Existing law, the California Uniform Controlled Substances Act, categorizes controlled substances into 5 designated schedules, places the greatest restrictions on those substances contained in Schedule I, and generally places the least restrictive limitations on controlled substances classified in Schedule V. Existing law categorizes ketamine as a Schedule III controlled substance.

Existing law makes it a crime to transport, import, sell, furnish, administer, or give away, including to offer or attempt to transport, import, sell, furnish, administer, or give away, specified controlled substances. Existing law makes a violation of that provision punishable by imprisonment in the county jail for 3, 4, or 5 years, except as specified. Existing law, with a specified exception, makes it a crime to possess for sale or sell ketamine. Existing law makes a violation of that provision punishable by imprisonment in the county jail for a period of not more than one year or in the state prison.

Existing law, the California Uniform Controlled Substances Act, categorizes controlled substances into 5 designated schedules, places the greatest restrictions on those substances contained in Schedule I, and generally places the least restrictive limitations on controlled substances classified in Schedule V. Existing law categorizes ketamine as a Schedule III controlled substance.

Existing law makes it a crime to transport, import, sell, furnish, administer, or give away, including to offer or attempt to transport, import, sell, furnish, administer, or give away, specified controlled substances. Existing law makes a violation of that provision punishable by imprisonment in the county jail for 3, 4, or 5 years, except as specified.

This bill would add ketamine to the list of substances for which it is a crime to transport, import, sell, furnish, administer, or give away. By expanding the scope of an existing crime, this bill would impose a state-mandated local program.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

Date of Hearing: April 9, 2025

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Buffy Wicks, Chair

ABPCA Bill Id:AB 837

Author:(Davies) – As Amended Ver:March 27, 2025

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

SUMMARY:

This bill changes the punishment for existing ketamine sales felonies and creates a new felony offense for transporting for sale, importing, or administering ketamine.

Specifically, under existing law, possession of ketamine for sales and sale of ketamine can be charged as a misdemeanor or a felony. A felony conviction is punishable by 16 months, two years, or three years in state prison. Instead, this bill makes a felony conviction punishable by three, four, or five years in county jail, or, if the defendant has certain prior convictions, by a state prison term.

The bill also creates a new felony offense for transporting for sale, importing into this state, furnishing, administering, or giving away ketamine, or offering or attempting to do those things. This new felony offense is punishable by three, four, or five years in county jail, or, if the defendant has certain prior convictions, by a state prison term.

FISCAL EFFECT:

1. Cost pressures (Trial Court Trust Fund, General Fund) of an unknown but potentially significant amount to the courts to adjudicate violations of the felony offense created by this bill. A defendant charged with a felony is entitled to a jury trial and, if the defendant is indigent, legal representation provided by the government. Actual court costs will depend on the number of violations and the amount of court time needed to adjudicate each case. Although courts are not funded on the basis of workload, increased pressure on the Trial Court Trust Fund may create a demand for increased funding for courts from the General Fund. The fiscal year 2024-25 state budget provides $37.3 million ongoing General Fund to backfill declining revenue to the Trial Court Trust Fund.
2. Costs (local funds, General Fund) of an unknown but potentially significant amount to the counties and the California Department of Corrections and Rehabilitation to incarcerate people convicted of ketamine offenses. It is difficult to anticipate the potential impact of this bill on the state prison population. The bill will result in some people serving their sentence for felony ketamine sales in county jail, rather than in prison as they would under existing law. But the bill also requires a person with certain prior convictions to be sentenced to a prison term if they are convicted of the new ketamine transport felony created by the bill.

Actual incarceration costs will depend on the number of convictions, the length of each sentence, and whether each sentence must be served in jail or prison. The average annual cost to incarcerate one person in jail is approximately $29,000. The Legislative Analyst’s Office estimates the average annual cost to incarcerate one person in prison is $133,000. Although county incarceration costs are generally not considered reimbursable state mandates pursuant to Proposition 30 (2012), overcrowding in county jails creates cost pressure on the General Fund because the state has historically granted new funding to counties to offset overcrowding resulting from 2011 public safety realignment.

COMMENTS:

1. Background. Ketamine is a Schedule III non-narcotic controlled substance. According to the federal Drug Enforcement Administration:

Ketamine is a dissociative anesthetic that has some hallucinogenic effects. Ketamine distorts the perception of sight and sound and makes the user feel disconnected and not in control. It is referred to as a “dissociative anesthetic hallucinogen” because it makes patients feel detached from their pain and environment.

