Assessing The Provision Of Criminal Indigent Defense

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Assessing the Provision ofCriminal Indigent DefenseG A B R I E L P E T E K L E G I S L AT I V E A N A LY S TSEPTEMBER 2022

AN LAO REPORTiiL E G I S L AT I V E A N A LY S T ’ S O F F I C E

AN LAO REPORTExecutive SummaryIndividuals charged with a crime have a right to effective assistance of legal counsel under theU.S. and California Constitutions. This is to ensure they receive equal protection and due processunder the law. The government is required to provide and pay for attorneys for those individualswho are unable to afford private attorneys. This is known as “indigent defense.”Importance of Effective Indigent Defense. In addition to being a constitutional right,effective indigent defense in criminal proceedings can help mitigate or eliminate majorconsequences that defendants face regardless of whether they are convicted, such as losinga job due to being held in jail until their case is resolved. Effective indigent defense can alsohelp ensure that all individuals are treated equitably in criminal proceedings, particularlylower-income individuals and certain racial groups who are at greater risk of experiencing seriousconsequences from being involved in the criminal justice system.Counties Primarily Responsible for Indigent Defense. In California, counties are primarilyresponsible for providing and paying for indigent defense. However, recent litigation suggests thatthe state could be held responsible for ensuring that effective indigent defense is being provided.Indigent defense is generally provided in a combination of three ways: (1) public defender officesoperated by the government, (2) private law firms or attorneys that contract with the governmentto provide representation in a certain number of cases and/or over a certain amount of time,or (3) individual private attorneys who are appointed by the court to specific cases. The actualprovision of indigent defense services, however, varies by county.State Lacks Information to Assess Indigent Defense Service Levels. The state currentlylacks comprehensive and consistent data that directly measures the effectiveness or quality ofindigent defense across the state. This makes it difficult for the Legislature to ensure effectiveindigent defense is being provided.Analysis of Limited Data Raises Questions About Effective Provision of IndigentDefense. In the absence of consistent statewide data and metrics more directly measuringthe effectiveness or quality of indigent defense, we analyzed limited available data comparingfunding, caseloads, and staffing of indigent defense providers with district attorneys whoprosecute cases, allowing for a rough, indirect assessment of existing indigent defense service.The identified differences are notable enough that they raise questions about the effectiveprovision of indigent defense in California. For example, in 2018-19, spending on district attorneyoffices was 82 percent higher than on indigent defense.Recommend Three Key Steps for Legislative Action. We recommend three key stepsthat the Legislature could take to ensure it has the necessary information to determine whethera problem exists with indigent defense service levels, what type of problem exists, and how toeffectively address such a problem. Specifically, we recommend the Legislature: (1) statutorilydefine appropriate metrics to more directly measure the quality of indigent defense; (2) requirecounties collect and report data to the state’s Office of the State Public Defender; and (3) use thedata to determine future legislative action, such as identifying whether resources are needed toensure effective indigent defense as well as how such resources could be targeted to maximizetheir impact.www.lao.ca.gov1

