For an updated article on dog bites see the American Veterinary Medical Association on Dog Bite Prevention at http://www.avma.org/pubhlth/dogbite/ -or National Center for Injury Prevention and Control at http://www.cdc.gov/ncipc/duip/dogbite.htm
This book has useful information Dogs Bite: But Balloons and Slippers are More Dangerous, by Janis Bradley
For a discussion group see
http://www.pitbull-chat.com/
On 28 May 2009 AKC announced
AKC and dog owners win ruling granting a trial to challenge constitutionality of Denver breed ban.
Most municipalities have long had laws regulating dogs that have a history of excessive aggression or viciousness. More recently however, some agencies have enacted ordinances designating certain breeds as dangerous or vicious. These ordinances may regulate or prohibit certain breeds regardless of the temperament or behavior of the individual animal. This was written in response to the question as to whether it is appropriate to enact a breed specific ordinance.
Breed specific legislation is probably not a practicable approach to regulation of dogs. Breed specific legislation is generally upheld only when it refers to named breeds of dogs and the standards set by recognized breed clubs. Proving that a particular dog falls within the ordinance usually requires expert testimony. Application of breed specific ordinances to mixed breed dogs presents both legal and practical difficulties. Whether even an expert can adequately identify a mixed breed dog is itself subject to controversy.
Regulation defining prohibited dog behavior is probably a more practicable approach than breed specific regulation. Such regulation is more likely to be supported. Properly drafted it has a stronger legal and evidentiary basis. Specificity aids enforcement and understanding of what is necessary to comply.
Dog owners often challenge the constitutionality of breed specific regulations.[ EN1] The challenge is a difficult one because in general the courts defer to lawmakers, upholding legislation when there is some rational connection to the promotion of public safety. Discrimination by breed of dog does not discriminate on the basis of a constitutionally protected class such as race, sex, religion etc. Discrimination, therefore, on the basis of breed of dog is constitutional if there is a rational basis for the classification and a reasonable relationship between the classification and the purpose of the law.
Opponents of breed specific ordinances vigorously deny the rationality of the classification, while proponents just as vigorously support it. In many cases, courts uphold breed specific regulations as constitutional. In some cases, all or parts of regulations have been struck down, primarily on the basis that the language identifying the breed is too vague.
An ordinance is unconstitutionally vague if it encourages arbitrary and erratic law enforcement. A law regulating conduct must give adequate notice of what is prohibited, so that a person knows what is prohibited and so as not to delegate basic policy matters to policemen, judges, and juries for resolution on an ad hoc and subjective basis.[ EN2] Strict precision is not required. The language used, however, must be sufficiently clear that the person subject to its requirements does not have to guess at the meaning. A court will uphold the law if the meaning of the statute is clear to a person of ordinary intelligence.
The breed most often named in breed specific legislation is commonly referred to as a "pit bull." I was not able to find any court that upheld legislation when that term was used alone. The problem with such ordinances is that they don't provide adequate notice of the prohibited conduct.[ EN3] There is no breed known simply as a "pit bull" and therefore no means by which a person could determine whether their dog is of the regulated breed. For the same reason, such an ordinance is too subjective to the individual whim of the enforcing officer.
Nationwide many courts uphold breed specific ordinances when the ordinance defines them by names recognized by national dog breed registry organizations such as the American Kennel Club or the United Kennel Club. The courts note that these organizations publish specific physical characteristics to guide enforcement. These standards provided a basis for examining the physical characteristics of the dog in question and comparing them with breed standards published by the two clubs. A few courts have upheld ordinances that define the breed in question to mean "any dog which exhibits those distinguishing characteristics" that "substantially conform to the standards" established either by the American Kennel Club or United Kennel Club. Other courts have struck such ordinances down as vague because of the difficulty for even experts to determine the breeding of mixed breed dogs.
Whether a dog's temperament can fairly be predicted based upon its breed is a hotly debated issue. Owner's of the specified breeds will undoubtedly argue that a breed specific ordinance is overbroad because "it regulates all owners of dogs of all the named breeds ... despite substantial evidence that viciousness is not a specific breed characteristic." Opponents of breed specific legislation can easily obtain expert testimony as to the gentle, controllable, characteristics of properly bred and reared dogs of the regulated breed. Based on references in both case law and law review articles the statistical data in this area is highly subject to manipulation to support the desired viewpoint.
