Brief of Amici Curiae in Support of Petitioner O.G.
Susan L. Burrell
L. Richard Braucher
Cyn Yamashiro
Markéta Sims
SimpleOriginal

Summary

S.B. 1391, a law keeping 14- and 15-year-olds from adult court, should be considered legal. It aligns with Proposition 57, which lets judges decide on adult trials for teens, aiming to keep more youth in the juvenile justice system.

2020 | State Juristiction

Brief of Amici Curiae in Support of Petitioner O.G.

Keywords adolescent development; juvenile transfers; brain science
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Summary of Argument

Under this Court’s decision in Amwest Surety Ins. Co. v. Wilson (1995) 11 Cal.4th 1243, 1256, it is presumed that the Legislature acted within its authority, and a statute will be upheld “if, by any reasonable construction, it can be said that the statute furthers the purposes” of the initiative. Of course, the court must examine the express statement of purpose included in the initiative. (Ibid.) But also, evidence of its purpose may be drawn from many sources, including the historical context of the amendment, and the ballot arguments favoring the measure. (Ibid, citing California Housing Finance Agency v. Patitucci (1978) 22 Cal.3d 171, 177.)Counsel for Petitioner has exhaustively responded to Real Party’s legal arguments on statutory interpretation and we will not repeat those arguments here. Instead, we will provide historical context and exploration of voter awareness and intent that supports the validity of the S.B. 1391 amendment.

Argument I summarizes the California legislative history of transfer law — its focus on capacity for rehabilitation, as well as longstanding imitations on transfer imposed by making transfer a judicial decision, and setting eligibility at age 16. The argument then turns to the historical interlude occurring between 1994 and 2000, when “get tough” laws permitted transfer at age 14, and, later, mandatory and discretionary transfer by prosecutors. Finally, the argument explores evolving consciousness about treatment of adolescents, research on delinquency, court cases and legislation that formed the context in which voters enacted Proposition 57, reversing the extreme measures of the “get tough” era.

Argument II examines the public discussion surrounding the vote on Proposition 57, and what the voters knew from the text of the measure and the ballot materials.

Argument III concludes that S.B. 1391 was consistent with and furthered the intent of Proposition 57 in subjecting fewer youth to prosecution in the adult system.

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Summary of Argument

This legal brief argues that Senate Bill 1391 (S.B. 1391) aligns with the intent and purpose of Proposition 57, a voter-approved initiative that reformed California's juvenile justice system. The brief asserts that S.B. 1391's provisions, which limit the prosecution of youth in the adult criminal justice system, are consistent with Proposition 57's goal of promoting rehabilitation and reducing the transfer of youth to adult courts. The brief relies on legal precedent, historical context, and analysis of the public discourse surrounding Proposition 57 to support this claim.

Argument I traces the historical evolution of California's transfer law, highlighting the emphasis on rehabilitation and the limitations imposed on transfer, such as the requirement of judicial authorization and the age threshold of 16. The argument then examines the period between 1994 and 2000, marked by a shift towards "get tough" policies that lowered the age for transfer to 14, and introduced mandatory and discretionary transfer options for prosecutors. Finally, the argument explores the evolving understanding of adolescent development, research on delinquency, and legal precedent that contributed to the context in which voters enacted Proposition 57.

Argument II examines the public discourse surrounding Proposition 57, focusing on the information available to voters through the proposition's text and accompanying ballot materials.

Argument III concludes that S.B. 1391 is consistent with and furthered the intent of Proposition 57 by limiting the number of youth subject to prosecution in the adult system.

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Summary of Argument

This brief examines the validity of California Senate Bill 1391, which amended Proposition 57, a ballot initiative enacted in 2016 aimed at reforming juvenile justice in California. The brief argues that the amendment is consistent with and furthers the intent of Proposition 57.

Argument I provides a historical overview of California's transfer law, highlighting its focus on rehabilitation and the limitations imposed on transfers by requiring judicial decisions and setting the eligibility age at 16. The argument then analyzes the "get tough" era between 1994 and 2000, during which the transfer age was lowered to 14, and prosecutors were granted mandatory and discretionary transfer powers. Finally, the brief explores the evolving understanding of adolescent development, delinquency research, court cases, and legislation that formed the context in which voters enacted Proposition 57, reversing the extreme measures of the "get tough" era.

Argument II examines the public discourse surrounding the vote on Proposition 57, focusing on the information voters received from the measure's text and the ballot materials.

Argument III concludes that S.B. 1391, by reducing the number of youth subject to adult prosecution, is consistent with and furthers the intent of Proposition 57.

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Summary of Argument

This legal argument explains why a state law (SB 1391) is valid. It supports the law by looking at its history and how it fits with a previous law passed by voters (Proposition 57).

Argument I discusses the history of California laws about moving young offenders from the juvenile justice system to the adult system (transfer). It shows that these laws have focused on giving young offenders the chance to get better (rehabilitation). The argument then explains how, between 1994 and 2000, stricter laws allowed young people to be transferred to the adult system at age 14, and even let prosecutors decide whether to transfer them. Finally, it talks about how our understanding of how to treat young offenders has changed over time. New research on delinquency, court cases, and laws helped voters understand the problems with the harsher "get tough" laws. This understanding led to the passing of Proposition 57, which reversed those harsh laws.

Argument II then explains what the public knew about Proposition 57 when they voted on it. It looks at the text of the measure and the information voters received during the election.

Argument III concludes that SB 1391 is a good fit with the intention of Proposition 57. SB 1391 limits the number of young people who are prosecuted in the adult system, which aligns with the goal of Proposition 57.

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Summary of Argument

This document supports a new law in California called S.B. 1391.

Laws about youth who break the law have changed over time in California, and usually the focus has been on helping kids get better. But some laws have made it hard to help kids by making it up to judges to decide if a kid should go to adult court. It also says that kids younger than 16 couldn’t go to adult court.

However, there was a time when laws got tougher. Kids as young as 14 could go to adult court, and prosecutors could decide if they should. But over time, people started to learn more about how to help kids and that they aren’t always the same as adults. Scientists studied youth who break the law and lawyers and lawmakers worked on new laws. This helped voters decide to change the laws again and make them less strict. This change is called Proposition 57.

S.B. 1391 is a good idea because it helps Proposition 57 work better. It helps keep fewer kids from going to adult court.

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Footnotes and Citation

Cite

Brief for Amici Curiae Pacific Juvenile Defender Center and Independent Juvenile Defender Program in Support of Petitioner, O.G. v. Superior Court of Ventura County, No. S259011 (Cal. June 12, 2020).

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