AN LAO REPORT2L E G I S L AT I V E A N A LY S T ’ S O F F I C E

AN LAO REPORTINTRODUCTIONIndividuals charged with a crime have theconstitutional right to effective assistance of legalcounsel to ensure that they receive equal protectionand due process before being deprived of theirliberty. The government is required to provide andpay for attorneys for those individuals who areunable to afford private attorney representation.This is known as “indigent defense.” In thisreport, we: (1) provide background informationon the provision of indigent defense in California;(2) discuss existing indigent defense service levelsand the lack of information to assess indigentdefense levels; and (3) make recommendations toimprove the state’s oversight of indigent defenseby defining appropriate metrics to more directlymeasure the quality of indigent defense, requiringthe collection and reporting of data, and using suchdata to inform future legislative actions. In preparingthis report, we consulted with indigent defenseproviders, researchers, and other stakeholders.We also analyzed data reported by counties tothe State Controller’s Office and the CaliforniaDepartment of Justice. Finally, we reviewed variouspapers and studies examining indigent defense inCalifornia as well as other jurisdictions.INDIGENT DEFENSE IN CALIFORNIAWhat Is Indigent Defense?Government-Funded Representation ofDefendants Unable to Afford Private Attorneys.The U.S. Constitution prohibits individuals frombeing deprived of life, liberty, or property withoutdue process of law. It also prohibits individualsfrom being denied equal protection under law.The U.S. Constitution further guarantees specificrights to individuals in criminal cases, includingthe right to a speedy trial and the right to have theassistance of an attorney. In combination, theseconstitutional rights have been interpreted to meanthat defendants in criminal cases are entitled toreceive effective assistance from an attorney whentheir life or liberty is at stake, unless this rightis knowingly and intelligently waived. (We note,however, that what specifically constitutes effectiveassistance is generally undefined. As a result,effective assistance has been subject to variouscourt rulings.) If a defendant is unable to affordan attorney, the government is responsible forproviding an attorney to ensure that the defendanthas the opportunity for a fair trial.The California Constitution contains nearlyidentical provisions. State statutes containprovisions to ensure that both federal and stateconstitutional standards are met. For example,www.lao.ca.govif individuals appear without an attorney for theirfirst court hearing (known as arraignment) whichis generally 48 hours from arrest, California courtsare required to (1) inform them of their right to havean attorney before being arraigned at the end ofthe first hearing, (2) ask if they would like to havean attorney appointed, and (3) appoint an attorneyto represent them if they desire one and are unableto pay for their own attorney. Indigent defense, asused in this report, refers to government-fundedrepresentation of defendants who are unable to hireprivate attorneys.How Is Indigent Defense Provided?Representation Provided in Three MajorWays. States have developed systems for providingattorneys to defendants who are unable to payfor representation in criminal cases. In California,indigent defense systems provide representationin one, or a combination, of three ways: (1) publicdefender offices operated by the government,(2) private law firms or attorneys that contractwith the government to provide representation ina certain number of cases and/or over a certainamount of time, or (3) individual private attorneyswho are willing to take on indigent criminalcases and are appointed by the court to specificcases with compensation ordered by the court.3

AN LAO REPORT(As we discuss below, the state recently authorizedthe Office of the State Public Defender [OSPD] toassist trial court indigent defense providers.)office can only represent one defendant in amulti-defendant case.) The second priority is tocounty-contracted private law firms or attorneys.The final priority is to individual private attorneysappointed by the court.Counties Primarily Responsible for IndigentDefense. In California, counties are primarilyresponsible for providing and paying for indigentActual Provision of Indigent Defense Variesdefense services. Most counties use at least twoby County. The provision of indigent defenseof the three ways described above to provideservice varies by county. For example, somerepresentation. California law authorizes countiescounties provide indigent defense representationto establish a public defender office to providethrough criminal defense attorneys primarilyrepresentation within the county. Currently, asfocusing on addressing the immediate legalshown in Figure 1, 34 of the 58 counties havecharge(s) facing the defendant. Other countieschosen to establish public defender offices.provide indigent defense services in a holisticThe remaining counties do not have public defendermanner in which a defendant’s legal issuesoffices. In counties with public defender offices, theare addressed along with underlying social orChief Public Defender is appointed by the countyother needs that could lead to future criminalboard of supervisors unless the board decided theactivity (such as the loss of employment, housingposition was to be elected at the time the office wasneeds, mental health assistance, or immigrationcreated. Currently, only the Chief Public Defenderconsequences). In this holistic defense model,of San Francisco County is elected. State lawdefense attorneys—as well as investigators, socialrequires that public defenders defend individualsworkers, and other staff—work collectively onwho are (1) charged with a criminal offense thata defendant’s case. Additionally, the manner incan be tried in the trial courts and (2) financiallywhich indigent defense staff are used can alsounable to pay for attorney representation. Upon anvary. For example, some public defender officesindividual’s request or a court order, counties mustthat employ social workers use them to connectalso provide representation in otherFigure 1specified cases where liberty maybe at stake, such as mental health34 of 58 Counties Operate Public Defender Officescivil commitments. Counties canCounties With a Public Defender Office (34 Counties)contract with private law firms orAlamedaMontereySanta Cruzattorneys in lieu of, or in additionContra CostaNapaShastato, their public defender offices.El DoradoNevadaSiskiyouFinally, state law authorizes theFresnoOrangeSolanoHumboldtRiversideSonomacourt to determine reasonableImperialSacramentoStanislauscompensation for private attorneysKernSan BernardinoTulareproviding indigent defenseLassenSan DiegoTuolumnerepresentation that must be paid byLos AngelesSan FranciscoVenturaMarinSanJoaquinYolothe county.In counties with populationsof more than 1.3 million people,state law requires courts appointattorneys to defendants in aparticular priority order. Publicdefender offices, if establishedby the county, have first priority.(A public defender office can refusecases in various circumstances.For example, a public defender4MendocinoMercedSanta BarbaraSanta ClaraCounties Without a Public Defender Office (24 Counties)AlpineAmadorButteCalaverasColusaDel erPlumasSan BenitoSan Luis ObispoSan MateoSierraSutterTehamaTrinityYubaL E G I S L AT I V E A N A LY S T ’ S O F F I C E

