe for trespass letters of authorization from 30 days to 12 months, as specified.
   4. AB 515 (Chen), of the 2021-2022 Legislative Session, was substantially similar to AB 2120 (Chen), of the 2023-2024 Legislative Session. AB 515 was vetoed by the Governor.
   5. AB 660 (Rubio), Chapter 381, Statutes of 2017, expands the crime of trespass on the property of a public agency.
   6. SB 1160 (Hueso), of the 2017-2018 Legislative Session, would have made entering a gaming facility on a federally recognized Indian tribe after receiving an order of exclusion from the tribal government, a misdemeanor offense. SB 1160 was never heard in Assembly Public Safety.
   7. AB 1686 (Medina), Chapter 453, Statutes of 2014, extended from six months to 12 months the time in which a property owner may authorize a peace officer to arrest a trespasser on private property, closed to the public and posted as being closed, without the owner of the property being present.
      
   8. SB 1295 (Block), Chapter 373, Statutes of 2014, extended from six months to 12 months the time in which a property owner may authorize a peace officer to arrest a trespasser on private property, closed to the public and posted as being closed, without the owner of the property being present, and provides that a request for assistance shall expire upon transfer of ownership of the property or upon change of the person in lawful possession.

REGISTERED SUPPORT / OPPOSITION:

Support

California Civil Liberties Advocacy

Oppose Unless Amended

Unite Here International Union, Afl-cio

Analysis Prepared by:

Date of Hearing:

Counsel: Ilan Zur

ASSEMBLY COMMITTEE ON PUBLIC SAFETY

Nick Schultz, Chair

ABPCA Bill Id:AB 1097

Author:(Ávila Farías) – As Amended Ver:March 17, 2025

As Proposed To Be Amended in Committee

SUMMARY:

Clarifies that California criminal trespass laws apply on Indian lands. Specifically, this bill:

1. Clarifies, for purposes of the crime of trespassing upon private property, whether or not generally open to the public, after having being informed by a peace officer, at the request of the owner, that the peace officer is acting at the request of the owner and that the property is not open to the particular person, or failing to leave the property after being asked to leave the property, that if the conduct occurs on Indian lands a peace officer includes a person designated by a Tribe that has been deputized or appointed by the county sheriff, and has completed the basic Commission on Peace Officer Standards and Training (POST) training course, and has the full powers and duties of a peace officer.
2. Clarifies that the use of the term “land” in California’s criminal trespass statutes also applies to Indian lands, which is declaratory of existing law.
3. Defines “Indian lands” as all land within the limits of any Indian reservation under the jurisdiction of the United States notwithstanding the issuance of any patent, and, including rights-of-way running through the reservation, all dependent Indian communities within the borders of the U.S. whether within the original or subsequently acquired territory thereof, and whether within or without the limits of a state, and all Indian allotments, the Indian titles to which have not been extinguished, including rights-of-way running through the same.

EXISTING FEDERAL LAW:

1. States that California has jurisdiction over offenses committed by or against Indians in Indian Country to the same extent that the State has jurisdiction over offenses committed elsewhere in the State. (18 U.S.C. § 1162.)
2. Provides that the criminal laws of California shall have the same force and effect within Indian country as they have elsewhere within the State. (Ibid.)

EXISTING STATE LAW:

1. States that any person designated by a tribe, who is deputized or appointed by the county sheriff, is a peace officer, if the person and the person has completed the basic POST training course. The authority of a peace officer pursuant to this subdivision includes the full powers and duties of a peace officer as specified in the above paragraph. (Pen. Code, § 830.6, subd. (b).)
2. Allows cities and counties to enter into a contract with an Indian tribe to provide police or sheriff protection services for the Indian tribe either solely on Indian lands, or on the Indian lands and territory adjacent to those Indian lands. (Gov. Code, § 54981.7)
   
