BSCC
San Luis Obispo Probation (2023-2024 inspection cycle)
Read the report at San Luis Obispo Probation ↗
June 25, 2024
Robert Reyes, Chief Probation Officer
San Luis Obispo Probation Department
1065 Kansas Avenue
San Luis Obispo, CA 93405
2023-2024 TARGETED INSPECTION, WELFARE & INSTITUTIONS CODE SECTIONS
209 & 885, SAN LUIS OBISPO COUNTY PROBATION DEPARTMENT DETENTION
FACILITIES
Dear Chief Reyes:
A Targeted Inspection of the San Luis Obispo County Probation Department Juvenile
Services Center has been completed. A pre-inspection briefing was held on Tuesday,
April 2, 2024, and the following facilities were inspected on Wednesday, June 19, 2024:
FACILITY NAME BSCC # FACILITY TYPE
San Luis Obispo Juvenile Hall (JH) 7539 JH
San Luis Obispo Coastal Valley Academy (CVA) 7540 CAMP
San Luis Obispo SYTF CVA 7541 SYTF
San Luis Obispo SYTF JH 7543 SYTF
These inspections were conducted pursuant to Welfare and Institutions Code Sections
209 and 885 to determine compliance with the Minimum Standards for Juvenile Detention
Facilities as outlined in Title 15, California Code of Regulations.
INSPECTION RESULTS
We identified no items of noncompliance with Title 15 Minimum Standards. Refer to the
attached Procedures Checklist for detailed information.
An Exit Briefing with your staff was held on Wednesday, June 19, 2024; BSCC staff
presented an inspection overview and discussed technical assistance and best practice
recommendations.
* * *
Please email me at elizabeth.gong@bscc.ca.gov or call (916) 704-2503 if you have any
questions.
Robert Reyes
Chief Probation Officer
Page 2
Sincerely,
ELIZABETH GONG
Field Representative
Facilities Standards and Operations Division
Enclosures
Cc: Presiding Judge, San Luis Obispo County Juvenile Court*
Chair, Juvenile Justice Commission, San Luis Obispo County*
Chair, Board of Supervisors, San Luis Obispo County*
County Administrator, San Luis Obispo County*
Tom Milder, Assistant Chief Probation Officer, San Luis Obispo Probation
Marguerite Harris, Chief Deputy Probation Officer, San Luis Obispo Probation
*Copies of the inspection are available upon request or online at www.bscc.ca.gov.
7539+ San Luis Obispo Probation JH Camp SYTF LTR 23-24
JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS
Board of State and Community Corrections
PROCEDURES CHECKLIST1
BSCC Code: 7539
FACILITY NAME: San Luis Obispo Juvenile Services Center – Juvenile Hall FACILITY TYPE: JH
PERSON(S) INTERVIEWED: Marguerite Harris – Chief Deputy Probation Officer, Superintendent; Robert Reyes, Chief
Probation Officer; Tom Milder, Assistant Chief Probation Officer; Jennifer Gonzales, Supervisor; Seth Price, Supervisor;
Laureen Kilenberger, Supervisor; Youth: Juan, age 17.
FIELD REPRESENTATIVE: Elizabeth Gong DATE: June 19, 2024
TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1321 STAFFING
Chapter 3, 3.2 Staffing
Each juvenile facility shall:
Chapter 3, 3.2, A-2
(a) have an adequate number of personnel sufficient to
carry out the overall facility operation and its
The facility has 34 Juvenile Supervision
programming, to provide for safety and security of youth
Officers (JSO), four (4) JSO III filled positions
and staff, and meet established standards and
and three (3) Supervising Deputy Probation
regulations;
Officers (SDPO). There are two (2) vacancies
in this series. Of the 34 JSO I/II, four (4) work
☒ ☐ ☐ control and one (1) is a new hire just
completing Core Training.
The staffing patterns remain at 12-hour shifts:
6am to 6pm; 6pm to 6am; 8am to 8pm; 9am
to 9pm; and 10am to 10pm. This allows for
maximum coverage during waking hours to
complete programming and other T15
responsibilities.
(b) ensure that no required services shall be denied
because of insufficient numbers of staff on duty absent Chapter 3, 3.2, A-1
exigent circumstances;
The agency has sufficient staffing levels to
☒ ☐ ☐ meet the needs of this population. On the day
of the inspection, there were 15 youth in
custody, eight (8) in pre-dispositional
detention.
(c) have a sufficient number of supervisory level staff to
ensure adequate supervision of all staff members; Chapter 3, 3.2, A-12
There are three (3) SDPO’s assigned to the
☒ ☐ ☐
facility. The graveyard supervisory staff is a
JSO III who maintains supervision of overall
operations of the facility during their shift.
1 This document is intended for use as a tool during the targeted inspection process; this worksheet may not contain each Title 15
regulation that is required. Additionally, many regulations on this worksheet are SUMMARIES of the regulation; the text on this
worksheet may not contain the entire text of the actual regulation. Please refer to the complete California Code of Regulations,
Title 15, Minimum Standards for Juvenile Facilities, Division 1, Chapter 1, Subchapter 5 for the complete list and text of
regulations.
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(d) have a clearly identified person on duty at all times
who is responsible for operations and activities and has Chapter 3, 3.2, A-3
completed the Juvenile Corrections Officer Core Course
☒ ☐ ☐
and PC 832 training; There is always a SDPO or JSO III on duty
and in charge of the facility.
(e) have at least one staff member present on each living
unit whenever there are youth in the living unit; ☒ ☐ ☐ Chapter 3, 3.2, A-4
(f) have sufficient food service personnel relative to the
number and security of living units, including staff The facility contracts with the SLO County Jail
qualified and available to: plan menus meeting nutritional to provide food services.
requirements of youth; provide kitchen supervision; direct
☒ ☐ ☐
food preparation and servings; conduct related training
programs for culinary staff; and maintain necessary
records; or, a facility may serve food that meets nutritional
standards prepared by an outside source;
(g) have sufficient administrative, clerical, recreational,
medical, dental, mental health, building maintenance, Chapter 3, 3.2, A-7
transportation, control room, facility security and other
☒ ☐ ☐
support staff for the efficient management of the facility, Ancillary personnel are not responsible for
and to ensure that youth supervision staff shall not be youth supervision.
diverted from supervising youth; and,
(h) assign sufficient youth supervision staff to provide
continuous wide awake supervision of youth, subject to Chapter 3, 3.2, A-6
temporary variations in staff assignments to meet special
program needs. Staffing shall be in compliance with a ☒ ☐ ☐ The facility schedules a minimum of 10 JSO’s
minimum youth-staff ratio for the following facility types: during waking hours and six (6) during
sleeping hours.
(1) Juvenile Halls
(A) during the hours that youth are awake, one Chapter 3, 3.2, A-8
☒ ☐ ☐
wide-awake youth supervision staff member on
duty for each 10 youth in detention;
(B) during the hours that youth are confined to their
room for the purpose of sleeping, one wide-awake Chapter 3, 3.2, A-9
☒ ☐ ☐
youth supervision staff member on duty for each
30 youth in detention;
(C) at least two wide-awake youth supervision staff
members on duty at all times, regardless of the Chapter 3, 3.2, A-6
number of youth in detention, unless an
arrangement has been made for backup support ☒ ☐ ☐ The facility operates with a minimum of one
services which allow for immediate response to (1) supervisor/shift leader and six (6) JSO’s on
emergencies; and, duty.
(D) at least one youth supervision staff member on
duty who is the same gender as youth housed in ☒ ☐ ☐ Chapter 3, 3.2, A-10
the facility.
(E) personnel with primary responsibility for other
duties such as administration, supervision of Chapter 3, 3.2, B-3, 4
personnel, academic or trade instruction, clerical, ☒ ☐ ☐
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(2) Special Purpose Juvenile Halls
(A) during hours that youth are awake, one wide- The JH is not Special Purpose.
☐ ☐ ☒
awake youth supervision staff member on duty for
each 10 youth in detention;
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(B) during the hours that youth are confined to their
room for the purpose of sleeping, one wide-awake
☐ ☐ ☒
youth supervision staff member on duty for each
30 youth in detention;
(C) at least two wide-awake youth supervision staff
members on duty at all times, regardless of the
number of youth in detention, unless an
☐ ☐ ☒
arrangement has been made for backup support
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member on
duty who is the same gender as youth housed in ☐ ☐ ☒
the facility.
(E) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical, ☐ ☐ ☒
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(3) Camps
(A) during the hours that youth are awake, one The JH is not a Camp.
☐ ☐ ☒
wide-awake youth supervision staff member on
duty for each 15 youth in the camp population;
(B) during the hours that youth are confined to their
room for the purpose of sleeping, one wide-awake
☐ ☐ ☒
youth supervision staff member on duty for each
30 youth present in the facility;
(C) at least two wide-awake youth supervision staff
members on duty at all times, regardless of the
number of youth in residence, unless
☐ ☐ ☒
arrangements have been made for backup support
services which allow for immediate response to
emergencies;
(D) at least one youth supervision staff member on
duty who is the same gender as youth housed in ☐ ☐ ☒
the facility;
(E) in addition to the minimum staff to youth ratio
required in (h)(3)(A)-(B), consideration shall be
given to the size, design, and location of the camp;
types of youth committed to the camp; and the ☐ ☐ ☒
function of the camp in determining the level of
supervision necessary to maintain the safety and
welfare of youth and staff;
(F) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical, ☐ ☐ ☒
farm, forestry, kitchen or maintenance shall not be
classified as youth supervision staff positions.
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1328 SAFETY CHECKS
Chapter 3, 3.15 Safety Checks
The facility administrator shall develop and implement
policy and procedures that provide for direct visual
The facility uses the Guard 1/Pipe Electronic
observation of youth at a minimum of every 15 minutes,
safety check system. The policy includes an
at random or varied intervals during hours when youth
audit process and staff expectations in terms
are asleep or when youth are in their rooms, confined in
of ‘random and varied’ specific language.
holding cells or confined to their bed in a dormitory.