AN LAO REPORTclients with services while others use them toidentify mitigating factors to assist with clients’ legaldefense (such as a defendant’s history of havingbeen abused).OSPD Recently Authorized to Assist TrialCourt Indigent Defense Providers. OSPDis a state agency that historically representeddefendants appealing their death penaltyconvictions. The mission of the agency wasexpanded in 2020 to include representation intrial court indigent defense cases—which is inaddition to the representation provided by countiesdiscussed previously. Additionally, the state alsoexpanded OSPD’s mission to include providingassistance and training to indigent defenseattorneys as well as other efforts to improve thequality of indigent defense representation. Theextent to which OSPD intends to use this expandedauthority is currently unclear.Why Is EffectiveIndigent Defense Important?Constitutionally Guaranteed Equal Protectionand Due Process Right. As discussed above, theU.S. and California Constitutions guarantee the rightto effective attorney assistance (unless knowinglyand intelligently waived) to ensure that defendantsin criminal proceedings receive equal protectionunder law and due process before being deprivedof life or liberty. The U.S. Supreme Court’s decisionin Gideon v. Wainwright (1963) found that the rightto counsel is “fundamental and essential to fairtrials” in the United States and that defendants whoare too poor to hire attorneys cannot be assuredof a fair trial unless attorneys are provided by thegovernment. The U.S. Supreme Court further notedthat even an intelligent and educated person wouldbe in danger of conviction due to a lack of skill andknowledge for adequately preparing a defense toestablish innocence. As such, effective defensecounsel is necessary to ensure a defendant hasa fair trial against government-funded and trainedprosecutors—irrespective of their income level.Stakeholders argue that the right of due processis important in criminal proceedings becauseprosecutors have significant flexibility to determinewhether and how to charge individuals (such as fora misdemeanor versus a felony), how a defendant’swww.lao.ca.govcase will proceed through the courts, and howcases will be resolved. Stakeholders furtherargue that effective assistance of counsel is evenmore important as the majority of criminal casesare resolved prior to trial—such as through pleabargains. This means these cases are typicallydecided through negotiations between prosecutorsand defendants. Accordingly, without effectiveassistance of counsel, defendants would be at asignificant disadvantage against legally trainedprosecutors and would have difficulty obtaining afair outcome. We note that, in 2019-20, 97 percentof felony cases were resolved prior to trial. Of thisamount, 80 percent were guilty pleas. Similarly,99 percent of misdemeanors were resolved prior totrial over the same time period.Helps Mitigate Potential SeriousConsequences. Research demonstrates thatinvolvement with the criminal justice systemcan have major consequences for defendants,regardless of whether they are ultimately convictedof a crime. For example, various interactions—suchas being arrested, appearing in court routinelyfor proceedings, completing required communityservice, and being incarcerated both pre-trialand post-trial—can have consequences fordefendants’ employment, child custody, housing,or immigration status (such as the loss of legalstatus and deportation). These consequences canhave a disproportionate impact on lower-incomeindividuals. For example, such individuals maynot have jobs willing to provide sufficient timeoff to come to court. As such, these defendantsmay choose to settle a case and avoid losingtheir jobs rather than contesting the case andgoing to trial. These consequences can alsohave a disproportionate impact on certain racialgroups in California as well. This is because thesegroups are more likely to be (1) involved withCalifornia’s criminal justice system due to theracial disparities that currently exist in the systemand (2) lower-income due to economic disparitiesthat have existed historically. (Please see the boxon the next page for additional information onracial disparities in the criminal justice system.)Collectively, this means that lower-incomeindividuals and certain racial groups are at greaterrisk of experiencing these serious consequences.5