3. Generally punishes trespass as a misdemeanor, punishable by a county jail term of up to six months, a fine of up to $1,000 or both. (Pen. Code, §§ 19, 602.)
4. Makes it a misdemeanor to willfully commit trespass by entering upon private property, including contiguous land, real property, or structures thereon belonging to the same owner, whether or not generally open to the public after: 1) having been informed by a peace officer at the request of the owner, their agent, or person in lawful possession, and upon being informed by the peace officer that the officer is acting at the request of the owner, their agent, or person in lawful possession, that the property is not open to the particular person; or 2) refusing or failing to leave the property upon being asked to leave the property, subject to the following:
   1. This crime applies only to a person who has been convicted of a crime committed upon the particular private property.
   2. A single notification or request to the person described above shall be valid and enforceable unless and until rescinded by the owner, the owner’s agent, or the person in lawful possession of the property.
   3. Where the person has been convicted of a violent felony, that notification or request applies without time limitation, if the person has been convicted of any other felony, this applies for no more than five years from the date of conviction, where the person has been convicted of a misdemeanor, this applies for no more than two years from the date of conviction, and where the person was convicted for an infraction, as specified, this applies for no more than one year from the date of conviction. (Pen. Code, §602, subd. (t).)
5. Establishes numerous other trespass crimes, as specified. (Pen. Code, §602, subds. (a)-(y).
   

FISCAL EFFECT:

Unknown

COMMENTS:

1. Author's Statement: According to the author, "Unfortunately, the seclusion tribes have learned to live with and the peace that they fought so long to obtain, has become threatened by trespassers. Additionally, this geographical seclusion has made it difficult to sustain an adequate number of law enforcement personnel to protect the lands. Trespassing on Indian lands places a significant safety risk on tribal families.

While California has existing law within California Penal Code Section 602 to protect against trespassing, this section of law does not explicitly include Indian lands as those protected under this statute. AB 1079 clarifies that federally recognized Indian Tribal lands are considered areas where trespassing would constitute a misdemeanor.”

1. Effect of this Bill: California’s primary trespass statute – Penal Code section 602 – has nearly an entire alphabet of subdivisions. (Pen. Code, 602.) Most of the subdivisions in Section 602 define separate crimes, typically each with slightly different elements than the other subdivisions. (Ibid.) Trespass is generally a misdemeanor, though California law does include a felony for aggravated trespass. (Pen. Code, § 602 subds. (k) & (l). For misdemeanor trespass, the penalty is up to six months of jail time or up to a $1,000 fine, or both. (Pen. Code, §§ 19, 602.)

Most relevant here is subdivision (t) which makes it a misdemeanor to willfully enter private property, including contiguous land, real property, or structures thereon, regardless of whether the land is generally open to the public after: 1) being informed by a peace officer at the request of the owner that the officer is acting at the request of the owner and that the property is not open to the particular person; or 2) refusing or failing to leave the property upon being asked to leave the property by the officer. (Pen. Code, §602, subd. (t)(1).).

This only applies to a person who has been convicted of a crime committed upon the particular private property. (Pen. Code, §602, subd. (t)(2).). Further, the notification by a peace officer, on behalf of an owner, that the property is not open to a particular person or a request for that person to leave the property, is valid and enforceable until rescinded by the owner, their agent, or the person in lawful possession of the property. (Pen. Code, §603, subd. (t)(3).) The amount of time that the notification or request remains in effect depends on the severity of the underlying crime. Where the person was convicted of a violent felony, that notification or request applies without time limitation, while if the person was convicted of any other felony, this applies for no more than five years from the date of conviction. (Pen. Code, §602, subd. (t)(4).). Additionally, if the person was convicted of a misdemeanor, this applies for no more than two years from the date of conviction. (Ibid.) If the person was convicted for an infraction, as specified, this applies for no more than one year from the date of conviction. (Ibid.)

This bill would clarify, for purposes of the above trespass crime, that if the conduct occurs on Indian lands, a peace officer includes a person designated by a Tribe that has been deputized or appointed by the county sheriff and has completed the basic POST training course, and has the full powers and duties of a peace officer.

Additionally, it clarifies that the use of the term “land” in specified California criminal trespass statutes includes Indian lands in California, which is declaratory of existing law.