Even courts that have accepted the argument have not struck down the breed specific ordinance as overbroad. Courts do not require mathematical certainty in the application of ordinances, only that the ordinance be rationally related to a valid public purpose and that the classification further the objectives of the ordinance.
Proponents of breed specific legislation will point out that there is evidence to support their assertion that certain breeds are known for a unique combination of strength, agility, tolerance for pain, and aggressiveness. These breeds are often obtained for these qualities, and the qualities are enhanced by their rearing. They will point that, as a group, certain dogs have a higher incidence of aggression than others and selective treatment is appropriate regardless of whether the cause is nature or nurture. The courts generally accept this as a rational basis for breed specific legislation.
Opponents of breed specific legislation will present evidence showing that viciousness can, and does, occur in any breed of dog.[ EN4] A law is not made unconstitutional simply because it does not cover all possible evils.[ EN5]
A governmental entity legally may be able to single out one or more breeds of dog and impose different requirements on them. An important question, however, is whether this is a practicable endeavor.
Even courts upholding breed specific ordinances note that there may be difficulty in proving that non-registered and or non-purebred dogs are of the defined breed. For example, boxers are often mistakenly identified as pit bulls even by supposed animal experts.[ EN6] A quick glance through a breed book will reveal how much one breed physically resembles another. For mixed breed dogs it may be impossible to determine the dogs actual heredity. In such cases, for example, a part boxer dog can easily be mistaken for a part pit bull. Most courts have placed the burden of proving that a dog is of the specified breed on the enforcing agency.
Dog owner's will assert, and there is evidence to support, the contention that treating all pit bulls as dangerous has "no scientific or empirical basis" and that dangerousness is a function of "environment, training, and upbringing."
Indeed most court's agree that there is no scientific method for determining a dog's breed such as blood test, x-rays or scientific tests." Most court's rely on comparing the degree to which the dog meets the breed standards set by either the American Kennel Club or the United States Kennel Club.
Breed specific legislation is not a practicable approach to regulation of dogs. Breed specific regulations may alleviate the anxieties of those who are particularly concerned about the reputation of particular dog breeds. Breed specific regulation is very controversial and difficult to administer. It requires training of enforcement personnel in the identification of those breeds and in distinguishing those breeds from others. It might not be possible to enforce such ordinances against mixed breed dogs that had only some of the physical characteristics of the named breed. Breed specific regulation is usually intended to avoid specific types of behavior believed to predominate in the breed. Whether aggression or other behaviors are so predictable in certain breeds as to justify separate treatment of the breed is a hotly debated topic.
Available statistical evidence is poor and, therefore, readily subject to manipulation to support the desired point of view. Opponents of breed specific legislation will point out that such regulation fails to adequately address the problem (aggressive dogs). They are also likely to argue that it treats unfairly owners of the specified breeds when the individual animal does not exhibit the feared characteristics. Proponents are likely to present statistical or testimonial evidence and argue that it supports treating certain breeds according to group characteristics even if it excludes individual dogs not exhibiting the undesirable behavior.
A more direct approach is to regulate the behavior. This has the advantage of wider acceptance and clearer standards resulting in easier administration. Legislation focusing on inappropriate and prohibited dog behavior is readily supportable legally, and creates fewer evidentiary problems. It also more directly addresses the concerns intended to be addressed by breed specific legislation.
Note: THE HYBRIDS HOWL: LEGISLATORS LISTEN -- THESE ANIMALS AREN'T CRYING WOLF Barbara J. Kramek 23 Rutgers L.J. 633 Copyright (c) 1992 by the Rutgers School of Law - Camden; Barbara J. Kramek
THE JURISPRUDENCE OF GENETICS Rochelle Cooper Dreyfuss & Dorothy Nelkin 45 Vand. L. Rev. 313 Copyright (c) 1992 by the Vanderbilt Law Review, Vanderbilt University School of Law; Rochelle Cooper Dreyfuss and Dorothy Nelkin
Comment: THE NEW BREED OF MUNICIPAL DOG CONTROL LAWS: ARE THEY CONSTITUTIONAL? Lynn Marmer 53 U. Cin. L. Rev. 1067 University of Cincinnati Law Review 1984 Copyright (c) 1984 by the University of Cincinnati; Lynn Marmer
DOG FEDERATION OF WISCONSIN, INC. v. CITY OF SOUTH MILWAUKEE (1993) 178 Wis.2d 353, 504 N.W.2d 375 DOG FEDERATION OF WISCONSIN, INC., Glenn Whitcomb, Mary Pat Dempsey, Delores Fenelon and Larry Fax, Plaintiffs-Appellants, v. CITY OF SOUTH MILWAUKEE, Defendant-Respondent. 178 Wis.2d 353, 504 N.W.2d 375 No. 92- 2131. Court of Appeals of Wisconsin. Submitted on Briefs June 2, 1993. Opinion Released July 20, 1993. Opinion Filed July 20, 1993. Petition for review denied.