Operationally, the policy provides direction for
Supervision is not replaced, but may be supplemented
staff in how to use and download the
by, an audio/visual electronic surveillance system
information before, during, and after their shift
designed to detect overt, aggressive or assaultive
to ensure the correct officer is associated with
behavior and to summon aid in emergencies. All safety
the check.
checks shall be documented with the actual time the
check is completed.
Facility administration audits and reviews all
safety checks daily, handling late checks by
staff through a counseling, documented
memo, or other measures internally.
☒ ☐ ☐
We noted there were six (6) late checks in
January 2024, nine (9) in March 2024, and six
(6) in May 2024, all with an average of 3240
checks in a month. We reviewed each
accompanying memo associated with the late
check, which included a video review of the
circumstances. Of the 21 late checks, the
agency found operator or electronic errors of
the system in five (5) instances.
Facility Administration continues to
acknowledge 100% compliance with policy by
recognizing staff who had no late checks in a
given month. In the months reviewed above,
18 staff had perfect checks in January 2024,
19 in March, and 18 in May.
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1354.5 ROOM CONFINEMENT
Chapter 5, 5.8 Room Confinement (RC)
(a) The facility administrator shall develop and
Chapter 5, 5.8, C Procedure for
implement written policies and procedures addressing
implementation of RC
the confinement of youth in their room that are
consistent with Welfare and Institutions Code Section
We reviewed all 15 incidents of Room
208.3. The placement of a youth in room confinement
Confinement in JH (Detention Youth) from
shall be accomplished in accordance with the following
January 2024 to the date of the inspection.
guidelines:
Most involved fights, youth physically
challenging staff or others, or defiance to the
point of an aggressive action or statements.
Of the 15 incidents, five (5) involved one
youth.
The staff monitor the behavior by having
discussions with the youth at minimum of
every 15 minutes and documenting the point
when a youth no longer poses a threat,
demonstrating he or she is ready to
reintegrate and come out of their room. Since
the last inspection, staff no longer wait for BH
staff to remove a youth but rather the on-duty
☒ ☐ ☐ JSO III meets with the youth to establish a
reintegration plan as soon as the youth is
ready.
The implementation and continued use of the
PBIS model of behavior modification allows
youth to confront negative behaviors by
reflection and discussion before a situation
escalates. Facility staff are trained to de-
escalate issues through counseling and
understanding the triggers which escalate bad
behavior. Allowing a youth to self-separate to
take a time out and work on calming behaviors
has been an effective tool as well.
Our review indicated the three (3) incidents of
RC that lasted beyond four (4) hours were
detention youth that continued to be
aggressive and unwilling to participate in a
safety plan and/or reintegration. The other 10
youth (12 incidents) were out of RC in less
than two (2) hours.
(1) Room confinement shall not be used before
other, less restrictive, options have been attempted Chapter 5, 5.8, C-1
and exhausted, unless attempting those options ☒ ☐ ☐
poses a threat to the safety or security of any youth
or staff.
(2) Room confinement shall not be used for the
purposes of punishment, coercion, convenience, or ☒ ☐ ☐ Chapter 5, 5.8, C-2
retaliation by staff.
(3) Room confinement shall not be used to the extent
that it compromises the mental and physical health ☒ ☐ ☐ Chapter 5, 5.8, C-3
of the youth.
(b) A youth may be held up to four hours in room
confinement. After the youth has been held in room Chapter 5, 5.8, C-8
☒ ☐ ☐
confinement for a period of four hours, staff shall do one
or more of the following:
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(1) Return the youth to general population. ☒ ☐ ☐ Chapter 5, 5.8, C-8
Chapter 5, 5.8, C-5, b
(2) Consult with mental health or medical staff. ☒ ☐ ☐ The facility behavior health staff are notified
when a youth is placed on RC and respond
immediately.
(3) Develop an individualized plan that includes the
goals and objectives to be met in order to reintegrate ☒ ☐ ☐ Chapter 5, 5.8, D
the youth to general population.
(4) If room confinement must be extended beyond
four hours, staff shall do each of the following: Chapter 5, 5.8, D-2
(A) Document the reasons for room confinement
and the basis for the extension, the date and time ☒ ☐ ☐
the youth was first placed in room confinement,
and when he or she is eventually released from
room confinement.
(B) Develop an individualized plan that includes
the goals and objectives to be met in order to ☒ ☐ ☐ Chapter 5, 5.8, D-3
integrate the youth to general population.
(C) Obtain documented authorization by the
facility superintendent or his or her designee ☒ ☐ ☐ Chapter 5, 5.8, D-1
every four hours thereafter.
(5) This section is not intended to limit the use of
single-person rooms or cells for the housing of youth Chapter 5, 5.8, A and B-1
☒ ☐ ☐
in juvenile facilities and does not apply to normal
sleeping hours.
(6) This section does not apply to youth or wards in
court holding facilities or adult facilities. ☒ ☐ ☐ Chapter 5, 5.8, B-2
(7) Nothing in this section shall be construed to
conflict with any law providing greater or additional ☒ ☐ ☐
protections to youth.
(8) This section does not apply during an
extraordinary emergency circumstance that requires Chapter 5, 5.8, B-3
a significant departure from normal institutional
operations, including a natural disaster or facility-
☒ ☐ ☐
wide threat that poses an imminent and substantial
risk of harm to multiple staff or youth. This exception
shall apply for the shortest amount of time needed to
address this imminent and substantial risk of harm.
(9) This section does not apply when a youth is
placed in a locked cell or sleeping room to treat and Chapter 5, 5.8, B-4
protect against the spread of a communicable
disease for the shortest amount of time required to
reduce the risk of infection, with the written approval
of a licensed physician or nurse practitioner, when
the youth is not required to be in an infirmary for an ☒ ☐ ☐
illness. Additionally, this section does not apply when
a youth is placed in a locked cell or sleeping room for
required extended care after medical treatment with
the written approval of a licensed physician or nurse
practitioner, when the youth is not required to be in
an infirmary for illness.
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1357 USE OF FORCE
Chapter 5, 5.11 Use of Force (UF)
The facility administrator, in cooperation with the
Chapter 5, 5.11, D-2 General Provisions
responsible physician, shall develop and implement
Chapter 5, 5.11, L Chemical Agents
written policies and procedures for the use of force,
which may include chemical agents. Force shall never
We reviewed all four (4) UF incidents since
be applied as punishment, discipline, retaliation or
January 2024 for pre-disposition JH youth.
treatment.
Staff are trained in UF and PBIS to prevent the
(a) At a minimum, each facility shall develop policies and
need for force unless no other options are
procedures which:
available. Of the four (4) UF incidents, none
involved OC spray.
☒ ☐ ☐
The incidents reviewed provided clear
documentation of events leading to the force
option, including attempts to de-escalate.
When medical and mental health staff are on-
site, they respond immediately. It is noted all
UF incidents are administratively reviewed,
including video review, to determine if the
force was necessary.
Each of the incidents were determined that
appropriate force was used.
(1) restricts the use of force to that which is deemed
reasonable and necessary, as defined in Section 1302 Chapter 5, 5.11, D-5
☒ ☐ ☐
to ensure the safety and security of youth, staff, others
and the facility.
(2) outline the force options available to staff including
both physical and non-physical options and define Chapter 5, 5.11, D-3, 4 and 5
when those force options are appropriate. Chapter 5, 5.11, E Control and Compliance
☒ ☐ ☐ Holds
Chapter 5, 5.11, F Other Hand to Hand Force
Methods
(3) describe force options or techniques that are
expressly prohibited by the facility. Chapter 5, 5.11, D -13 Carotid Hold
☒ ☐ ☐
Chapter 5, 5.11, F-3 Kicking and punching.
(4) describe the requirements of staff to report any
inappropriate use of force, and to take affirmative Chapter 5, 5.11, D-10
☒ ☐ ☐
action to immediately stop it. Chapter 5, 5.11, O-8
(5) define a standardized reporting format that
includes time period and procedure for documenting Chapter 5, 5.11, P-1 through 5
and reporting the use of force, including reporting
requirements of management and line staff and
procedures for reviewing and tracking use of force
incidents by supervisory and or management staff, ☒ ☐ ☐
which include procedures for debriefing a particular
incident with staff and/or youth for the purposes of
training as well as mitigating the effects of trauma that
may have been experienced by staff and /or the youth
involved.
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(6) Include an administrative review and a system for
investigating unreasonable use of force. Chapter 5, 5.11, P-5
The Chief Deputy conducts an independent
☒ ☐ ☐ review of all UF incidents to determine the
need for internal investigation. Their review
includes submitted recommendations by the
supervisor who reviewed video of the incident.
(7) define the role, notification, and follow-up
procedures required after use of force incidents for Chapter 5, 5.11, D-15 Medical and Mental
medical, mental health staff and parents or legal Health
guardians. ☒ ☐ ☐ Chapter 5, 5.11, L-7 OC Spray notifications
Chapter 5, 5.11, L, O-10 Parent notification of
UF
(8) describe the limitations of use of force on pregnant
youth in accordance with Penal Code Section 6030(f) Chapter 5, 5.11, C-1, a
and Welfare and Institutions Code Section 222.
☒ ☐ ☐
This policy addresses known medical
conditions, including pregnant youth.
(b) Facilities that authorize chemical agents as a force
option shall include policies and procedures that: Chapter 5, 5.11, L Chemical Agents
(1) identify who is approved to carry and/or utilize Chapter 5, 5.11, L-1 Trained staff only
chemical agents in the facility and the type, size and ☒ ☐ ☐
the approved method of deployment for those It is noted there have been no incidents of OC
chemical agents. spray use in 2024.