Although ketamine may be prescribed to treat medical conditions, including anxiety and depression, it is also used recreationally, either by itself or mixed with other illegal drugs. As described in more detail in the analysis of this bill by the Assembly Committee on Public Safety, criminal offenses related to ketamine use and sales are punished differently under existing law than offenses related to other drugs. This bill brings punishment of ketamine offenses more into alignment with punishment of other drug offenses.

1. Support and Opposition. This bill is supported by law enforcement associations and the California District Attorneys Association, which writes:

AB 837 is a critical step in addressing the growing threat of illicit ketamine distribution. By amending Section 11352, this bill provides law enforcement and prosecutors with the necessary legal tools to combat illegal ketamine trafficking and protect public safety.

The bill is opposed by criminal justice reform groups, including Drug Policy Alliance, which writes:

Increased penalties will not result in a safer California, but will create needless suffering for individuals convicted for sharing, transporting or furnishing ketamine, cause social and financial harms for families of those incarcerated, cost taxpayers for additional criminal and correctional system expenditures, and have significant long term economic and social impacts for individuals and communities. …Increasing the penalties on supply-side drug market activity does not reduce the drug supply, reduce suffering associated with drug use or incarceration, or reduce drug use.

Analysis Prepared by: Annika Carlson / APPR. / (916) 319-2081

Date of Hearing:

Chief Counsel: Andrew Ironside

ASSEMBLY COMMITTEE ON PUBLIC SAFETY

Nick Schultz, Chair

ABPCA Bill Id:AB 837

Author:(Davies) – As Introduced Ver:February 19, 2025

As Proposed to be Amended in Committee

SUMMARY:

Makes it a felony to attempt to traffic or to traffic, furnish, or give away ketamine. Specifically, this bill:

1. Provides that transporting, importing into this state, furnishing, administering, or giving away, or offering to do any of those things, or attempting to transport or import into this state, ketamine is punishable by imprisonment for 16 months, two years, or three years.
   
2. Makes felony possession for sale or sale a realigned felony.

EXISTING LAW:

1. Lists controlled substances in five “schedules” - intended to list drugs in decreasing order of harm and increasing medical utility or safety - and provides penalties for possession of and commerce in controlled substances.  Schedule I includes the most serious and heavily controlled substances, with Schedule V being the least serious and most lightly controlled substances. (Health & Saf. Code, §§ 11054-11058.)
   
2. Classifies ketamine as a Schedule III controlled substance. (Health & Saf. Code, § 11056, subd. (g).)
   
3. Makes possession of ketamine a misdemeanor punishable in county jail for up to one year. (Health & Saf. Code, § 11377, subd. (a).)
   
4. Provides for punishment by 16 months, 2 years, or 3 three years in state prison for possession of ketamine when the defendant has one or more prior specified “serious” or “violent” felony convictions or a prior conviction requiring sex offender registration. (Health & Saf. Code, § 11377, subd. (a).)
   
5. Makes possession of ketamine for sale or sale of ketamine an alternate felony/misdemeanor punishable by up to one year in county jail or 16 months, two years, or three years in state prison. (Health & Saf. Code, § 11379.2.)
   
6. Makes it felony to transport, import into this state, sell, furnish, administer, or give away, or to offer to do any of those things, or to attempt to import into this state or transport, any Schedule III controlled substance that is not a narcotic, except ketamine, punishable by imprisonment for two, three, or four years. (Health & Saf. Code, § 11379, subd. (a).)
   
7. Makes it a felony to transport any Schedule III controlled substance that is not a narcotic, except ketamine, within this state from one county to another noncontiguous county punishable by imprisonment for three, six, or nine years. (Health & Saf. Code, § 11379, subd. (b).)
   
8. Makes it felony to transport, import into this state, sell, furnish, administer, or give away, or to offer to do any of those things, or to attempt to import into this state or transport, any Schedule III controlled substance that is a narcotic, or a schedule III hallucinogen, punishable by imprisonment for two, three, or four years. (Health & Saf. Code, § 11379, subd. (a).)
   
9. Makes it a felony to transport any Schedule III controlled substance that is a narcotic, or a Schedule III hallucinogen, within this state from one county to another noncontiguous county punishable by imprisonment for three, six, or nine years. (Health & Saf. Code, § 11379, subd. (b).)
   