CITY OF TOPEKA v. MAYER (1992) 16 Kan.App.2d 567, 826 P.2d 527 CITY OF TOPEKA, Appellee, v. Gwendolyn M. MAYER, Appellant. No. 66715. Court of Appeals of Kansas. Feb. 14, 1992. Review Denied April 21, 1992. 16 Kan.App.2d 567, 826 P.2d 527
OHIO v. FERGUSON (1991) 76 Ohio App.3d 747, 603 N.E.2d 345 The STATE of Ohio, Appellee, v. FERGUSON, Appellant. No. 89AP-27. Court of Appeals of Ohio, Franklin County. 76 Ohio App.3d 747, 603 N.E.2d 345 Decided Dec. 12, 1991.
COLORADO DOG FANCIERS, INC. v. CITY AND COUNTY OF DENVER (1991) 820 P.2d 644) The COLORADO DOG FANCIERS, INC., the American Dog Owners Association, the United Kennel Club, Ken Lee, Colorado Humane Society, Inc., Colorado American Pit Bull Terrier Breeders Association, Inc., Colorado Dog Academy, Inc., Dale and Sue Ellen Fresenberg, Pat Andrasen, Dr. William A. Suro, Russell L. Lopez, and Ambrose and Rama Mallett, Plaintiffs-Appellants and Cross-Appellees, v. The CITY AND COUNTY OF DENVER, Acting By and Through its CITY COUNCIL, John A. Fairman, Manager/CEO of the Department of Health and Hospitals for the City and County of Denver, and Federico Pena, Mayor for the City and County of Denver, Defendants-Appellees and Cross- Appellants. No. 90SA342. Supreme Court of Colorado, En Banc. Nov. 12, 1991.
ROBERTSON v CITY AND COUNTY OF DENVER (1994) 874 P.2d 325, 29 A.L.R.5th 837 Lawrence M. ROBERTSON, Jr., M.D.; Sharon Deatherage; Jeffrey Hecht; and David Jewell, d/b/a Scotties Guns & Militaria, Plaintiffs-Appellees, State of Colorado, ex rel. Duane Woodard, Plaintiff/Intervenor-Appellee, v.The CITY AND COUNTY OF DENVER; Ari Zavaras, Chief of Police of the City and County of Denver; and Manuel Martinez, Manager of Safety and Ex-Officio Sheriff of the City and County of Denver, Defendants-Appellants. No. 93SA91. Supreme Court of Colorado, May 2, 1994.
HOLT v. CITY OF MAUMELLE (1991) 307 Ark. 115, 817 S.W.2d 208 Steele HOLT, Appellant, v. CITY OF MAUMELLE, et al., Appellees. No. 90-352. Supreme Court of Arkansas. Oct. 28, 1991.
GREENWOOD v. CITY OF NORTH SALT LAKE (1991) 817 P.2d 816 Kate GREENWOOD and Andrew Greenwood, personally, and Ralph Greenwood, both personally and as president and members of American Dog Breeders' Association, Inc., Plaintiffs and Appellants, v. CITY OF NORTH SALT LAKE, an incorporated municipality, Defendant and Appellee. No. 890355. Supreme Court of Utah. Sept. 10, 1991.
AMERICAN DOG OWNERS ASSOCIATION, INC. v. CITY OF DES MOINES (1991) 469 N.W.2d 416 AMERICAN DOG OWNERS ASSOCIATION, INC.; Responsible Dog Owners of Iowa, Inc.; and Roger Anderson, Appellants, v. CITY OF DES MOINES, Appellee. No. 89-1725. Supreme Court of Iowa. May 15, 1991.