(2) mandate that chemical agents only be used when
there is an imminent threat to the youth’s safety or the Chapter 5, 5.11, L-2
safety of others and only when de-escalation efforts ☒ ☐ ☐
have been unsuccessful or are not reasonably
possible.
(3) outline the facility’s approved methods and
timelines for decontamination from chemical agents. Chapter 5, 5.11, L-6
This shall include that youth who have been exposed Chapter 5, 5.11, L-8
to chemical agents shall not be left unattended until
☒ ☐ ☐
that youth is fully decontaminated or is no longer Policies provide youth are provided a change
suffering the effects of the chemical agent. of clothes within one hour of the incident and
are not left unattended.
(4) define the role, notification, and follow-up
procedures required after use of force incidents Chapter 5, 5.11, L-7 OC Spray notifications
☒ ☐ ☐
involving chemical agents for medical, mental health Chapter 5, 5.11, O-10 Parent notification of UF
staff and parents or legal guardians.
(5) provide for the documentation of each incident of
use of chemical agents, including the reasons for Chapter 5, 5.11, O-2, a-h
which it was used, efforts to de-escalate prior to use,
youth and staff involved, the date, time and location ☒ ☐ ☐
of use, decontamination procedures applied and
identification of any injuries sustained as a result of
such use.
(c) Facilities shall develop policies and procedure which
require that agencies provide initial and regular training Chapter 5, 5.11, C Training
in use of force and chemical agents when appropriate Chapter 5, 5.11, C-1, a
☒ ☐ ☐
that address:
(1) known medical and behavioral health conditions
that would contraindicate certain types of force;
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(2) acceptable chemical agents and the methods of
application. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(3) signs or symptoms that should result in
immediate referral to medical or behavioral health. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(4) instruction on the Constitutional Limitations of
Use of Force. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(5) physical training force options that may require
the use of perishable skills. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(6) timelines the facility uses to define regular
training. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
1361 GRIEVANCE PROCEDURE
Chapter 5, 5.15 Grievance Procedure
The facility administrator shall develop and implement
Chapter 5, 5.15 A
written policies and procedures whereby any youth may
appeal and have resolved grievances relating to any
We reviewed all seven (7) Grievances
condition of confinement, including but not limited to
submitted by youth from January 2024 to the
health care services, classification decisions, program
date of the inspection for JH. The agency
participation, telephone, mail or visiting procedures,
documented a response within one (1) day,
food, clothing, bedding, mistreatment, harassment or
and resolution within five (5) days. All were
violations of the nondiscrimination policy. There shall be
resolved at the Supervisor level or lower with
no time limit on filing grievances. Policies and
no youth requesting appeal to the DCPO.
procedures shall include provisions whereby the facility
Staff responses were fair and appeared
manager ensures:
consistently applied with the other grievances
reviewed for like issues.
☒ ☐ ☐ Facility staff have conversations with the
youth and review video as a matter of
procedure, to ensure the youth understands
and accepts the outcome.
The youth we interviewed in detention, Juan,
indicated he filed a grievance regarding the
loss of his Peer Leadership status due to
tagging in his room. The youth was presented
with his statement that there was no graffiti
upon entry; therefore, he accepted the
consequence even though he stated he did
not do it. We encouraged Juan to continue
through the process to ensure he feels
adequately heard.
(a) a grievance form and instructions for registering a
grievance, which includes provisions for the youth to ☒ ☐ ☐ Chapter 5, 5.15, A
have free access to the form;
(b) the youth shall have the option to confidentially file
the grievance or to deliver the form to any youth ☒ ☐ ☐ Chapter 5, 5.15, G-3
supervision staff working in the facility;
(c) resolution of the grievance at the lowest appropriate
staff level; ☒ ☐ ☐ Chapter 5, 5.15, G
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(d) provision for a prompt review and initial response to
grievances within three (3) business days, grievances Chapter 5, 5.15, E and G
that relate to health and safety issues must be
addressed immediately; The facility has an expectation to respond to
☒ ☐ ☐
the grievance by end of shift or within two (2)
days and resolution within five (5) days. All
were compliant with this expectation.
(1) The youth may elect to be present to explain
his/her version of the grievance to a person not Chapter 5, 5.15, G-6
☒ ☐ ☐
directly involved in the circumstances which led to
the grievance.
(2) Provision for a staff representative approved by
the facility administrator to assist the youth. ☒ ☐ ☐ Chapter 5, 5.15, C
(e) provision for a written response to the grievance
which includes the reasons for the decisions; ☒ ☐ ☐ Chapter 5, 5.15, G-7
(f) a system which provides that any appeal of a
grievance shall be heard by a person not directly Chapter 5, 5.15, F
☒ ☐ ☐
involved in the circumstances which led to the
grievance;
(g) resolution of the grievance must occur within ten (10)
business days unless circumstances dictate a longer Chapter 5, 5.15, G-8
☒ ☐ ☐
time frame. The youth shall be notified of any delay;
and,
(h) the policy shall provide multiple internal and external
methods to report sexual abuse and sexual harassment. ☒ ☐ ☐ Chapter 5, 5.15, G-13
Whether or not associated with a grievance, concerns
of parents, guardians, staff or other parties shall be Chapter 5, 5.15, G-12
☒ ☐ ☐
addressed and documented in accordance with written
policies and procedures within a specified timeframe.
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1371 PROGRAMS, RECREATION, AND
EXERCISE. Chapter 6, 6.2 Programs, Recreation and
Exercise
The facility administrator shall develop and implement
written policies and procedures for programs,
Programs for the pre-dispositional youth in JH
recreation, and exercise for all youth. The intent is to
are facilitated by Restorative Partners (RP),
minimize the amount of time youth are in their rooms or
an In-Custody and Reentry Program for San
their bed area.
Luis Obispo County. Restorative Partners Inc.
serves people impacted by crime through a
continuum of services that focus on mind,
body, and spiritual transformation. The
programs include evidence-based, trauma-
informed approaches that increase self-
esteem, pro-social skills, multi-cultural and
non-violent communication, and life and job
skills. The nonprofit agency offers a
continuum of services to meet the needs in the
community for both youth and adult
populations. The goal for the juvenile facility is
to include gender-specific, trauma-informed,
and evidence-based services to the youth
population.
RP offers a comprehensive program schedule
with numerous opportunities for youth
participation, including: Sunday/Religious
Service; Cooking Programs; Crossroads
(cognitive and evidence-based curriculum
specific to offense); A Window between
Worlds (Healing Program); Book Club; Music
☒ ☐ ☐ Programs; West Garden Program, Art and
Creative Writing; Lumina Alliance Group; Bible
Study; Restorative Justice; Chess Club;
Sports Programs; AA and NA; Meditation;
Ping-Pong; and Tutoring. RP also
acknowledges youth Birthdays (one time a
month) and Peer Leader status (weekly) with
celebrations for the youth. The agency is in the
middle of hiring a new Program Manager for
RP at the facility to ensure coordination of all
the youth activities.
Youth also receive programming services
from the San Luis Obispo Behavior Health
Clinicians and agency staff. These
opportunities include: Individual and Family
Counseling; a comprehensive Cognitive
Behavior Curriculum; Substance Abuse
Treatment; Child and Family Team meetings;
Independent Living; Parent Education and
Support; Off-site Community Activities;
Community Work Service Projects;
Gardening; Culinary Activities; Video, Board
and Card games; Movie Night; High
School/Birthday and Holiday celebrations; In
house employment opportunities; Career Path
Opportunities; Gender-specific programming;
and, PBIS.
It is important to note the agency, in
coordination with the San Luis Obispo Office
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
of Education, has hired a Classified
Coordinator effective June 24, 2024, to assist
graduated students and those not wanting to
complete their K-12 education (age out and
decline services) with post-secondary
opportunities while in the facility.
Juvenile facilities shall provide the opportunity for
programs, recreation, and exercise a minimum of three Chapter 6, 6.2, A-1
hours a day during the week and five hours a day each
☒ ☐ ☐
Saturday, Sunday or other non-school days, of which
one hour shall be an outdoor activity, weather
permitting.
A youth’s participation in programs, recreation, and
exercise may be suspended only upon a written finding Chapter 6, 6.2, A-2
by the administrator/manager or designee that a youth ☒ ☐ ☐
represents a threat to the safety and security of the
facility.
Such program, recreation, and exercise schedule shall
be posted in the living units. ☒ ☐ ☐ Chapter 6, 6.2, A-3
There will be a written annual review of the programs,
recreation, and exercise by the responsible agency to Chapter 6, 6.2, A-4
ensure content offered is current, consistent, and
relevant to the population. ☒ ☐ ☐ The most recent annual review of programs
was completed by Valerie Vega, Restorative
Justice Manager II, completed in June 2024.
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(a) Programs. All youth shall be provided with the
opportunity for at least one hour of daily programming to Chapter 6, 6.2, B-1, a - c
include, but not be limited to, trauma focused, cognitive,
evidence-based, best practice interventions that are
culturally relevant and linguistically appropriate, or pro-
social interventions and activities designed to reduce
recidivism. These programs should be based on the
youth’s individual needs as required by Sections 1355
and 1356. Such programs may be provided under the
direction of the Chief Probation Officer or the County
Office of Education and can be administered by county
partners such as mental health agencies, community
based organizations, faith-based organizations or
Probation staff.
Programs may include but are not limited to:
(1) Cognitive Behavior Interventions;
(2) Management of Stress and Trauma; ☒ ☐ ☐
(3) Anger Management;
(4) Conflict Resolution;
(5) Juvenile Justice System;
(6) Trauma-related interventions;
(7) Victim Awareness;
(8) Self-Improvement;
(9) Parenting Skills and support;
(10) Tolerance and Diversity;
(11) Healing Informed Approaches;
(12) Interventions by Credible Messengers;
(13) Gender Specific Programming;
(14) Art, creative writing, or self-expression;
(15) CPR and First Aid training;
(16) Restorative Justice or Civic Engagement;
(17) Career and leadership opportunities; and,
(18) Other topics suitable to the youth population.