AN LAO REPORTRacial Disparities in the Criminal Justice SystemResearch indicates that racial disparities exist at various points of California’s criminal justicesystem—including in law enforcement stops, arrests, and prosecutions. Such racial disparitiesare particularly notable for African Americans and Hispanics. Examples of such research areprovided below.   Stops. In its 2022 annual report, the state Racial Identity and Profiling Advisory Boardevaluated data collected in 2020 from 18 law enforcement agencies, including the 15 largestagencies in California. The board found that a greater proportion of African Americans werestopped (17 percent of stops) relative to their proportion of the population (about 7 percentof the population).   Arrests. In a September 2019 report, the Public Policy Institute of California (PPIC) foundracial disparities in arrests statewide. For example, PPIC found that the African Americanarrest rate in 2016 was three times the white arrest rate. PPIC also found that AfricanAmericans have higher arrest rates than whites in nearly all California counties—with arrestsrates that are on average about six times higher in counties with the largest disparities andnearly two times higher in counties with the lowest disparities.   Felony Prosecutions. In a 2021 report, Judicial Council found that African American andHispanic adults were disproportionately represented in felony defendants. Specifically,African Americans made up 19 percent of felony defendants and about 6 percent of thestate’s adult population. Hispanics made up 45 percent of felony defendants and 36 percentof the state’s adult population.Additionally, research suggests that African Americans and Latinos could also be less likelyto afford a private defense attorney due to economic disparities. Specifically, in a 2016 reportexamining the Los Angeles area, the Federal Reserve Bank of San Francisco—in partnership withseveral universities and research organizations—found that the median net worth of U.S. AfricanAmerican households ( 4,000), Mexican households ( 3,500), and other Latino households( 42,500) were substantially lower than white households ( 355,000).Effective assistance of counsel can help mitigateor eliminate such impacts, which is a factor thataffects whether individuals actually receive equalprotection and due process of law. For example,effective assistance can result in an individual beingreleased from jail pending criminal proceedings thatcan take months or years to conclude. This allowsthe individual to avoid serious life impacts—such aslosing a job or child custody—that otherwise mayhave resulted if the individual remained detained.It also reduces the pressure for individuals to settlecases to avoid such impacts and allows them the6ability to determine whether and how to contesttheir cases, which could result in a not guiltyverdict. Additionally, effective assistance can resultin the identification of mitigating circumstances orrelevant defenses that can lead to better plea deals,lesser charges, or dismissal of cases—all of whichcan help mitigate the major life consequencesthat could be experienced by individuals. As such,effective defense, including indigent defense, isa key tool to help ensure that all individuals aretreated equitably in criminal proceedings.L E G I S L AT I V E A N A LY S T ’ S O F F I C E