SINGER v. CITY OF CINCINNATI (1990) 57 Ohio App.3d 1, 566 N.E.2d 190 SINGER et al., Appellants, v. CITY OF CINCINNATI et al., Appellees. No. C- 890060. Court of Appeals of Ohio, Hamilton County. April 25, 1990.
ZUNIGA v. SAN MATEO DEPARTMENT OF HEALTH SERVICES (1990) 218 Cal.App.3d 1521, 267 Cal.Rptr. 755 Richard C. ZUNIGA, Plaintiff and Appellant, v. SAN MATEO DEPARTMENT OF HEALTH SERVICES, Defendant and Respondent. PENINSULA HUMANE SOCIETY, Real Party in Interest. No. A042530. Court of Appeal, First District, Division 1. March 23, 1990.
CITY OF AKRON v. TIPTON. (1989) 53 Ohio Misc.2d 18, 559 N.E.2d 1385 CITY OF AKRON v. TIPTON. Nos. 89 CRB 6541, 89 CRB 6548, 89 CRB 6549, 89 CRB 6551 and 89 CRB 6552. Akron Municipal Court, Ohio. Decided Oct. 31, 1989.
AMERICAN DOG OWNERS ASSOCIATION v. CITY OF YAKIMA (1989) 113 Wash.2d 213, 777 P.2d 1046 AMERICAN DOG OWNERS ASSOCIATION, a nonprofit corporation; Mark R. Johnson and Bonnie Jeannie Johnson, husband and wife; and David Carvo, a single man, individually and on behalf of a class of persons similarly situated, Appellants, v. CITY OF YAKIMA, a Washington municipal corporation, Respondent. No. 56122-2. Supreme Court of Washington, En Banc. Aug. 24, 1989. Reconsideration Denied Oct. 11, 1989.
HEARN v. CITY OF OVERLAND PARK (1989) 244 Kan. 638, 772 P.2d 758, 57 USLW 2642, 80 A.L.R.4th 51 Randy L. HEARN, et al., Appellants, v. The CITY OF OVERLAND PARK, Kansas, Appellee. No. 62045. Supreme Court of Kansas. April 14, 1989.
AMERICAN DOG OWNERS ASSOCIATION, INC. v. CITY OF LYNN. (1989) 404 Mass. 73, 533 N.E.2d 642 AMERICAN DOG OWNERS ASSOCIATION, INC., American Pit Bull Terrier Club of New England and Responsible Dog Owners Defense Committee of Lynn, Inc; Bonny Simone and Grace Walters, individually. v. CITY OF LYNN. Supreme Judicial Court of Massachusetts, Essex. Argued Oct. 4, 1988. Decided Feb. 9, 1989.
GARCIA v. VILLAGE OF TIJERAS (1988) 108 N.M. 116, 767 P.2d 355, 57 USLW 2507 Melvin L. GARCIA, Raymond A. Sanchez, David J. Wilson, Margaret H. Amacker and Duke City Pit Bull Terrier Club, Inc., a non-profit New Mexico corporation, Plaintiffs-Appellants, v. The VILLAGE OF TIJERAS, a municipality of the State of New Mexico, Defendant-Appellee. No. 9424. Court of Appeals of New Mexico. Oct. 11, 1988. Certiorari Denied Dec. 6, 1988
There are a couple of organizations that regularly appear as plaintiffs attempting to overturn such ordinances. For a full discussion of pit bull bans, see Russell G. Donaldson, Annotation, Validity and Construction of Statute, Ordinance, or Regulation Applying to Specific Dog Breeds, Such as "Pit Bulls" or "Bull Terriers", 80 A.L.R. 4th 70 (1989). See generally, Diane K. Hale, Note, Man Bites Dog With Ohio's Vicious Dog Statute, 37 CLEV. ST. L.REV. 119 (1989); Lynn Marmer, Comment, The New Breed of Municipal Dog Control Laws: Are They Constitutional?, 53 U. CIN.L.REV. 1067 (1984); Special Section, Vicious-Dog Legislation -- Controlling the Pit Bull, 13 U. DAYTON L.REV. 267 (1988); Michael A. Oropallo, Comment, Taking The Bite Out Of Pit Bull Attacks: Is There An Answer?, 15 OHIO N.U. L.REV. 83 (1988); Julie A. Thorne, Note, If Spot Bites The Neighbor, Should Dick And Jane Go To Jail?, 39 SYRACUSE L.REV. 1445 (1988).