(b) Recreation. All youth shall be provided the opportunity
for at least one hour of daily access to unscheduled Chapter 6, 6.2, C-1
activities such as leisure reading, letter writing, and ☒ ☐ ☐
entertainment. Activities shall be supervised and include
orientation and may include coaching of youth.
(c) Exercise. All youth shall be provided with the
opportunity for at least one hour of large muscle activity Chapter 6, 6.2, D-1
each day.
Youth in each program participate in one hour
of Physical Education during the school day
☒ ☐ ☐
facilitated by the SLOCOE. Because
graduated youth are still in the classroom,
they participate in exercise with Court School
youth.
The administrator/manager may suspend, for a period
not to exceed 24 hours, access to recreation and Chapter 6, 6.2, D-3
programs. The administrator/manager shall document ☒ ☐ ☐
the reasons why suspension of recreation and programs
occurs.
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JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS
Board of State and Community Corrections
PROCEDURES CHECKLIST1
BSCC Code: 7540
FACILITY NAME: San Luis Obispo Juvenile Services Center: FACILITY TYPE: Camp
Coastal Valley Academy (CVA)
PERSON(S) INTERVIEWED: Marguerite Harris, Chief Deputy Probation Officer, Superintendent; Robert Reyes, Chief
Probation Officer; Tom Milder, Assistant Chief Probation Officer; Jennifer Gonzales, Supervisor; Seth Price, Supervisor;
Laureen Kilenberger, Supervisor; Youth: Jerimiah, age 18.
FIELD REPRESENTATIVE: Elizabeth Gong DATE: June 19, 2024
TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1321 STAFFING
Chapter 3, 3.2 Staffing
Each juvenile facility shall:
Chapter 3, 3.2, A-2
(a) have an adequate number of personnel sufficient to
carry out the overall facility operation and its
The facility has 34 Juvenile Supervision
programming, to provide for safety and security of youth
Officers (JSO), four (4) JSO III filled positions,
and staff, and meet established standards and
and three (3) Supervising Deputy Probation
regulations;
Officers (SDPO). There are two (2) vacancies
in this series. Of the 34 JSO I/II, four (4) work
☒ ☐ ☐ control and one (1) is a new hire just
completing Core Training.
The staffing patterns remain at 12-hour shifts:
6am to 6pm; 6pm to 6am; 8am to 8pm; 9am
to 9pm; and 10am to 10pm. This allows for
maximum coverage during waking hours to
complete programming and other T15
responsibilities.
(b) ensure that no required services shall be denied
because of insufficient numbers of staff on duty absent Chapter 3, 3.2, A-1
exigent circumstances;
The agency has sufficient staffing levels to
☒ ☐ ☐
meet the needs of this population. On the day
of the inspection, there were 15 youth in
custody, three (3) youth in CVA.
(c) have a sufficient number of supervisory level staff to
ensure adequate supervision of all staff members; Chapter 3, 3.2, A-12
There are three (3) SDPO’s assigned to the
☒ ☐ ☐
facility. The graveyard supervisory staff is a
JSO III who maintains supervision of overall
operations of the facility during the shift.
1 This document is intended for use as a tool during the targeted inspection process; this worksheet may not contain each Title 15
regulation that is required. Additionally, many regulations on this worksheet are SUMMARIES of the regulation; the text on this
worksheet may not contain the entire text of the actual regulation. Please refer to the complete California Code of Regulations,
Title 15, Minimum Standards for Juvenile Facilities, Division 1, Chapter 1, Subchapter 5 for the complete list and text of
regulations.
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(d) have a clearly identified person on duty at all times
who is responsible for operations and activities and has Chapter 3, 3.2, A-3
completed the Juvenile Corrections Officer Core Course
☒ ☐ ☐
and PC 832 training; There is always a SDPO or JSO III on duty
and in charge of the facility.
(e) have at least one staff member present on each living
unit whenever there are youth in the living unit; ☒ ☐ ☐ Chapter 3, 3.2, A-4
(f) have sufficient food service personnel relative to the
number and security of living units, including staff The facility contracts with the SLO County Jail
qualified and available to: plan menus meeting nutritional to provide food services.
requirements of youth; provide kitchen supervision; direct
☒ ☐ ☐
food preparation and servings; conduct related training
programs for culinary staff; and maintain necessary
records; or, a facility may serve food that meets nutritional
standards prepared by an outside source;
(g) have sufficient administrative, clerical, recreational,
medical, dental, mental health, building maintenance, Chapter 3, 3.2, A-7
transportation, control room, facility security and other
☒ ☐ ☐
support staff for the efficient management of the facility, Ancillary personnel are not responsible for
and to ensure that youth supervision staff shall not be youth supervision.
diverted from supervising youth; and,
(h) assign sufficient youth supervision staff to provide
continuous wide awake supervision of youth, subject to Chapter 3, 3.2, A-6
temporary variations in staff assignments to meet special
program needs. Staffing shall be in compliance with a ☒ ☐ ☐ The facility operates with a minimum of 10
minimum youth-staff ratio for the following facility types: JSO’s during waking hours and six (6) during
sleeping hours.
(1) Juvenile Halls
(A) during the hours that youth are awake, one CVA is a Camp.
☐ ☐ ☒
wide-awake youth supervision staff member on
duty for each 10 youth in detention;
(B) during the hours that youth are confined to their
room for the purpose of sleeping, one wide-awake
☐ ☐ ☒
youth supervision staff member on duty for each
30 youth in detention;
(C) at least two wide-awake youth supervision staff
members on duty at all times, regardless of the
number of youth in detention, unless an
☐ ☐ ☒
arrangement has been made for backup support
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member on
duty who is the same gender as youth housed in ☐ ☐ ☒
the facility.
(E) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical, ☐ ☐ ☒
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(2) Special Purpose Juvenile Halls
(A) during hours that youth are awake, one wide- CVA is a Camp.
☐ ☐ ☒
awake youth supervision staff member on duty for
each 10 youth in detention;
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(B) during the hours that youth are confined to their
room for the purpose of sleeping, one wide-awake
☐ ☐ ☒
youth supervision staff member on duty for each
30 youth in detention;
(C) at least two wide-awake youth supervision staff
members on duty at all times, regardless of the
number of youth in detention, unless an
☐ ☐ ☒
arrangement has been made for backup support
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member on
duty who is the same gender as youth housed in ☐ ☐ ☒
the facility.
(E) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical, ☐ ☐ ☒
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(3) Camps
(A) during the hours that youth are awake, one Chapter 3, 3.2, A-8
wide-awake youth supervision staff member on
duty for each 15 youth in the camp population; The facility chooses to staff the CVA as a JH
☒ ☐ ☐ with the ratio of 1:10 during waking hours. Our
review of schedules for the entire Juvenile
Services Center revealed the agency has
sufficient staffing at all times.
(B) during the hours that youth are confined to their
room for the purpose of sleeping, one wide-awake Chapter 3, 3.2, A-9
☒ ☐ ☐
youth supervision staff member on duty for each
30 youth present in the facility;
(C) at least two wide-awake youth supervision staff
members on duty at all times, regardless of the Chapter 3, 3.2, A-6
number of youth in residence, unless
☒ ☐ ☐
arrangements have been made for backup support The facility will operate with a minimum of six
services which allow for immediate response to (6) JSO’s on duty.
emergencies;
(D) at least one youth supervision staff member on
duty who is the same gender as youth housed in ☒ ☐ ☐ Chapter 3, 3.2, A-10
the facility;
(E) in addition to the minimum staff to youth ratio
required in (h)(3)(A)-(B), consideration shall be Chapter 3, 3.2, B-2
given to the size, design, and location of the camp;
types of youth committed to the camp; and the ☒ ☐ ☐ The policy has sufficient staff assigned with
function of the camp in determining the level of the opportunity to fluctuate depending on
supervision necessary to maintain the safety and population.
welfare of youth and staff;
(F) personnel with primary responsibility for other
duties such as administration, supervision of Chapter 3, 3.2, B-4
personnel, academic or trade instruction, clerical, ☒ ☐ ☐
farm, forestry, kitchen or maintenance shall not be
classified as youth supervision staff positions.
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1328 SAFETY CHECKS
Chapter 3, 3.15 Safety Checks
The facility administrator shall develop and implement
policy and procedures that provide for direct visual
The facility uses the Guard 1/Pipe Electronic
observation of youth at a minimum of every 15 minutes,
safety check system. The policy includes an
at random or varied intervals during hours when youth
audit process and staff expectations in terms
are asleep or when youth are in their rooms, confined in
of ‘random and varied’ specific language.
holding cells or confined to their bed in a dormitory.
Operationally, the policy provides direction for
Supervision is not replaced, but may be supplemented
staff in how to use and download the
by, an audio/visual electronic surveillance system
information before, during, and after their shift
designed to detect overt, aggressive or assaultive
to ensure the correct officer is associated with
behavior and to summon aid in emergencies. All safety
the check.
checks shall be documented with the actual time the
check is completed.
Facility administration audits and reviews all
safety checks daily, handling late checks by
staff through a counseling, documented
memo, or other measures internally.
☒ ☐ ☐
We noted there were six (6) late checks in
January 2024, nine (9) in March 2024, and six
(6) in May 2024, with a minimum of 3240
checks each month. We reviewed each
accompanying memo associated with the late
check, which included a video review of the
circumstances. Of the 21 late checks, the
agency found operator or electronic errors of
the system in five (5) instances.
Facility Administration continues to
acknowledge 100% compliance with policy by
recognizing staff who had no late checks in a
given month. In the months reviewed above,
18 staff had perfect checks in January 2024,
19 in March, and 18 in May.