AN LAO REPORTRECENT DEVELOPMENTS IMPACTINGINDIGENT DEFENSE IN CALIFORNIARecent Legal ChallengeConcerns have been raised in variousjurisdictions regarding whether effective indigentdefense assistance is being provided. A recentchallenge by the American Civil Liberties Union(ACLU) in California, in which Fresno County andthe state were sued, suggests that the state couldbe held responsible for ensuring that effectiveindigent defense is being provided. Specifically,the state and Fresno County recently settled acase alleging a failure to provide constitutionallyrequired indigent defense service levels. Notably,the court ruled that the state could not say it wasnot responsible for meeting its constitutionalresponsibilities just because the services areprimarily provided by counties. It is unclear theextent to which other counties (and by extensionthe state) could face similar allegations in the future.Below, we discuss the recent legal challenge inmore detail.some of the allegations against it. The court refusedto do so and specifically found that the statecould not say it was not responsible for meetingits constitutional responsibilities just becausethe responsibilities had been delegated to thecounties. The state settled by agreeing to expandthe mission of OSPD so that it would be authorizedto provide support for county indigent defensesystems—including providing training and technicalassistance, and identifying steps to improve thestate’s provision of indigent criminal defense. Thestate also agreed to seek funding through theannual budget process for such purposes. A totalof 4 million from the General Fund was provided in2020-21 ( 3.5 million ongoing) for these purposes.As this case was settled, it is unclear whether otherCalifornia counties are similarly situated—resultingin potential state liability in those cases as well.We note that Fresno County also settled byagreeing to various requirements that it mustcomply with for four years. These requirementsinclude: (1) providing a minimum amount of annualfunding to the Fresno County Public Defender’sOffice, (2) specifying goals for employing a certainnumber of supervisorial staff, (3) regularly reviewingand reporting case files, (4) adopting certainpolicies (such as related to the use of non-attorneyACLU Filed Case Against Fresno County andthe State. The ACLU filed a case against FresnoCounty and the State of California in 2015 allegingthat Fresno County’s indigent defense system failedto comply with minimal constitutional and statutoryrequirements to provide effective assistanceof counsel to indigent defendants. As shownin Figure 2, the lawsuit listedFigure 2nine ways—such as excessivecaseloads and a lack of supportAlleged Ways Fresno County Failed to Providestaff—in which these requirementsEffective Indigent Criminal Defense Service Levelswere allegedly violated. It also Excessive caseloads.asserted that the state abdicated Deprivation of conflict-free and independent representation.its responsibility to ensure thateffective assistance of counsel Lack of continuous representation.for indigent defendants was being Inadequate attorney-client contact and confidential communication.provided by the county. Insufficient or no training for attorneys in the Fresno County Public Defender’s Office.State and Fresno CountySettled Case in January 2020.This case was not fully litigated andultimately settled in January 2020.Prior to settlement, the state filed apetition asking the court to dismisswww.lao.ca.gov Inadequate factual investigation from loss of necessary investigator staffing. Grossly deficient number of support staff in the Fresno County Public Defender’s Office. Lack of parity with prosecutorial counterparts. Failure to monitor and supervise Fresno County’s Public Defense System to ensurecompliance with minimal constitutional and statutory requirements.7

AN LAO REPORTstaff and to trial performance standards), and(5) the regular reporting of specified caseload andother data (such the number of cases openedand closed).Increased State InvolvementDespite primarily being a county responsibility,the state has increased its involvement withthe indigent defense system in recent yearsby providing funding and requiring certainassessments. As discussed previously, the stateexpanded OSPD’s mission to provide trainingand other assistance to trial court indigentdefense counsel. Additionally, the 2020-21budget included 10 million one-time GeneralFund for a pilot program to provide grants toeligible county public defender offices for indigentdefense services. Additionally, the 2021-22 budgetincluded 50 million annually for three years forindigent defense providers to address certainpost-conviction proceedings. The budget alsorequired counties to report on how the fundingwas used and that an independent evaluation beconducted to assess the impact of the providedfunding by August 1, 2025. Finally, Chapter 583 of2021 (AB 625, Arambula) directed OSPD—uponappropriation—to undertake a study to assessappropriate workloads for indigent defenseattorneys and to submit a report with findingsand recommendations to the Legislature byJanuary 1, 2024. The 2022-23 budget subsequentlyprovided 1 million for this purpose.STATE LACKS INFORMATION TOASSESS INDIGENT DEFENSE SERVICE LEVELSIn order to help ensure that effective indigentdefense assistance is being provided, it is importantfor the state to periodically assess indigent defenseservice levels. However, as we discuss below,the lack of consistent data and metrics makes itdifficult to fully evaluate existing service levels atthis time. Although, some available data, whichwe present below, raise questions about theadequacy of current service levels and whether thestate and counties are providing effective indigentdefense assistance.Lack of Consistent Data and Metricsto Fully Evaluate Indigent DefenseService LevelsThe state lacks comprehensive and consistentdata that directly measures the effectivenessor quality of indigent defense representationprovided across the state. This makes it difficultfor the Legislature to assess the specific levels andeffectiveness of indigent defense being providedacross counties.County Choices Impact Data and MetricsCollected. Counties operate independently fromone another and can make very different choices8in the priorities and operations of various countyprograms—including their indigent defensesystems. As a result, counties have taken differentapproaches to evaluating and monitoring theprovision of indigent defense services. This meansthat the type of indigent defense data collected,how it is collected, and how it is used varies bycounty. The specific approach selected generallyreflects how counties plan on using the information.For example, some counties collect data forbudgeting purposes while others may collect datato monitor the quality of service provided (such asto ensure attorneys are not assigned to cases thatexceed their experience levels).Challenges Collecting Data. There arechallenges in collecting data on the quality ofindigent defense. In some cases, counties maynot be collecting data in a robust and usablemanner. For example, technology programs usedby different actors (such as the public defenderoffice, sheriff’s office, or court) may be not beprogrammed to capture certain data. There arealso challenges coordinating data collection fromprivate law firms or attorneys providing indigentdefense. Finally, there are also challenges withL E G I S L AT I V E A N A LY S T ’ S O F F I C E

