Subject: Eureka City Council Bill No. 731-C.S.
From: Brenda Grantland
Date: Mon, 02 Aug 2004 21:37:32 -0700
To: virginia@ci.eureka.ca.gov, kerrigan@ci.eureka.ca.gov, mbwolford@ci.eureka.ca.gov, jleonard@ci.eureka.ca.gov, mjones@ci.eureka.ca.gov, dtranberg@ci.eureka.ca.gov, plavallee@ci.eureka.ca.gov

Forfeiture Endangers American Rights
Brenda Grantland, Board President
20 Sunnyside Suite A-419
Mill Valley CA 94941
(415)389-8551
www.fear.org
                                                                                        August 2, 2004
                                                                              
                                                                                         Re:  City Council Bill 731-C.S.

Dear Eureka City Councilmembers:

I am not a resident of your city, but I appear in court there periodically as an attorney.  I have two decades of expertise on the issue of asset forfeiture which I would like to share with you in your consideration of Bill 731-C.S.  As a private attorney (sole practitioner) I have 21 years' experience defending forfeiture cases.  I also serve as president of the Board of Directors of the national nonprofit organization Forfeiture Endangers American Rights.  My organization and I have been key consultants on several important pieces of forfeiture reform legislation -- including California's AB-114 (the Burton bill) which reformed state law in 1994, and the Civil Asset Reform Act of 2000 (Rep. Henry Hyde's bill), which reformed federal forfeiture law in April 2000.  In my private practice I have litigated the constitutionality of various forfeiture schemes.  My civil rights suit against the forfeiture procedures and practices of the District of Columbia in implementing their first forfeiture law was filed in 1987.  That case is still pending -- on the issue of the attorneys fees the District owes us for 17 years of litigation.

I am writing you to urge you not to pass this bill, and especially not without extensive public hearings weighing the pros and cons of this legislation. 

For several reasons I believe your ordinance is unconstitutional under the U.S. and California constitutions. 
  1. Although I have not studied this issue in detail, it is my opinion that cities and counties do not have the authority under the balance of powers in the state constitution to enact punitive criminal legislation like this ordinance.  Under the doctrine of preemption, state criminal law controls, and your ordinance is in conflict with the state criminal law in several respects.  It would be insane and unworkable for this country to become a patchwork of conflicting criminal laws that vary from burg to burg as travellers make their way around the countryside.
  2. This ordinance is too vague and confusing to give fair notice of what conduct could legally result in forfeiture of a car.  If the language of a statute is so overbroad,  vague or confusing that it does not give fair notice of what is prohibited, it is void for vagueness.
  3. The conflict of interest created by allowing the police and prosecutors to profit financially has been the subject of several lawsuits.  Two members of FEAR's Board of Directors -- Vice President Scott Bullock (at the Institute for Justice, Washington D.C.) and member Mark Clausen, a sole practitioner in Windsor, California -- have each obtained rulings at the trial level, holding the forfeiture scheme unconstitutional when the prosecutor and police stand to profit from the forfeitures. 
  4. The lack of a prompt post-seizure hearing was grounds for declaring a similar N.Y. ordinance unconstitutional in Krimstock v. Kelly, 306 F.3d 40 (2nd Cir. 2002) cert. denied 539 U.S. 969 (2003).  The same issue was resolved in property owners' favor in my 17-year old case, Patterson v. District of Columbia, in an opinion published in 1989. 
  5. If your city passes this ordinance they can expect litigation over these constitutional issues.  That litigation expense should be figured into the costs when computing the potential profitability of such an ordinance.
A city-wide forfeiture ordinance like this one is also bad law enforcement policy.
  1. There has never been any evidence that forfeiture statutes or ordinances are effective in deterring crime.  Emperical studies conducted by social scientists show the opposite -- that it diverts law enforcement attention away from solving crime to seizing property for the income it generates.
  2. In a smaller community such as Eureka, the number of law enforcement personnel diverted to run a forfeiture sting operation is substantial, resulting in a serious drain on crime fighting resources.  Forfeiture sting operations require undercover officers watching or participating in petty crimes in order to build the evidence to seize property.  Once they decide they have probable cause to seize, another team of officers is pulled off their crime fighting duties to seize the car and transport it.  It may take a dozen officers to take down a suspect and bring in one car, with hours spent on paperwork and subsequent court activities to perfect the forfeiture.  This is a big investment for a petty crime, and not cost-effective.
  3. Studies show that forfeiture schemes like this usually lose money rather than make money.  The average car seized under such statutes is usually worth $1,000 to $2,000 or less depending on the demographics of the area.  The towing and storage costs eat up the value while the car is detained pending forfeiture proceedings.  This draft ordinance tries to shift the storage and towing costs to the property owner even if the government declines to prosecute.  That feature of the ordinance is also likely to be challenged in the courts.
For these reasons, you should scrap your plans for passing a forfeiture ordinance.  At the very least you should hold public hearings with reasonable notice to allow us, and other concerned citizens and Eureka residents, to present our case to you in person.  If you hold these hearings and hear our evidence I believe you will agree it would not be wise, or just, or Constitutional to pass this ordinance.

Please visit the FEAR website (www.fear.org) for more information. 

Sincerely,

Brenda Grantland