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1354.5 ROOM CONFINEMENT
Chapter 5, 5.8 Room Confinement (RC)
(a) The facility administrator shall develop and
Chapter 5, 5.8, C Procedure for
implement written policies and procedures addressing
implementation of RC
the confinement of youth in their room that are
consistent with Welfare and Institutions Code Section
We reviewed the only three (3) incidents
208.3. The placement of a youth in room confinement
involving room confinement in the CVA from
shall be accomplished in accordance with the following
January 2024 to the date of the inspection. All
guidelines:
three (3) included aggressive and verbally
threatening behavior. The process in these
situations includes monitoring behavior by
discussions with the youth at minimum of
every 15 minutes and documenting the point
when a youth no longer poses a threat,
demonstrating he or she is ready to
reintegrate and come out of their room.
Since the last inspection, staff no longer wait
for BH staff to remove a youth but rather the
on-duty JSO III meets with the youth to
establish a reintegration plan as soon as the
☒ ☐ ☐
youth is ready.
The implementation and continued use of the
PBIS model of behavior modification allows
youth to confront negative behaviors by
reflection and discussion before a situation
escalates. Facility staff are trained to de-
escalate issues through counseling and
understanding the triggers which escalate bad
behavior. Allowing a youth to self-separate to
take a time out and work on calming behaviors
has been an effective tool as well.
Facility-wide, the agency has had 21 incidents
of RC since January 2024, five (5) involving
one (1) youth in detention and three (3)
involving one (1) youth in SYTF. Our review
indicated most were removed at or before two
(2) hours and three (3) incidents were longer
than four (4) hours.
(1) Room confinement shall not be used before
other, less restrictive, options have been attempted Chapter 5, 5.8, C-1
and exhausted, unless attempting those options ☒ ☐ ☐
poses a threat to the safety or security of any youth
or staff.
(2) Room confinement shall not be used for the
purposes of punishment, coercion, convenience, or ☒ ☐ ☐ Chapter 5, 5.8, C-2
retaliation by staff.
(3) Room confinement shall not be used to the extent
that it compromises the mental and physical health ☒ ☐ ☐ Chapter 5, 5.8, C-3
of the youth.
(b) A youth may be held up to four hours in room
confinement. After the youth has been held in room Chapter 5, 5.8, C-8
☒ ☐ ☐
confinement for a period of four hours, staff shall do one
or more of the following:
(1) Return the youth to general population. ☒ ☐ ☐ Chapter 5, 5.8, C-8
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Chapter 5, 5.8, C-5, b
(2) Consult with mental health or medical staff. ☒ ☐ ☐ The facility behavior health staff are notified
when a youth is placed on RC and respond
immediately.
(3) Develop an individualized plan that includes the
goals and objectives to be met in order to reintegrate ☒ ☐ ☐ Chapter 5, 5.8, D
the youth to general population.
(4) If room confinement must be extended beyond
four hours, staff shall do each of the following: Chapter 5, 5.8, D-2
(A) Document the reasons for room confinement
and the basis for the extension, the date and time ☒ ☐ ☐
the youth was first placed in room confinement,
and when he or she is eventually released from
room confinement.
(B) Develop an individualized plan that includes
the goals and objectives to be met in order to ☒ ☐ ☐ Chapter 5, 5.8, D-3
integrate the youth to general population.
(C) Obtain documented authorization by the
facility superintendent or his or her designee ☒ ☐ ☐ Chapter 5, 5.8, D-1
every four hours thereafter.
(5) This section is not intended to limit the use of
single-person rooms or cells for the housing of youth Chapter 5, 5.8, A and B-1
☒ ☐ ☐
in juvenile facilities and does not apply to normal
sleeping hours.
(6) This section does not apply to youth or wards in
court holding facilities or adult facilities. ☒ ☐ ☐ Chapter 5, 5.8, B-2
(7) Nothing in this section shall be construed to
conflict with any law providing greater or additional ☒ ☐ ☐
protections to youth.
(8) This section does not apply during an
extraordinary emergency circumstance that requires Chapter 5, 5.8, B-3
a significant departure from normal institutional
operations, including a natural disaster or facility-
☒ ☐ ☐
wide threat that poses an imminent and substantial
risk of harm to multiple staff or youth. This exception
shall apply for the shortest amount of time needed to
address this imminent and substantial risk of harm.
(9) This section does not apply when a youth is
placed in a locked cell or sleeping room to treat and Chapter 5, 5.8, B-4
protect against the spread of a communicable
disease for the shortest amount of time required to
reduce the risk of infection, with the written approval
of a licensed physician or nurse practitioner, when
the youth is not required to be in an infirmary for an ☒ ☐ ☐
illness. Additionally, this section does not apply when
a youth is placed in a locked cell or sleeping room for
required extended care after medical treatment with
the written approval of a licensed physician or nurse
practitioner, when the youth is not required to be in
an infirmary for illness.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1357 USE OF FORCE
Chapter 5, 5.11 Use of Force (UF)
The facility administrator, in cooperation with the
Chapter 5, 5.11, D-2 General Provisions
responsible physician, shall develop and implement
Chapter 5, 5.11, L Chemical Agents
written policies and procedures for the use of force,
which may include chemical agents. Force shall never
There have been no UF incidents since
be applied as punishment, discipline, retaliation or
January 2024 for CVA with only six (6)
treatment.
incidents for JH and SYTF, none of which
(a) At a minimum, each facility shall develop policies and
involved OC spray.
procedures which:
☒ ☐ ☐
The incidents we did review provided clear
documentation of events leading to the force
option, including attempts to de-escalate.
When medical and mental health staff are on-
site, they respond immediately. It is noted all
UF incidents are administratively reviewed,
including video review, to determine if the
force was necessary.
(1) restricts the use of force to that which is deemed
reasonable and necessary, as defined in Section 1302 Chapter 5, 5.11, D-5
☒ ☐ ☐
to ensure the safety and security of youth, staff, others
and the facility.
(2) outline the force options available to staff including
both physical and non-physical options and define Chapter 5, 5.11, D-3, 4 and 5
when those force options are appropriate. Chapter 5, 5.11, E Control and Compliance
☒ ☐ ☐ Holds
Chapter 5, 5.11, F Other Hand to Hand Force
Methods
(3) describe force options or techniques that are
expressly prohibited by the facility. Chapter 5, 5.11, D -13 Carotid Hold
☒ ☐ ☐
Chapter 5, 5.11, F-3 Kicking and punching.
(4) describe the requirements of staff to report any
inappropriate use of force, and to take affirmative Chapter 5, 5.11, D-10
☒ ☐ ☐
action to immediately stop it. Chapter 5, 5.11, O-8
(5) define a standardized reporting format that
includes time period and procedure for documenting Chapter 5, 5.11, P-1 through 5
and reporting the use of force, including reporting
requirements of management and line staff and
procedures for reviewing and tracking use of force
incidents by supervisory and or management staff, ☒ ☐ ☐
which include procedures for debriefing a particular
incident with staff and/or youth for the purposes of
training as well as mitigating the effects of trauma that
may have been experienced by staff and /or the youth
involved.
(6) Include an administrative review and a system for
investigating unreasonable use of force. Chapter 5, 5.11, P-5
The Chief Deputy conducts an independent
☒ ☐ ☐ review of all UF incidents to determine the
need for internal investigation. Their review
includes submitted recommendations by the
supervisor who reviewed video of the incident.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(7) define the role, notification, and follow-up
procedures required after use of force incidents for Chapter 5, 5.11, D-15 Medical and Mental
medical, mental health staff and parents or legal Health
guardians. ☒ ☐ ☐ Chapter 5, 5.11, L-7 OC Spray notifications
Chapter 5, 5.11, L, O-10 Parent notification of
UF
(8) describe the limitations of use of force on pregnant
youth in accordance with Penal Code Section 6030(f) Chapter 5, 5.11, C-1, a
and Welfare and Institutions Code Section 222.
☒ ☐ ☐
This policy addresses known medical
conditions, including pregnant youth.
(b) Facilities that authorize chemical agents as a force
option shall include policies and procedures that: Chapter 5, 5.11, L Chemical Agents
(1) identify who is approved to carry and/or utilize Chapter 5, 5.11, L-1 Trained staff only
chemical agents in the facility and the type, size and ☒ ☐ ☐
the approved method of deployment for those It is noted there have been no incidents of OC
chemical agents. spray use since March 2022.
(2) mandate that chemical agents only be used when
there is an imminent threat to the youth’s safety or the Chapter 5, 5.11, L-2
safety of others and only when de-escalation efforts ☒ ☐ ☐
have been unsuccessful or are not reasonably
possible.
(3) outline the facility’s approved methods and
timelines for decontamination from chemical agents. Chapter 5, 5.11, L-6
This shall include that youth who have been exposed Chapter 5, 5.11, L-8
to chemical agents shall not be left unattended until
☒ ☐ ☐
that youth is fully decontaminated or is no longer Policies provide youth are provided a change
suffering the effects of the chemical agent. of clothes within one (1) hour of the incident
and are not left unattended.
(4) define the role, notification, and follow-up
procedures required after use of force incidents Chapter 5, 5.11, L-7 OC Spray notifications
☒ ☐ ☐
involving chemical agents for medical, mental health Chapter 5, 5.11, O-10 Parent notification of UF
staff and parents or legal guardians.
(5) provide for the documentation of each incident of
use of chemical agents, including the reasons for Chapter 5, 5.11, O-2, a-h
which it was used, efforts to de-escalate prior to use,
youth and staff involved, the date, time and location ☒ ☐ ☐
of use, decontamination procedures applied and
identification of any injuries sustained as a result of
such use.