AN LAO REPORTcollecting consistent data. For example, counties(and their departments) may not define a case ortrack cases in the same manner. The magnitude ofsuch data collection challenges differs by countybased on how each county administers andconducts oversight of indigent defense services.This makes it difficult to fully and fairly evaluate theeffectiveness of indigent service levels currentlybeing provided across the state.Lack of Consensus on Appropriate Metrics.While there appears to be consensus on theoverarching goals of providing effective defenserepresentation, there seems to be a lack ofconsensus in California (and the nation generally)on what metrics should be used to directlymeasure the effectiveness of indigent defenserepresentation—further contributing to the variationin data and metrics collected across counties.This is because there are different ways to measurewhether effective assistance is being provided—such as whether it is legally effective (includingwhether a different outcome could have beenobtained) or perceived to be effective (such aswhether the defendant felt they received adequaterepresentation). (In the box on the next page, wediscuss the various metrics and standards currentlyused across the nation to measure the effectiveprovision of indigent defense representation.)Comparisons of Limited Data RaiseQuestions About Service LevelsAs discussed in the prior section, there is a lackof consensus on what data and metrics shouldbe used to directly measure the effectivenessof indigent defense representation—includingwhether legal effectiveness, the perception ofeffectiveness, and/or some other definition ofeffectiveness should be measured. However,effectiveness is likely correlated with the amountof time and resources available for indigentdefense providers to spend on cases. For example,sufficient resources can enable indigent defenseproviders to spend the time necessary to developa trusting relationship with their clients in order toobtain information that can be critical to a defense,to assess what outcomes are desired (such asto minimize time spent incarcerated or to avoidimmigration consequences), and to assist clients towww.lao.ca.govdetermine how they would like to proceed in theircases. In addition, the ability of indigent defenseproviders to effectively represent their clientscan be undermined if they have significantly lessresources than the prosecutors seeking to convicttheir clients. For example, if indigent defenseproviders have less resources than prosecutors toemploy investigative services, it means they mightnot be able to fully explore mitigating circumstancesthat could impact a client’s defense regardless ofwhether it results in a different outcome. This isbecause a defendant might not feel their case wasfairly and fully argued.In the absence of consistent statewide data andmetrics more directly measuring the effectivenessor quality of indigent defense, we compare limitedavailable data related to the resources available toindigent defense providers as well as the districtattorneys who prosecute cases. We also comparesuch data between counties. Examining differencesin funding, caseloads, and staffing allows for arough, indirect assessment of existing indigentdefense service levels by considering the amounto

The government is required to provide and pay for attorneys for those individuals who are unable to afford private attorneys. This is known as "indigent defense." Importance of Effective Indigent Defense. In addition to being a constitutional right, effective indigent defense in criminal proceedings can help mitigate or eliminate major

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