1. California Criminal Trespass Laws Apply on Tribal Land: Under Public Law 280 (1953), California has jurisdiction over offenses committed by or against Indians in Indian Country to the same extent that the State has jurisdiction over offenses committed elsewhere in the State. (18 U.S.C. § 1162.) California’s criminal laws have the same force and effect within Indian country as they have elsewhere within the State. (Ibid.) In other words, the criminal laws of California, including criminal trespass laws, extend to Indian lands within the state.
   

Accordingly prosecutors and law enforcement may enforce criminal trespasses on Indian lands to the same extent they can enforce criminal trespass on property not located on Indian land. Given that Public Law 280 created concurrent jurisdiction over criminal offenses committed by or against Indians within Indian Country, tribal police may also enforce certain crimes on Indian land. Specifically, if the offender is non-Indian, and the victim is non-Indian or Indian or it is a victimless crime the state generally has exclusive jurisdiction. (Draper v. United States (1896) 164 U.S. 240). Alternatively, if the offender is Indian, and the victim is Indian or non-Indian, there is concurrent state and tribal jurisdiction, exclusive of the federal government. (Indian Civil Rights Act, 25 U.S.C. § 1301.) Lastly, if the offender is Indian, and it is a victimless crime, there is concurrent state and tribal jurisdiction, exclusive of the federal government. (Ibid.) Given that trespass is generally a victimless crime, tribal police already have the authority to enforce trespass violations where the offender is Indian, irrespective of involvement of state or local law enforcement.

Additionally, Indian governments seeking to prohibit persons from entering tribal land while under an order of exclusion may already do so. In Duro v. Reina, the Supreme Court addressed the authority of tribal law enforcement to detain non-Indians: [T]ribes also possess their traditional and undisputed power to exclude persons whom they deem to be undesirable from tribal lands []… Tribal law enforcement authorities have the power to restrain those who disturb public order on the reservation, and [] if necessary, to eject them. Where jurisdiction to try and punish an offender rests outside the tribe, tribal officers may exercise [] their power to detain the offender and transport him to the proper authorities. (Duro v. Reina (1990) 495 U.S. 676, 696.)

In sum, California’s criminal trespass laws already apply to Indian lands within the state, and as such, local, state and tribal law enforcement have the authority to enforce criminal trespass violations on Indian lands.

1. Argument in Support: According to California Civil Liberties Advocacy, “AB 1097 is a long-overdue clarification of state law under the framework of Public Law 280, which delegates certain criminal jurisdiction to the state in Indian country. While existing California law penalizes various forms of trespass on private property, it has lacked clarity regarding Indian lands, leaving enforcement inconsistent and leaving tribal governments without practical recourse in cases of repeat trespassers—even after criminal activity has occurred. This bill closes that gap.

“Affirming Tribal Sovereignty

“Most importantly, AB 1097 properly recognizes the inherent sovereign authority of federally recognized tribes to regulate access to their lands, issue exclusion orders, and partner with local law enforcement agencies on a voluntary basis to enforce those orders. This is not only a matter of criminal law but also a fundamental affirmation of tribal self-determination and territorial integrity. In a time when Indigenous communities still face challenges to their jurisdiction and dignity, AB 1097 represents a thoughtful step toward parity and respect.

“Protecting Due Process and Civil Liberties

“Importantly, AB 1097 builds upon existing due process protections by extending California’s current limitations on trespass enforcement to Indian lands. Under existing law, enhanced trespass penalties apply only to individuals who have committed a prior criminal offense on the same property, with enforceability limited by time—ranging from one year for infractions to five years for felonies, and unlimited for violent felonies. This bill preserves those safeguards while clarifying that they now apply equally to Indian lands and tribal exclusion orders. By explicitly defining terms such as “Indian lands,” “order of exclusion,” and “tribal government,” AB 1097 helps ensure enforcement is targeted, consistent, and respectful of individual rights as well as tribal sovereignty.

“Advancing Civil Liberties Through Sovereignty

“As a civil liberties organization, CCLA believes property rights, the right to self-governance, and the right to safety on one’s own land are foundational liberties. These rights are no less applicable to sovereign tribal nations. AB 1097 ensures that tribal lands are treated with the same dignity and respect as any other private or governmental property under California law.”