(c) Facilities shall develop policies and procedure which
require that agencies provide initial and regular training Chapter 5, 5.11, C Training
in use of force and chemical agents when appropriate Chapter 5, 5.11, C-1, a
☒ ☐ ☐
that address:
(1) known medical and behavioral health conditions
that would contraindicate certain types of force;
(2) acceptable chemical agents and the methods of
application. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(3) signs or symptoms that should result in
immediate referral to medical or behavioral health. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(4) instruction on the Constitutional Limitations of
Use of Force. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
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(5) physical training force options that may require
the use of perishable skills. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(6) timelines the facility uses to define regular
training. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
1361 GRIEVANCE PROCEDURE
Chapter 5, 5.15 Grievance Procedure
The facility administrator shall develop and implement
Chapter 5, 5.15 A
written policies and procedures whereby any youth may
appeal and have resolved grievances relating to any
There were no grievances filed by CVA youth
condition of confinement, including but not limited to
from January 2024 to the date of the
health care services, classification decisions, program
inspection. Of the seven (7) filed during this
participation, telephone, mail or visiting procedures,
time frame, all by JH youth, we found the
food, clothing, bedding, mistreatment, harassment or
agency documented a response in one (1)
violations of the nondiscrimination policy. There shall be
☒ ☐ ☐ day and resolution within five (5) days. Staff
no time limit on filing grievances. Policies and
responses were fair and appeared
procedures shall include provisions whereby the facility
consistently applied with the other grievances
manager ensures:
reviewed for like issues.
We noted facility staff have conversations with
the youth and review video as a matter of
procedure, to ensure the youth understands
and accepts the outcome.
(a) a grievance form and instructions for registering a
grievance, which includes provisions for the youth to ☒ ☐ ☐ Chapter 5, 5.15, A
have free access to the form;
(b) the youth shall have the option to confidentially file
the grievance or to deliver the form to any youth ☒ ☐ ☐ Chapter 5, 5.15, G-3
supervision staff working in the facility;
(c) resolution of the grievance at the lowest appropriate
staff level; ☒ ☐ ☐ Chapter 5, 5.15, G
(d) provision for a prompt review and initial response to
grievances within three (3) business days, grievances Chapter 5, 5.15, E and G
that relate to health and safety issues must be
addressed immediately; The facility has an expectation to respond to
☒ ☐ ☐
the grievance by end of shift or within two (2)
days and resolution within five (5) days. All
were compliant with this expectation.
(1) The youth may elect to be present to explain
his/her version of the grievance to a person not Chapter 5, 5.15, G-6
☒ ☐ ☐
directly involved in the circumstances which led to
the grievance.
(2) Provision for a staff representative approved by
the facility administrator to assist the youth. ☒ ☐ ☐ Chapter 5, 5.15, C
(e) provision for a written response to the grievance
which includes the reasons for the decisions; ☒ ☐ ☐ Chapter 5, 5.15, G-7
(f) a system which provides that any appeal of a
grievance shall be heard by a person not directly Chapter 5, 5.15, F
☒ ☐ ☐
involved in the circumstances which led to the
grievance;
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(g) resolution of the grievance must occur within ten (10)
business days unless circumstances dictate a longer Chapter 5, 5.15, G-8
☒ ☐ ☐
time frame. The youth shall be notified of any delay;
and,
(h) the policy shall provide multiple internal and external
methods to report sexual abuse and sexual harassment. ☒ ☐ ☐ Chapter 5, 5.15, G-13
Whether or not associated with a grievance, concerns
of parents, guardians, staff or other parties shall be Chapter 5, 5.15, G-12
☒ ☐ ☐
addressed and documented in accordance with written
policies and procedures within a specified timeframe.
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1371 PROGRAMS, RECREATION, AND
EXERCISE. Chapter 6, 6.2 Programs, Recreation and
Exercise
The facility administrator shall develop and implement
written policies and procedures for programs,
Youth committed to CVA are provided
recreation, and exercise for all youth. The intent is to
programming services from the San Luis
minimize the amount of time youth are in their rooms or
Obispo Behavior Health Clinicians,
their bed area.
Restorative Partners Inc. (RP), and agency
staff.
Restorative Partners Inc. serves people
impacted by crime through a continuum of
services that focus on mind, body, and
spiritual transformation. Programming
opportunities include: Individual and Family
Counseling; a comprehensive Cognitive
Behavior Curriculum; Substance Abuse
treatment; Child and Family Team meetings;
Independent Living; Parent Education and
Support from the SLO Behavior Health staff.
Facility staff facilitate off-site Community
Activities; Community Work Service Projects;
Gardening; Culinary Activities; Video, Board,
and Card games; Movie Night; High
School/Birthday and Holiday celebrations; In-
house and outside employment opportunities;
Career Path Opportunities; Gender-specific
☒ ☐ ☐ programming; and PBIS.
RP services for CVA youth are similar to JH
youth and also include: gender-specific,
trauma-informed, and evidence-based
services to the youth population;
Sunday/Religious Service; Cooking
Programs; Crossroads (cognitive and
evidence-based curriculum specific to
offense); Book Club; Music Programs; West
and CVA Garden Program, Art and Creative
Writing; Lumina Alliance Group; A Window
between Worlds; Bible Study; Restorative
Justice; Chess Club; Sports Programs; AA
and NA; Meditation; Ping-Pong; and Tutoring.
RP also acknowledges youth Birthdays (one
time a month) and Peer Leader status
(weekly) with celebrations for the youth.
It is important to note the agency, coordinated
with the San Luis Obispo Office of Education,
has a Classified Coordinator effective June
24, 2024, to assist graduated students and
those not wanting to complete their K-12
education (age out and decline services) with
post-secondary opportunities while in the
facility.
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Juvenile facilities shall provide the opportunity for
programs, recreation, and exercise a minimum of three Chapter 6, 6.2, A-1
hours a day during the week and five hours a day each
☒ ☐ ☐
Saturday, Sunday or other non-school days, of which
one hour shall be an outdoor activity, weather
permitting.
A youth’s participation in programs, recreation, and
exercise may be suspended only upon a written finding Chapter 6, 6.2, A-2
by the administrator/manager or designee that a youth ☒ ☐ ☐
represents a threat to the safety and security of the
facility.
Such program, recreation, and exercise schedule shall
be posted in the living units. ☒ ☐ ☐ Chapter 6, 6.2, A-3
There will be a written annual review of the programs,
recreation, and exercise by the responsible agency to Chapter 6, 6.2, A-4
ensure content offered is current, consistent, and
relevant to the population. ☒ ☐ ☐ The most recent annual review of programs
was completed by Valerie Vega with
Restorative Partners in June 2024.
(a) Programs. All youth shall be provided with the
opportunity for at least one hour of daily programming to
include, but not be limited to, trauma focused, cognitive, Chapter 6, 6.2, B-1, a – c
evidence-based, best practice interventions that are
culturally relevant and linguistically appropriate, or pro- We interviewed CVA youth Jeremiah, age 18,
social interventions and activities designed to reduce who is enrolled at Cuesta College for his
recidivism. These programs should be based on the second quarter. He is happy with the
youth’s individual needs as required by Sections 1355 education opportunities after having
and 1356. Such programs may be provided under the graduated in December 2023 while in CVA.
direction of the Chief Probation Officer or the County He expressed he liked the Independent Living
Office of Education and can be administered by county Program provided weekly but felt many
partners such as mental health agencies, community- offerings were for younger youth. We passed
based organizations, faith-based organizations or this information on to facility administrators
Probation staff. and advised him to have conversations with
Programs may include but are not limited to: RP and facility supervisors to assist with more
(1) Cognitive Behavior Interventions; avenues he can explore.
(2) Management of Stress and Trauma; ☒ ☐ ☐
(3) Anger Management;
(4) Conflict Resolution;
(5) Juvenile Justice System;
(6) Trauma-related interventions;
(7) Victim Awareness;
(8) Self-Improvement;
(9) Parenting Skills and support;
(10) Tolerance and Diversity;
(11) Healing Informed Approaches;
(12) Interventions by Credible Messengers;
(13) Gender Specific Programming;
(14) Art, creative writing, or self-expression;
(15) CPR and First Aid training;
(16) Restorative Justice or Civic Engagement;
(17) Career and leadership opportunities; and,
(18) Other topics suitable to the youth population.
(b) Recreation. All youth shall be provided the opportunity
for at least one hour of daily access to unscheduled Chapter 6, 6.2, C-1
activities such as leisure reading, letter writing, and ☒ ☐ ☐
entertainment. Activities shall be supervised and include
orientation and may include coaching of youth.
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(c) Exercise. All youth shall be provided with the
opportunity for at least one hour of large muscle activity Chapter 6, 6.2, D-1
each day.
Youth in each program participate in one (1)
hour of Physical Education during the school
☒ ☐ ☐
day facilitated by the SLOCOE. Because
graduated youth are still in the classroom,
they participate in exercise with Court School
youth.
The administrator/manager may suspend, for a period
not to exceed 24 hours, access to recreation and Chapter 6, 6.2, D-3
programs. The administrator/manager shall document ☒ ☐ ☐
the reasons why suspension of recreation and programs
occurs.
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JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS
Board of State and Community Corrections
PROCEDURES CHECKLIST1
BSCC Code: 7541
FACILITY NAME: San Luis Obispo Juvenile Services Center: FACILITY TYPE: SYTF
Coastal Valley Academy (CVA) – SOAR Step Down
PERSON(S) INTERVIEWED: Marguerite Harris – Chief Deputy Probation Officer, Superintendent; Robert Reyes, Chief
Probation Officer; Tom Milder, Assistant Chief Probation Officer; Jennifer Gonzales, Supervisor; Seth Price, Supervisor;
Laureen Kilenberger, Supervisor.
There were no youth in this stepdown program on the day of the inspection. We were advised one SYTF youth completed
the CVA Program and remains successfully integrated in the community. The following information relate to policy and
practice in the facility for all programs.
FIELD REPRESENTATIVE: Elizabeth Gong DATE: June 19, 2024
TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1321 STAFFING
Chapter 3, 3.2 Staffing
Each juvenile facility shall:
Chapter 3, 3.2, A-2
(a) have an adequate number of personnel sufficient to
carry out the overall facility operation and its
The facility has 34 Juvenile Supervision
programming, to provide for safety and security of youth
Officers (JSO), four (4) JSO III filled positions,
and staff, and meet established standards and
and three (3) Supervising Deputy Probation
regulations;
Officers (SDPO). There are two (2) vacancies
in this series. Of the 34 JSO I/II, four (4) work
☒ ☐ ☐ control and one (1) is a new hire just
completing Core Training.