EN 2 Grayned v. City of Rockford (1972) 408 U.S. 104, 108-109, 92 S.Ct. 2294, 2299, 33 L.Ed2d 222.
EN 3 American Dog Owners Ass'n v. City of Des Moines, 469 N.W.2d 416, 417-418 (Iowa 1991) (ordinance banning Staffordshire Terrier, American Pit Bull Terrier, American Staffordshire Terrier or dogs of any "other breed or mixed breed ... known as pit bulls, pit bull dogs or pit bull terriers"); American Dog Owners Ass'n v. City of Lynn, 404 Mass. 73, 533 N.E.2d 642, 646 (1989) (identification by breed name insufficient) (dictum).
EN 4 See, for example, the following: Pickney & Kennedy, Traumatic Deaths from Dog Attacks in the United States, 69 PEDIATRICS, Feb., 1982, at 193-94. The report identified the following as responsible for human fatalities during the study period from May, 1975 to April, 1980: German Shepherd (16); Husky (9); St. Bernard (8); Bull Terrier (6); Great Dane (6); Malamute (5); Golden Retriever (3); Boxer (2); Dachshund (2); Doberman Pinscher (2); Collie (2); Rottweiler (1); Basenji (1); Chow-Chow (1); Labrador Retriever (1); Yorkshire Terrier (1); mixed and unknown breeds (15). Cited in Comment: THE NEW BREED OF MUNICIPAL DOG CONTROL LAWS: ARE THE CONSTITUTIONAL? by Lynn Marmer 53 University of Cincinnati Law Review 1067 at note 62
EN 5 Roschen v. Ward, 279 U.S. 337, 339, 49 S.Ct. 336, 336, 73 L.Ed. 722; Semler v. Dental Examiners, 294 U.S. 608, 610, 55 S.Ct. 570, 571, 79 L.Ed. 1086; Katzenbach v. Morgan (1966) 384 U.S. 641, 657, 86 S.Ct. 1717, 1727, 16 L.Ed.2d 828.
EN 6 Instances noted at note 61 in The Hybrids Howl: Legislators Listen -- These Animals aren't crying wolf 23 Rutgers Law Journal 633 citing articles by Margaret Cleek, Danger On The Rise!--Part I, --Part II in PURE-BRED DOGS/ AMERICAN KENNEL GAZETTE, Aug. 1991, at 94, and Oct. 1991, at 111 and Nan Weitzman, Welcome To America--The Land Of Dog Laws, GOOD DOG!, Feb. 1991, at 14, 15 and Jacqueline Fraser, Mistaken Identity, DOG FANCY, Feb. 1991, at 25 .
EN 7 The court noted "Appellant's contention that the words "inherent nature" are unclear is without merit. The dictionary defines "inherent" as "structural or involved in the constitution or essential character of something" and "belonging by nature or settled habit." (Webster's Third New Internat. Dict. Unabridged (1961) p. 1163.) We believe that the meaning of the words is commonly accepted. In the context of the ordinance, which defines a dangerous animal as a menace to public safety by reason of training or inherent nature, it is a sufficiently clear description which is susceptible to proof at a hearing."
EN 8 (1) no indication that the puppies threatened human health and safety, as required under the ordinance definition. (2) no evidence that the young puppies had ever harmed each other or engaged in unprovoked attacks on humans or other animals. (3) the unspecified aggressive behavior observed by the county staff failed to support a finding of an inherently dangerous nature, because in the absence of testimony regarding the cause of such behavior, it could be easily attributed to a number of factors including the fact of being caged [i.e. the cause could be the caging, instead of the dogs inherent nature, and it was solely the dogs "inherent nature" for dangerousness that provided the basis for the determination that the puppies were "dangerous animals"].
EN 9 Citing Lockwood, Vicious-Dog Legislation--Controlling the Pit Bull, 13 Univ. Dayton L.Rev. 267, 270, citing a 1987 study. "Thus a dog whose genetic predisposition is to be aggressive may present little or no danger if the dog is well-trained and reasonably supervised, whereas an animal with little innate tendency to bite may become dangerous if improperly trained, socialized, supervised, treated, or provoked." ; Note, The New Breed of Municipal Dog Control Laws: Are They Constitutional? (1984) 53 Cinn.L.Rev. 1067, 1077 [citing a survey showing that "pit bull" type dogs are not uniquely dangerous].)