10. Defines “narcotic drug” as any of the following, whether produced directly or indirectly by extraction from substances of vegetable origin, or independently by means of chemical synthesis, or by a combination of extraction and chemical synthesis:
    
    1. Opium and opiate, and any salt, compound, derivative, or preparation of opium or opiate; or any salt, compound, isomer, or derivative, whether natural or synthetic of opium or opiate, but not including isoquinoline alkaloids of opium;
       
    2. Opium poppy and poppy straw;
       
    3. Coca leaves and any salt, compound, derivative, or preparation of coca leaves, but no including deconcainized coca leaves or extractions of coca leaves which do not contain cocaine or ecgonine;
       
    4. Cocaine or ecgonine, whether natural or synthetic, or any salt, isomer, derivative, or preparation thereof; or,
       
    5. Acetylfentanyl, the thiophene analog thereof, derivatives of either, and any salt, compound, isomer, or preparation of acetylfentanyl or the thiophene analog thereof. (Health & Saf. Code, § 11019.)

FISCAL EFFECT:

Unknown

COMMENTS:

1. Author's Statement: According to the author, “California has become a leader in cracking down on the illegal drug trafficking that has been negatively affecting our neighborhoods and communities. When sold outside of legitimate medical channels, ketamine use lacks the necessary supervision to ensure safety. Without appropriate dosing and monitoring, it increases the risk of harmful outcomes. Prolonged use of ketamine has been linked to cognitive impairment, memory loss, and psychological issues, including anxiety, depression, and hallucinations. AB 837 is a common-sense measure to ensure this controlled substance is regulated by the appropriate forces when it comes to transporting it into this state and leaves the ability for it to still be used for legitimate medical purposes.”
   
2. Ketamine: Ketamine is a dissociative anesthetic that is used both medically and recreationally. According to the Drug Enforcement Administration (DEA):
   

Ketamine distorts the perception of sight and sound and makes the user feel disconnected and not in control. It is referred to as a “dissociative anesthetic hallucinogen” because it makes patients feel detached from their pain and environment.

Ketamine can induce a state of sedation (feeling calm and relaxed), immobility, relief from pain, and amnesia (no memory of events while under the influence of the drug) and is used for the dissociative sensations and hallucinogenic effects.^[1]

Ketamine is used medically to treat psychological disorders, notably treatment-resistant anxiety and depression.^[2] A professor of psychiatry at the Yale School of Medicine said, “Ketamine is possibly the major advance in the area of psychiatry in the past fifty year, but it’s not without risk… The reality is it is an amazing treatment for many people, but we also know that it is a drug that people misuse and will abuse.”^[3]

For decades, ketamine has been popular as a party drug,^[4] and research suggests its use in the United States is on the rise.^[5] Available as a powder or liquid, it can be injected, mixed in drinks, smoked, or snorted.^[6] Although often used in isolation, ketamine has been found in combination with other drugs such amphetamine, cocaine, fentanyl, MDMA, and methamphetamine.^[7] The DEA has also identified it as a drug used to facilitate sexual assault.^[8]

Ketamine use is not without risks. Ketamine has the potential for low to moderate physical dependence or high psychological dependence.^[9] An overdose can cause loss of consciousness and dangerously slowed breathing—and, on rare occasions, death.^[10] The DEA reported six deaths from ketamine overdose between 2020 and 2022.^[11] A recent study found that, of a total of 228,668 drug overdose deaths between July 2019 and June 2023, ketamine was the only drug detected in toxicology reports in just 24 overdose deaths.^[12] That same study found that roughly 82% of deaths in which ketamine was detected on toxicology reports involved other drugs.^[13] The majority of those deaths involved illicit fentanyl.^[14]

1. Effect of the Bill: Ketamine is a Schedule III controlled substance under the California Uniform Controlled Substances Act. It is not a narcotic. (See Health & Saf. Code, § 11019.) With the exception of ketamine and Schedule III hallucinogenic substances, possession for sale of a non-narcotic Schedule III substance is punishable by imprisonment of up to three years, and sale is punishable by imprisonment of up to four years. (Health & Saf. Code, §§ 11378, subd. (a); 11379, subd. (a).) Existing law also makes transport, import into this state, sale, furnishing, administering, or giving away, or offering to do any of those things, or attempting to import into this state or transporting any non-narcotic Schedule III substance, with the exception of ketamine and Schedule III hallucinogenic substances, punishable by imprisonment for up to four years. (Health & Saf. Code, §§ 11352, subd. (a); 11379, subd. (a).)
   