1. Argument in Opposition: According to UNITE HERE International Union, “While we remain steadfast in support of tribal sovereignty, we remain just as steadfast in our resolve to protect the access rights granted to union organizers and employees under the Tribal Labor Relations ordinance (TLRO). To that end, we were able to support previous iterations of this bill, including SB 1160 (Hueso) in 2018, which included protections ensuring that labor organizers and employees exercising their rights to organize a union are not improperly removed from tribal lands via orders of exclusion. To that end, we request Assembly Member Avila Farias to take the same language, which is in sum and substance virtually identical to the language in SB 1160:

“If the order of exclusion pertains to a labor organization or its representatives or eligible employees engaged in otherwise lawful labor activity, the tribe shall first obtain a decision from the Tribal Labor Panel established by the tribal labor relations ordinance stating that the order of exclusion does not conflict with the tribal labor relations ordinance adopted by the tribe or with a labor contract that is applicable to the gaming facility, provided that the affected labor organization, its representatives and eligible employees shall be given notice and an opportunity to be heard by the Tribal Labor Panel before such decision is issued.

“This language was previously negotiated by UNITE HERE and tribal stakeholders in 2018. We urge Assembly Member Avila Farias to amend her bill with the same language, which balances tribal sovereignty against the need to preserver organizing rights.”

1. Related Legislation: AB 31 (Ramos), would establish a pilot program, under the direction of the DOJ and the Commission on Peace Officer Standards and Training that would grant tribal law enforcement officers, of specified tribes, state peace officer authority on Indian land and elsewhere in the state under specified circumstances. AB 31 is pending in the Assembly Appropriations suspense file.
   
2. Prior Legislation:
   1. AB 2120 (Chen), of the 2023-2024 Legislative Session, would have allowed a licensed repossession agency and its employees to enter upon real property, not open to the public and without the consent of the owner, when they are searching for collateral or repossessing collateral, and upon completing the search or repossession, leave the private property within a reasonable amount of time. AB 2120 was vetoed by the Governor.
   2. SB 468 (Seyarto), of the 2023-2024 Legislative Session, would have authorized, for the purposes of requesting assistance enforcing trespass violations, a request for peace officer assistance to continue after a change in ownership or transfer of lawful possession if the transferee notifies the relevant law enforcement or the city of the change. SB 468 was never heard in Senate Public Safety.
   3. SB 602 (Archuleta), Chapter 404, Statutes of 2023, extends the operative timeframe for trespass letters of authorization from 30 days to 12 months, as specified.
   4. AB 515 (Chen), of the 2021-2022 Legislative Session, was substantially similar to AB 2120 (Chen), of the 2023-2024 Legislative Session. AB 515 was vetoed by the Governor.
   5. AB 660 (Rubio), Chapter 381, Statutes of 2017, expands the crime of trespass on the property of a public agency.
   6. SB 1160 (Hueso), of the 2017-2018 Legislative Session, would have made entering a gaming facility on a federally recognized Indian tribe after receiving an order of exclusion from the tribal government, a misdemeanor offense. SB 1160 was never heard in Assembly Public Safety.
   7. AB 1686 (Medina), Chapter 453, Statutes of 2014, extended from six months to 12 months the time in which a property owner may authorize a peace officer to arrest a trespasser on private property, closed to the public and posted as being closed, without the owner of the property being present.
      
   8. SB 1295 (Block), Chapter 373, Statutes of 2014, extended from six months to 12 months the time in which a property owner may authorize a peace officer to arrest a trespasser on private property, closed to the public and posted as being closed, without the owner of the property being present, and provides that a request for assistance shall expire upon transfer of ownership of the property or upon change of the person in lawful possession.

REGISTERED SUPPORT / OPPOSITION:

Support

California State Sheriffs' Association (Sponsor)
Crime Victims United of California

Oppose Unless Amended

California Attorneys for Criminal Justice
California Public Defenders Association (CPDA)

Analysis Prepared by:

Ilan Zur / PUB. S. / (916) 319-3744