The staffing patterns remain at 12-hour shifts:
6am to 6pm; 6pm to 6am; 8am to 8pm; 9am
to 9pm; and 10am to 10pm. This allows for
maximum coverage during waking hours to
complete programming and other T15
responsibilities.
(b) ensure that no required services shall be denied
because of insufficient numbers of staff on duty absent Chapter 3, 3.2, A-1
exigent circumstances;
The agency has sufficient staffing levels to
☒ ☐ ☐
meet the needs of this population. On the day
of the inspection, there were no youth in the
CVA -SYTF Stepdown program.
1 This document is intended for use as a tool during the targeted inspection process; this worksheet may not contain each Title 15
regulation that is required. Additionally, many regulations on this worksheet are SUMMARIES of the regulation; the text on this
worksheet may not contain the entire text of the actual regulation. Please refer to the complete California Code of Regulations,
Title 15, Minimum Standards for Juvenile Facilities, Division 1, Chapter 1, Subchapter 5 for the complete list and text of
regulations.
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(c) have a sufficient number of supervisory level staff to
ensure adequate supervision of all staff members; Chapter 3, 3.2, A-12
There are three (3) SDPO’s assigned to the
☒ ☐ ☐
facility. The graveyard supervisory staff is a
JSO III who maintains supervision of overall
operations of the facility during the shift.
(d) have a clearly identified person on duty at all times
who is responsible for operations and activities and has Chapter 3, 3.2, A-3
completed the Juvenile Corrections Officer Core Course
☒ ☐ ☐
and PC 832 training; There is always a SDPO or JSO III on duty
and in charge of the facility.
(e) have at least one staff member present on each living
unit whenever there are youth in the living unit; ☒ ☐ ☐ Chapter 3, 3.2, A-4
(f) have sufficient food service personnel relative to the
number and security of living units, including staff The facility contracts with the SLO County Jail
qualified and available to: plan menus meeting nutritional to provide food services.
requirements of youth; provide kitchen supervision; direct
☒ ☐ ☐
food preparation and servings; conduct related training
programs for culinary staff; and maintain necessary
records; or, a facility may serve food that meets nutritional
standards prepared by an outside source;
(g) have sufficient administrative, clerical, recreational,
medical, dental, mental health, building maintenance, Chapter 3, 3.2, A-7
transportation, control room, facility security and other
☒ ☐ ☐
support staff for the efficient management of the facility, Ancillary personnel are not responsible for
and to ensure that youth supervision staff shall not be youth supervision.
diverted from supervising youth; and,
(h) assign sufficient youth supervision staff to provide
continuous wide awake supervision of youth, subject to Chapter 3, 3.2, A-6
temporary variations in staff assignments to meet special
program needs. Staffing shall be in compliance with a ☒ ☐ ☐ The facility operates with a minimum of 10
minimum youth-staff ratio for the following facility types: JSO’s during waking hours and six (6) during
sleeping hours.
(1) Juvenile Halls
(A) during the hours that youth are awake, one CVA – SYTF is an SYTF Program that follows
wide-awake youth supervision staff member on the same guidelines as the Coastal Valley
☐ ☐ ☒
duty for each 10 youth in detention; Camp Program. It is a post-dispositional
program.
(B) during the hours that youth are confined to their
room for the purpose of sleeping, one wide-awake
☐ ☐ ☒
youth supervision staff member on duty for each
30 youth in detention;
(C) at least two wide-awake youth supervision staff
members on duty at all times, regardless of the
number of youth in detention, unless an
☐ ☐ ☒
arrangement has been made for backup support
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member on
duty who is the same gender as youth housed in ☐ ☐ ☒
the facility.
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(E) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical, ☐ ☐ ☒
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(2) Special Purpose Juvenile Halls
(A) during hours that youth are awake, one wide-
☐ ☐ ☒
awake youth supervision staff member on duty for
each 10 youth in detention;
(B) during the hours that youth are confined to their
room for the purpose of sleeping, one wide-awake
☐ ☐ ☒
youth supervision staff member on duty for each
30 youth in detention;
(C) at least two wide-awake youth supervision staff
members on duty at all times, regardless of the
number of youth in detention, unless an
☐ ☐ ☒
arrangement has been made for backup support
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member on
duty who is the same gender as youth housed in ☐ ☐ ☒
the facility.
(E) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical, ☐ ☐ ☒
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(3) Camps
(A) during the hours that youth are awake, one Chapter 3, 3.2, A-8
wide-awake youth supervision staff member on
duty for each 15 youth in the camp population; The facility chooses to staff the CVA – SYTF
☒ ☐ ☐ as a JH with the ratio of 1:10 during waking
hours. Our review of schedules for the entire
Juvenile Services Center revealed the agency
has sufficient staffing at all times.
(B) during the hours that youth are confined to their
room for the purpose of sleeping, one wide-awake Chapter 3, 3.2, A-9
☒ ☐ ☐
youth supervision staff member on duty for each
30 youth present in the facility;
(C) at least two wide-awake youth supervision staff
members on duty at all times, regardless of the Chapter 3, 3.2, A-6
number of youth in residence, unless
☒ ☐ ☐
arrangements have been made for backup support The facility will operate with a minimum of six
services which allow for immediate response to (6) JSO’s on duty.
emergencies;
(D) at least one youth supervision staff member on
duty who is the same gender as youth housed in ☒ ☐ ☐ Chapter 3, 3.2, A-10
the facility;
(E) in addition to the minimum staff to youth ratio
required in (h)(3)(A)-(B), consideration shall be Chapter 3, 3.2, B-2
given to the size, design, and location of the camp;
types of youth committed to the camp; and the ☒ ☐ ☐ The policy has sufficient staff assigned with
function of the camp in determining the level of the opportunity to fluctuate depending on
supervision necessary to maintain the safety and population.
welfare of youth and staff;
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(F) personnel with primary responsibility for other
duties such as administration, supervision of Chapter 3, 3.2, B-4
personnel, academic or trade instruction, clerical, ☒ ☐ ☐
farm, forestry, kitchen or maintenance shall not be
classified as youth supervision staff positions.
1328 SAFETY CHECKS
Chapter 3, 3.15 Safety Checks
The facility administrator shall develop and implement
policy and procedures that provide for direct visual
The facility uses the Guard 1/Pipe Electronic
observation of youth at a minimum of every 15 minutes,
safety check system. The policy includes an
at random or varied intervals during hours when youth
audit process and staff expectations in terms
are asleep or when youth are in their rooms, confined in
of ‘random and varied’ specific language.
holding cells or confined to their bed in a dormitory.
Operationally, the policy provides direction for
Supervision is not replaced, but may be supplemented
staff in how to use and download the
by, an audio/visual electronic surveillance system
information before, during, and after their shift
designed to detect overt, aggressive or assaultive
to ensure the correct officer is associated with
behavior and to summon aid in emergencies. All safety
the check.
checks shall be documented with the actual time the
check is completed.
Facility administration audits and reviews all
safety checks daily, handling late checks by
staff through a counseling, documented
memo, or other measures internally.
☒ ☐ ☐
We noted there were six (6) late checks in
January 2024, nine (9) in March 2024, and six
(6) in May 2024, of the minimum of 3240
checks. We reviewed each accompanying
memo associated with the late check, which
included a video review of the circumstances.
Of the 21 late checks, the agency found
operator or electronic errors of the system in
five (5) instances.
Facility Administration continues to
acknowledge 100% compliance with policy by
recognizing staff who had no late checks in a
given month. In the months reviewed above,
18 staff had perfect checks in January 2024,
19 in March, and 18 in May.
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1354.5 ROOM CONFINEMENT
Chapter 5, 5.8 Room Confinement (RC)
(a) The facility administrator shall develop and
Chapter 5, 5.8, C Procedure for
implement written policies and procedures addressing
implementation of RC
the confinement of youth in their room that are
consistent with Welfare and Institutions Code Section
There were no incidents of RC in the CVA –
208.3. The placement of a youth in room confinement
SYTF program from January 2024 to the date
shall be accomplished in accordance with the following
of the youth’s release.
guidelines:
The process in these situations includes
monitoring behavior by discussions with the
youth at minimum of every 15 minutes and
documenting the point when a youth no longer
poses a threat, demonstrating he or she is
ready to reintegrate and come out of their
room.
Since the last inspection, staff no longer wait
for BH staff to remove a youth but rather the
on-duty JSO III meets with the youth to
establish a reintegration plan as soon as the
☒ ☐ ☐
youth is ready.
The implementation and continued use of the
PBIS model of behavior modification allows
youth to confront negative behaviors by
reflection and discussion before a situation
escalates. Facility staff are trained to de-
escalate issues through counseling and
understanding the triggers which escalate bad
behavior. Allowing a youth to self-separate to
take a time out and work on calming behaviors
has been an effective tool as well.
Facility-wide, the agency has had 21 incidents
of RC since January 2024, of which five (5)
involved one (1) youth in detention and three
(3) involved one (1) youth in JH SYTF. Our
review of all incidents indicated most were
removed at or before two (2) hours and three
(3) incidents were longer than four (4) hours.
(1) Room confinement shall not be used before
other, less restrictive, options have been attempted Chapter 5, 5.8, C-1
and exhausted, unless attempting those options ☒ ☐ ☐
poses a threat to the safety or security of any youth
or staff.
(2) Room confinement shall not be used for the
purposes of punishment, coercion, convenience, or ☒ ☐ ☐ Chapter 5, 5.8, C-2
retaliation by staff.
(3) Room confinement shall not be used to the extent
that it compromises the mental and physical health ☒ ☐ ☐ Chapter 5, 5.8, C-3
of the youth.