   Ketamine is treated differently than other non-narcotic Schedule III controlled substances. Existing law makes possession of ketamine a misdemeanor punishable in county jail for up to one year. (Health & Saf. Code, § 11377, subd. (a).) Possession of ketamine for sale or sale of ketamine is a wobbler punishable by up to one year in county jail or 16 months, two years, or three years in state prison. (Health & Saf. Code, § 11379.2.) With the passage of Proposition 36 (2024), a person who sells, furnishes, administers, or gives away ketamine to another who subsequently suffers significant and substantial physical injury from the drug is eligible for an enhancement of up to three years in state prison. (Pen. Code, § 12022.7, subd. (f)(2).) Under existing law, however, ketamine is specifically excepted from penalties for transporting, furnishing, administering, or giving it away.
   

This bill would make transporting, furnishing, administering, or giving away ketamine punishable by imprisonment for 16 months, two years, or three years. This bill would also make possession for sale and sale of ketamine a realigned felony—people serve their time in county jail rather than state prison unless they have a prior strike or sex-registrable offense.

1. Harsher Sentences for Drug Trafficking Unlikely to Reduce Drug Use or Deter Criminal Conduct: Ample research on the impact of increasing penalties for drug offenses on criminal behavior has called into question the effectiveness of such measures. In a report examining the relationship between prison terms and drug misuse, PEW Charitable Trusts found “[n]o relationship between drug imprisonment rates and states’ drug problems,” finding that “high rates of drug imprisonment did not translate into lower rates of drug use, arrests, or overdose deaths.”^[15]
   
   Unduly long sentences are counterproductive for public safety and contribute to the dynamic of diminishing returns as the incarcerated population expands.^[16] The Council on Criminal Justice reviewed the evidence on the effect of harsher punishments on criminal behavior and came to the same conclusion, noting specifically with regards to drug crimes:
   

The empirical evidence on selective incapacitation suggests that long sentences may produce short- and long-term public safety benefits for individuals engaged in violent offending, but may produce the opposite effect for those engaged in drug-related offending…where an incarcerated individual is quickly replaced by a new recruit. This “replacement effect” occurs—and undermines the overall crime-reducing effects of incapacitation—when there is “demand” for a particular criminal activity. The illicit drug business offers the most obvious example: when someone who plays a role in a drug trafficking organization is incarcerated, someone else must take his or her place…^[17]

According to PEW, “[A] large body of prior research…cast[s] doubt on the theory that stiffer prison terms deter drug misuse, distribution, and other drug-law violations.”^[18] PEW concludes:

Putting more drug-law violators behind bars for longer periods of time has generated enormous costs for taxpayers, but it has not yielded a convincing public safety return on those investments. Instead, more imprisonment for drug offenders has meant limited funds are siphoned away from programs, practices, and policies that have been proved to reduce drug use and crime. (Ibid.)

Based on this research, one might reasonably question whether increasing penalties for trafficking ketamine would meaningfully impact the drug’s availability or the number of people who use it.

1. Argument in Support: According to the California District Attorneys Association: “Currently, ketamine is classified as a Schedule III controlled substance under Health and Safety Code Section 11056(f), but it is not included in the existing list of substances covered under Section 11352. This has created a legal loophole, preventing law enforcement and prosecutors from effectively addressing illicit ketamine trafficking under the same penalties applicable to Schedule I and II drugs.
   
   “AB 837 corrects this oversight by ensuring that unauthorized distribution and trafficking of ketamine are subject to felony penalties under Section 11352, bringing it in line with other dangerous and widely abused substances. Specifically, this bill will:

• Enhance Public Safety. Ketamine is increasingly being abused recreationally and has been linked to drug-facilitated sexual assault (“date rape drug”). Strengthening criminal penalties for illegal ketamine distribution will help deter illicit sales and trafficking
  
• Close a Legal Loophole. Despite its classification as a Schedule III substance, ketamine has not been subject to the same penalties as other dangerous drugs. This bill aligns ketamine penalties with those applied to Schedule I and II substances, preventing criminals from exploiting gaps in current law (Section 11352(a)).
  