OK, I said I wasn't going to update the above paper and I really haven't but I wanted to make the certain information available.
On the usenet newsgroup rec.pets.dogs.behavior the question came up about shelter policies of killing all "pitbull" type dogs. The person inquired whether legal action could be taken because of the difficulty in proving the dog was a "pitbull". This resulted in someone responding that it was useless to file a lawsuit. I didn't see it that way and I went to the statutes to see how I could point out some possible avenues to address it. I went to the California Codes website published by the state and I found a number of interesting code sections.
I must stress here. This is what I found as of November 5, 1999. Critical Update! I did not research the law, the interpretation, the statutory history, not did I try to put them in context with other legislation. But if you want to explore the possibilities here are the statutes:
The following are all from the Food and Agriculture Code, State of California
17005. (a) It is the policy of the state that no adoptable animal should be euthanized if it can be adopted into a suitable home. Adoptable animals include only those animals eight weeks of age or older that, at or subsequent to the time the animal is impounded or otherwise taken into possession, have manifested no sign of a behavioral or temperamental defect that could pose a health or safety risk or otherwise make the animal unsuitable for placement as a pet, and have manifested no sign of disease, injury, or congenital or hereditary condition that adversely affects the health of the animal or that is likely to adversely affect the animal's health in the future.
(b) It is the policy of the state that no treatable animal should be euthanized. A treatable animal shall include any animal that is not adoptable but that could become adoptable with reasonable efforts. This subdivision, by itself, shall not be the basis of liability for damages regarding euthanasia.
31108. (a) The required holding period for a stray dog impounded pursuant to this division shall be six business days, not including the day of impoundment, except as follows:
(1) If the pound or shelter has made the dog available for owner redemption on one weekday evening until at least 7:00 p.m. or one weekend day, the holding period shall be four business days, not including the day of impoundment.
(2) If the pound or shelter has fewer than three full-time employees or is not open during all regular weekday business hours, and if it has established a procedure to enable owners to reclaim their dogs by appointment at a mutually agreeable time when the pound or shelter would otherwise be closed, the holding period shall be four business days, not including the day of impoundment.
Except as provided in Section 17006, stray dogs shall be held for owner redemption during the first three days of the holding period, not including the day of impoundment, and shall be available for owner redemption or adoption for the remainder of the holding period.
(b) Any stray dog that is impounded pursuant to this division shall, prior to the killing of that animal for any reason other than irremediable suffering, be released to a nonprofit, as defined in Section 501(c)(3) of the Internal Revenue Code, animal rescue or adoption organization if requested by the organization prior to the scheduled killing of that animal. In addition to any required spay or neuter deposit, the pound or shelter, at its discretion, may assess a fee, not to exceed the standard adoption fee, for animals released.
31683. Nothing in this chapter shall be construed to prevent a city or county from adopting or enforcing its own program for the control of potentially dangerous or vicious dogs that may incorporate all, part, or none of this chapter, or that may punish a violation of this chapter as a misdemeanor or may impose a more restrictive program to control potentially dangerous or vicious dogs, provided that no program shall regulate these dogs in a manner that is specific as to breed.
There are three things to note: (1) a dog cannot be presumed vicious based on breed, nor can it be more restricted based on breed. (2) a shelter must release a dog to a qualified rescue if the rescue asks for the dog, the excpetion being "irremediable suffering" and (3)) an explicit State policy of adopting out adoptable animals.
Since the statute 17005 may at first appear only to "estrays" because of its placement, it is important to note that the subsequent seciont 17006 is expressly referred to in F&A codes 31108, 31752, 31753, and 31754. The only logical conclusion is that the chapter containing section 170005 and 17006 does not necessarily apply only to livestock. Research into the legislative history would be necessary to support this.
SB861 has changed things.
Governor Schwarzenegger has signed SB861 into law. Beginning January 1, 2006 local governments will be able to pass breed-specific mandatory spay/neuter ordinances, and several have already announced their intentions to enact such measures. There is a referendum move to try to block enactment of that law.
Get more information from Chako - Dog Lobby and Advocacy also see the website to Defeat SB 861
Note: I reserve the right to make public any responses whether by e-mail or other means.
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