[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-1-en-105":3,"doc-seo-383833-105":53,"doc-detail-383833-en":126},{"code":4,"msg":5,"data":6},0,"success",[7,14,19,24,29,34,39,44,49],{"id":8,"doc_module":9,"doc_module_name":10,"category_name":11,"show_sort_weight":12,"slug":13},11,1,"Template","Presentations",90,"presentations",{"id":15,"doc_module":9,"doc_module_name":10,"category_name":16,"show_sort_weight":17,"slug":18},12,"Resumes",80,"resumes",{"id":20,"doc_module":9,"doc_module_name":10,"category_name":21,"show_sort_weight":22,"slug":23},14,"Invoices",70,"invoices",{"id":25,"doc_module":9,"doc_module_name":10,"category_name":26,"show_sort_weight":27,"slug":28},15,"Posters",60,"posters",{"id":30,"doc_module":9,"doc_module_name":10,"category_name":31,"show_sort_weight":32,"slug":33},16,"Social Media",50,"social-media",{"id":35,"doc_module":9,"doc_module_name":10,"category_name":36,"show_sort_weight":37,"slug":38},17,"Forms",40,"forms",{"id":40,"doc_module":9,"doc_module_name":10,"category_name":41,"show_sort_weight":42,"slug":43},18,"Letters",30,"letters",{"id":45,"doc_module":9,"doc_module_name":10,"category_name":46,"show_sort_weight":47,"slug":48},21,"Paper Templates",5,"papers-templates",{"id":50,"doc_module":9,"doc_module_name":10,"category_name":51,"show_sort_weight":4,"slug":52},158,"General","general-158",{"code":4,"msg":54,"data":55},"ok",{"site_id":56,"language":57,"slug":58,"title":59,"keywords":60,"description":61,"schema_data":62,"social_meta":119,"head_meta":121,"extra_data":123,"updated_unix":125},105,"en","prisma-legal-center-for-youth-justice-legal-center-letter-to-esc-october-13-2025","Prisma Legal Center for Youth Justice - Legal Center Letter to ESC - October 13, 2025","","Letter from Prisma Legal Center for Youth Justice to members of the Juvenile Regulations Revision Executive Steering Committee, addressing the 2022 Juvenile Titles 15 and 24 Regulations Revision. It commends modernization efforts while requesting clarification and amendments to better protect youth safety, well-being, and rehabilitation. Key issues include eliminating chemical agents, tightening restraint rules, addressing staffing shortages, ensuring cost-free phone access, clarifying visitation limits, improving food standards, correcting outdoor access requirements, and strengthening oversight and inspections by BSCC.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/prisma-legal-center-for-youth-justice-legal-center-letter-to-esc-october-13-2025/383833/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/prisma-legal-center-for-youth-justice-legal-center-letter-to-esc-october-13-2025/383833.png","ImageObject",442,249,{"name":88,"@type":89},"Melati","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-11","2026-09-24",true,{"@type":98,"interactionType":99,"userInteractionCount":79},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"What is the purpose of the letter to the Executive Steering Committee?","Question",{"text":108,"@type":109},"The letter asks for clarification and amendments to the draft regulations revision to improve youth safety, well-being, and successful rehabilitation while modernizing minimum standards for juvenile facilities.","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"Which proposals does the letter emphasize regarding chemical agents?",{"text":113,"@type":109},"It strongly urges eliminating chemical agents and, if elimination is not recommended, establishing strict limits on when and how they can be used, who may use them, and how related data and information are gathered and reviewed.",{"name":115,"@type":106,"acceptedAnswer":116},"What restraint and oversight changes does the letter request?",{"text":117,"@type":109},"It calls for prohibiting prone restraints, banning “the WRAP,” limiting restraint use to imminent danger situations, and clarifying that BSCC inspection and oversight applies and local inspections do not replace BSCC inspections required under the Welfare and Institutions Code.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},383833,1791408871,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":79,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":135,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":27},962085570644,"https://ap-avatar.wpscdn.com/davatar_994ba38a5ba835b3df7d355c54d3ed8d","Prisma  \nLegal Center  \nFor Youth Justice  \nOctober 13, 2025  \nBoard of State and Community Corrections  \nJuvenile Regulations Revision Executive Steering Committee  \nVia email:  \nDear Executive Steering Committee Members:  \nI write on behalf of Prisma Legal Center for Youth Justice (Prisma Legal) regarding the 2022 Juvenile Titles 15 and 24 Regulations Revision. Prisma Legal is public interest, movement law firm that partners with and supports youth justice leaders and organizations.  \nWe commend the Executive Steering Committee’s efforts to modernize these the Minimum Standards for Juvenile Facilities to improve the lives of incarcerated young people. However, several aspects of the drafts warrant further clarification or amendment to ensure youth safety, well-being, and successful rehabilitation.  \nInformation and support for these comments was previously provided to the ESC and working groups, and for the sake of expediency, two prior letters are attached for reference and incorporation in this comment: the July 7, 2022, Youth Law Center Letter (Letter 1) and the September 24, 2024, Prisma Legal Center for Youth Justice Letter (Letter 2) .  \nWhile we believe there is still much work to be done to bring California juvenile facilities in line with best practices and common decency, we also understand that this process has been lengthy, and youth are awaiting the proposed changes. For this reason, we want to highlight some important items for clarification and amendment:  \n• Chemical Agents: The ESC should recommend the elimina[on of chemical agents in juvenile facili[es. If it fails to do so, it must, at a minimum, take significant steps to reduce the use of such weapons, collect data and closely monitor incidents involving chemical agents, and develop a plan to work towards elimina[on.  \n• Physical and Mechanical Restraints: To bring California in line with modern interna[onal standards on the treatment of children, ensure youth safety, and prevent harm, the ESC must 1) prohibit the use of prone restraints, 2) ban use of “the WRAP,” 3) evaluate and specify which physical restraints may be used in juvenile facili[es, and 4) prohibit the use of any restraint (physical or mechanical) except in situa[ons when a youth’s behavior presents an imminent danger of serious harm to self or others.  \n• Staffing Shortages and Noncompliance: The ESC must make it plain that staffing shortages do not excuse noncompliance with other regula[ons in the absence of a documented emergency that meets the defini[on of and follows the process for suspension in Sec[on 1311.  \n• Telephone Access: The ESC must require that youth in juvenile facili[es have regular, no-cost telephone contact with their families, and must prohibit facili[es from condi[oning telephone access to behavior and discipline programs.  \n• Visita9on: Sec[on 1374 must be clarified to ensure that the minimum weekly visita[on requirements are per youth, and not merely the minimum required for a facility’s general visi[ng hours per week.  \n• Food Quality and Quan9ty: The ESC should prohibit the use of jail-based food service or contracts to provide meals to youth in juvenile facili[es. It should addi[onally require that any contract for the provision of food specifically refers to and requires compliance with the minimum standards for juvenile facili[es.  \n• Programs, Recrea9on, and Exercise-Outdoor Access: Address the dracing error in the current proposal that inadvertently changed the outdoor access requirement weekly rather than daily.  \n• Oversight and Inspec9on: The ESC should specify that regula[ons are subject to inspec[on and oversight by the BSCC, and that local inspec[ons do not replace BSCC inspec[ons required pursuant to Welfare and Ins[tu[ons Code § 209.  \nElimination of Chemical Restraints  \nWe strongly urge the Board to prohibit the use of chemical agents in juvenile facilities. Across the country, facility administrators have moved away from these practices due to the severe p","cbCaidVsY4In1Rny","https://ap.wps.com/l/cbCaidVsY4In1Rny","pdf",5329974,171,"English","## Request for clarification and amendments\n## Key provisions raised\n### Chemical agents\n### Physical and mechanical restraints\n### Staffing shortages and noncompliance\n### Telephone access\n### Visitation requirements\n### Food quality and quantity\n### Programs, recreation, exercise, and outdoor access\n### Oversight and inspection","[{\"question\":\"What is the purpose of the letter to the Executive Steering Committee?\",\"answer\":\"The letter asks for clarification and amendments to the draft regulations revision to improve youth safety, well-being, and successful rehabilitation while modernizing minimum standards for juvenile facilities.\"},{\"question\":\"Which proposals does the letter emphasize regarding chemical agents?\",\"answer\":\"It strongly urges eliminating chemical agents and, if elimination is not recommended, establishing strict limits on when and how they can be used, who may use them, and how related data and information are gathered and reviewed.\"},{\"question\":\"What restraint and oversight changes does the letter request?\",\"answer\":\"It calls for prohibiting prone restraints, banning “the WRAP,” limiting restraint use to imminent danger situations, and clarifying that BSCC inspection and oversight applies and local inspections do not replace BSCC inspections required under the Welfare and Institutions Code.\"}]","Prisma Legal Center for Youth Justice - Legal Center Letter to ESC - October 13, 2025 | PDF",1790259572]