• Increase Criminal Penalties for Unlawful Distribution. Individuals who unlawfully transport, sell, or distribute ketamine will face three (3), four (4), or five (5) years in county jail, and if the transport occurs between noncontiguous counties, the penalty will increase to three (3), six (6), or nine (9) years (Section 11352(a)-(b))…
  

“AB 837 is a critical step in addressing the growing threat of illicit ketamine distribution. By amending Section 11352, this bill provides law enforcement and prosecutors with the necessary legal tools to combat illegal ketamine trafficking and protect public safety.”

1. Argument in Opposition: According to the Drug Policy Alliance, “Current Health & Safety Code 11379.2 makes it a criminal offense to possess ketamine for sale, punishable by up to 3 years of incarceration. If an individual is not a U.S. citizen, any conviction related to ketamine transportation, sale, or possession may lead to deportation and family separation, per federal laws. Rather than wasting money and lives on incarceration, California should invest in public education, harm reduction strategies and improved access to drug treatment paid for by private and public medical insurance.
   
   “Increased penalties will not result in a safer California, but will create needless suffering for individuals convicted for sharing, transporting or furnishing ketamine, cause social and financial harms for families of those incarcerated, cost taxpayers for additional criminal and correctional system expenditures, and have significant long term economic and social impacts for individuals and communities. Highly publicized crackdowns and prosecutions of person who shared or furnished ketamine will make it less likely that people will call 911 or seek emergency medical care when they witness a medical crisis involving the drug.
   
   “Ketamine is a Schedule III medication. Classified as a short-acting analgesic, it is used to promote sedation during and after surgery. It is also used to treat severe depression, PTSD, and substance use disorders. In medical settings, ketamine is considered safe and effective and the World Health Organization lists it as an essential medicine. Veterans suffering severe depression, or thoughts of suicide or self-harm, have benefited from medical supervised ketamine treatment. In some areas, it is available from the Veterans Administration Medical Centers.
   
   “Non-prescription use of ketamine has been common in the United States for decades. However, death from ketamine overdose is rare. A review by the US Centers for Disease Control and Prevention found that ketamine was detected in less than one-half of one percent of all drug overdose deaths in the United States from 2019 to 2023 (0.4%), and in the overwhelming majority of those cases, it was used in combination with other drugs, namely fentanyl, methamphetamine, cocaine or alcohol.
   
   “We all want our loved ones and communities to be safe, but the existing criminal penalty for ketamine possession for sale is already draconian and counterproductive. Increasing the penalties on supply-side drug market activity does not reduce the drug supply, reduce suffering associated with drug use or incarceration, or reduce drug use.
   
   “The Drug Policy Alliance is the leading organization in the U.S. focused on addressing harms of drug use and drug criminalization through a holistic approach to drugs that prioritizes health, equity, social supports and community wellbeing. DPA opposes AB 837 (Davies) as a step backward toward the failed drug war approach to drug problems.”
   
2. Related Legislation:
   
   1. AB 634 (J. Gonzalez), would make tianeptine a Schedule I substance under California’s Uniform Controlled Substances Act (UCSA). AB 634 is pending hearing in this committee.
      
   2. SB 6 (Ashby), would make xylazine, also known as “tranq,” a Schedule III drug under the UCSA. SB 6 is scheduled for hearing today in the Senate Public Safety Committee.
      
3. Prior Legislation:
   1. AB 3029 (Bains), of the 2023-2024 Legislative Session, would have made xylazine, also known as “tranq,” a Schedule III drug under the UCSA, contingent on the federal government adding xylazine to Schedule III of the federal CSA. AB 3029 was held in suspense in the Senate Appropriations Committee.
      
   2. SB 1502 (Ashby), of the 2023-2024 Legislative Session, was nearly identical to SB 6 (Ashby). SB 1502 failed passage in the Assembly Public Safety Committee.
      

REGISTERED SUPPORT / OPPOSITION:

Support

Arcadia Police Officers' Association
Brea Police Association
Burbank Police Officers' Association
California Association of School Police Chiefs
California Coalition of School Safety Professionals
California District Attorneys Association
California Narcotic Officers' Association
California Reserve Peace Officers Association
California State Sheriffs' Association
Claremont Police Officers Association
Corona Police Officers Association
Culver City Police Officers' Association
Fullerton Police Officers' Association
Los Angeles School Police Management Association
Los Angeles School Police Officers Association
Murrieta Police Officers' Association
Newport Beach Police Association
Palos Verdes Police Officers Association
Placer County Deputy Sheriffs' Association
Pomona Police Officers' Association
Riverside Police Officers Association
Riverside Sheriffs' Association
Santa Ana Police Officers Association

Oppose

ACLU California Action
California Public Defenders Association (CPDA)
Californians for Safety and Justice (CSJ)
Californians United for A Responsible Budget
Drug Policy Alliance
Ella Baker Center for Human Rights
Initiate Justice
Initiate Justice Action
Justice2jobs Coalition
Local 148 Los Angeles County Public Defender's Union
San Francisco Public Defender
Sister Warriors Freedom Coalition
Vera Institute of Justice

Analysis Prepared by:

Andrew Ironside / PUB. S. / (916) 319-3744

1. Dept. of Justice/Drug Enforcement Administration, Drug Fact Sheet (Dec. 2024) <https://www.dea.gov/sites/default/files/2020-06/Ketamine-2020.pdf> [last visited Mar. 6, 2025]. ↑

2. Drug Enforcement Administration, Diversion Control Division, Ketamine (Feb. 2024) <https://www.deadiversion.usdoj.gov/drug_chem_info/ketamine.pdf> [last viewed Mar. 19, 2024]. ↑

3. McPhillips, Illicit ketamine on the rise in the US, research suggests, CNN.com (May 24, 2023) https://www.cnn.com/2023/05/24/health/illicit-ketamine-rise-in-us/index.html [last viewed Mar. 19, 2025]. ↑

4. Rogers, What to Know About Ketamine, John Hopkins Bloomberg School of Public Health (Jan. 26, 2024) https://publichealth.jhu.edu/2024/what-to-know-about-ketamine [last visited Mar. 19, 2025]. ↑

5. Palamar, et al., Trends in Illicit Ketamine Seizures in the US From 2017 to 2022, JAMA Psychiatry (May 24, 2023) https://jamanetwork.com/journals/jamapsychiatry/fullarticle/2804864?guestAccessKey=3028fa32-72f0-4705-84de-d7da9c0b62ee&utm_source=For_The_Media&utm_medium=referral&utm_campaign=ftm_links&utm_content=tfl&utm_term=052423#google_vignette [last visited Mar. 19, 2025]. ↑

6. Drug Fact Sheet, supra. ↑

7. Ibid. ↑

8. U.S. Dept. of Justice, Drug Enforcement Administration, Drug-Facilitated Sexual Assault (Apr. 2017) ↑

9. Drug Fact Sheet, supra. ↑

10. Vivolo-Kantor, et al. Notes from the Field: Ketamine Detection and Involvement in Drug Overdose Deaths—United States, July 2019-July 2023, CDC (Nov. 7, 2024) https://www.cdc.gov/mmwr/volumes/73/wr/mm7344a4.htm [last visited Mar. 19, 2025]. ↑

11. Drug Enforcement Administration, Diversion Control Division, Ketamine (Feb. 2024) <https://www.deadiversion.usdoj.gov/drug_chem_info/ketamine.pdf> [last viewed Mar. 19, 2024]. ↑

12. Ibid. ↑

13. Ibid. ↑

14. Ibid. ↑

15. PEW, More Imprisonment Does Not Reduce State Drug Problems (Mar. 2018) p. 5 <https://www.pewtrusts.org/-/media/assets/2018/03/pspp_more_imprisonment_does_not_reduce_state_drug_problems.pdf> [last viewed Feb. 6, 2023]; see generally, Przybylski, Correctional and Sentencing Reform for Drug Offenders (Sept. 2009) < http://www.ccjrc.org/wp-content/uploads/2016/02/Correctional_and_Sentencing_Reform_for_Drug_Offenders.pdf> [last visited Mar. 20, 2023]. ↑

16. Long-Term Sentences: Time to Reconsider the Scale of Punishment, 87 UMKC L.Rev. 1 (Nov. 5, 2018). ↑

17. Long Sentences Task Force, Council on Criminal Justice, The Impact of Long Sentences on Public Safety: A Complex Relationship (Nov. 2022) p. 8 https://counciloncj.org/wp-content/uploads/2022/11/Impact-of-Long-Sentences-on-Public-Safety.pdf [last visited Apr. 24, 2023] [internal citations omitted] [emphasis added]; National Institute of Justice, U.S. Department of Justice, Five Things About Deterrence (June 5, 2016) <https://nij.ojp.gov/topics/articles/five-things-about-deterrence> [last visited Feb. 2, 2023.]. ↑

18. PEW, supra. ↑