(b) A youth may be held up to four hours in room
confinement. After the youth has been held in room Chapter 5, 5.8, C-8
☒ ☐ ☐
confinement for a period of four hours, staff shall do one
or more of the following:
(1) Return the youth to general population. ☒ ☐ ☐ Chapter 5, 5.8, C-8
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Chapter 5, 5.8, C-5, b
(2) Consult with mental health or medical staff. ☒ ☐ ☐ The facility behavior health staff are notified
when a youth is placed on RC and respond
immediately.
(3) Develop an individualized plan that includes the
goals and objectives to be met in order to reintegrate ☒ ☐ ☐ Chapter 5, 5.8, D
the youth to general population.
(4) If room confinement must be extended beyond
four hours, staff shall do each of the following: Chapter 5, 5.8, D-2
(A) Document the reasons for room confinement
and the basis for the extension, the date and time ☒ ☐ ☐
the youth was first placed in room confinement,
and when he or she is eventually released from
room confinement.
(B) Develop an individualized plan that includes
the goals and objectives to be met in order to ☒ ☐ ☐ Chapter 5, 5.8, D-3
integrate the youth to general population.
(C) Obtain documented authorization by the
facility superintendent or his or her designee ☒ ☐ ☐ Chapter 5, 5.8, D-1
every four hours thereafter.
(5) This section is not intended to limit the use of
single-person rooms or cells for the housing of youth Chapter 5, 5.8, A and B-1
☒ ☐ ☐
in juvenile facilities and does not apply to normal
sleeping hours.
(6) This section does not apply to youth or wards in
court holding facilities or adult facilities. ☒ ☐ ☐ Chapter 5, 5.8, B-2
(7) Nothing in this section shall be construed to
conflict with any law providing greater or additional ☒ ☐ ☐
protections to youth.
(8) This section does not apply during an
extraordinary emergency circumstance that requires Chapter 5, 5.8, B-3
a significant departure from normal institutional
operations, including a natural disaster or facility-
☒ ☐ ☐
wide threat that poses an imminent and substantial
risk of harm to multiple staff or youth. This exception
shall apply for the shortest amount of time needed to
address this imminent and substantial risk of harm.
(9) This section does not apply when a youth is
placed in a locked cell or sleeping room to treat and Chapter 5, 5.8, B-4
protect against the spread of a communicable
disease for the shortest amount of time required to
reduce the risk of infection, with the written approval
of a licensed physician or nurse practitioner, when
the youth is not required to be in an infirmary for an ☒ ☐ ☐
illness. Additionally, this section does not apply when
a youth is placed in a locked cell or sleeping room for
required extended care after medical treatment with
the written approval of a licensed physician or nurse
practitioner, when the youth is not required to be in
an infirmary for illness.
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1357 USE OF FORCE
Chapter 5, 5.11 Use of Force (UF)
The facility administrator, in cooperation with the
Chapter 5, 5.11, D-2 General Provisions
responsible physician, shall develop and implement
Chapter 5, 5.11, L Chemical Agents
written policies and procedures for the use of force,
which may include chemical agents. Force shall never
There have been no UF incidents since
be applied as punishment, discipline, retaliation or
January 2024 for CVA - SYTF with only six (6)
treatment.
incidents for JH and JH SYTF, none of which
(a) At a minimum, each facility shall develop policies and
involved OC spray.
procedures which:
☒ ☐ ☐
The incidents we did review provided clear
documentation of events leading to the force
option, including attempts to de-escalate.
When medical and mental health staff are on-
site, they respond immediately. It is noted all
UF incidents are administratively reviewed,
including video review, to determine if the
force was necessary.
(1) restricts the use of force to that which is deemed
reasonable and necessary, as defined in Section 1302 Chapter 5, 5.11, D-5
☒ ☐ ☐
to ensure the safety and security of youth, staff, others
and the facility.
(2) outline the force options available to staff including
both physical and non-physical options and define Chapter 5, 5.11, D-3, 4 and 5
when those force options are appropriate. Chapter 5, 5.11, E Control and Compliance
☒ ☐ ☐ Holds
Chapter 5, 5.11, F Other Hand to Hand Force
Methods
(3) describe force options or techniques that are
expressly prohibited by the facility. Chapter 5, 5.11, D -13 Carotid Hold
☒ ☐ ☐
Chapter 5, 5.11, F-3 Kicking and punching.
(4) describe the requirements of staff to report any
inappropriate use of force, and to take affirmative Chapter 5, 5.11, D-10
☒ ☐ ☐
action to immediately stop it. Chapter 5, 5.11, O-8
(5) define a standardized reporting format that
includes time period and procedure for documenting Chapter 5, 5.11, P-1 through 5
and reporting the use of force, including reporting
requirements of management and line staff and
procedures for reviewing and tracking use of force
incidents by supervisory and or management staff, ☒ ☐ ☐
which include procedures for debriefing a particular
incident with staff and/or youth for the purposes of
training as well as mitigating the effects of trauma that
may have been experienced by staff and /or the youth
involved.
(6) Include an administrative review and a system for
investigating unreasonable use of force. Chapter 5, 5.11, P-5
The Chief Deputy conducts an independent
☒ ☐ ☐ review of all UF incidents to determine the
need for internal investigation. Their review
includes submitted recommendations by the
supervisor who reviewed video of the incident.
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(7) define the role, notification, and follow-up
procedures required after use of force incidents for Chapter 5, 5.11, D-15 Medical and Mental
medical, mental health staff and parents or legal Health
guardians. ☒ ☐ ☐ Chapter 5, 5.11, L-7 OC Spray notifications
Chapter 5, 5.11, L, O-10 Parent notification of
UF
(8) describe the limitations of use of force on pregnant
youth in accordance with Penal Code Section 6030(f) Chapter 5, 5.11, C-1, a
and Welfare and Institutions Code Section 222.
☒ ☐ ☐
This policy addresses known medical
conditions, including pregnant youth.
(b) Facilities that authorize chemical agents as a force
option shall include policies and procedures that: Chapter 5, 5.11, L Chemical Agents
(1) identify who is approved to carry and/or utilize Chapter 5, 5.11, L-1 Trained staff only
chemical agents in the facility and the type, size and ☒ ☐ ☐
the approved method of deployment for those It is noted there have been no incidents of OC
chemical agents. spray use since March 2022.
(2) mandate that chemical agents only be used when
there is an imminent threat to the youth’s safety or the Chapter 5, 5.11, L-2
safety of others and only when de-escalation efforts ☒ ☐ ☐
have been unsuccessful or are not reasonably
possible.
(3) outline the facility’s approved methods and
timelines for decontamination from chemical agents. Chapter 5, 5.11, L-6
This shall include that youth who have been exposed Chapter 5, 5.11, L-8
to chemical agents shall not be left unattended until
☒ ☐ ☐
that youth is fully decontaminated or is no longer Policies provide youth are provided a change
suffering the effects of the chemical agent. of clothes within one (1) hour of the incident
and are not left unattended.
(4) define the role, notification, and follow-up
procedures required after use of force incidents Chapter 5, 5.11, L-7 OC Spray notifications
☒ ☐ ☐
involving chemical agents for medical, mental health Chapter 5, 5.11, O-10 Parent notification of UF
staff and parents or legal guardians.
(5) provide for the documentation of each incident of
use of chemical agents, including the reasons for Chapter 5, 5.11, O-2, a-h
which it was used, efforts to de-escalate prior to use,
youth and staff involved, the date, time and location ☒ ☐ ☐
of use, decontamination procedures applied and
identification of any injuries sustained as a result of
such use.
(c) Facilities shall develop policies and procedure which
require that agencies provide initial and regular training Chapter 5, 5.11, C Training
in use of force and chemical agents when appropriate Chapter 5, 5.11, C-1, a
☒ ☐ ☐
that address:
(1) known medical and behavioral health conditions
that would contraindicate certain types of force;
(2) acceptable chemical agents and the methods of
application. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(3) signs or symptoms that should result in
immediate referral to medical or behavioral health. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(4) instruction on the Constitutional Limitations of
Use of Force. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
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(5) physical training force options that may require
the use of perishable skills. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(6) timelines the facility uses to define regular
training. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
1361 GRIEVANCE PROCEDURE
Chapter 5, 5.15 Grievance Procedure
The facility administrator shall develop and implement
Chapter 5, 5.15 A
written policies and procedures whereby any youth may
appeal and have resolved grievances relating to any
There were no grievances filed by CVA SYTF
condition of confinement, including but not limited to
youth from January 2024 to the date of the
health care services, classification decisions, program
youth’s release. Of the seven (7) filed during
participation, telephone, mail or visiting procedures,
this time frame, all by JH youth, we found the
food, clothing, bedding, mistreatment, harassment or
agency documented a response in one (1)
violations of the nondiscrimination policy. There shall be
☒ ☐ ☐ day and resolution within five (5) days. Staff
no time limit on filing grievances. Policies and
responses were fair and appeared
procedures shall include provisions whereby the facility
consistently applied with the other grievances
manager ensures:
reviewed for like issues.
We noted facility staff have conversations with
the youth and review video as a matter of
procedure, to ensure the youth understands
and accepts the outcome.
(a) a grievance form and instructions for registering a
grievance, which includes provisions for the youth to ☒ ☐ ☐ Chapter 5, 5.15, A
have free access to the form;
(b) the youth shall have the option to confidentially file
the grievance or to deliver the form to any youth ☒ ☐ ☐ Chapter 5, 5.15, G-3
supervision staff working in the facility;
(c) resolution of the grievance at the lowest appropriate
staff level; ☒ ☐ ☐ Chapter 5, 5.15, G
(d) provision for a prompt review and initial response to
grievances within three (3) business days, grievances Chapter 5, 5.15, E and G
that relate to health and safety issues must be
addressed immediately; The facility has an expectation to respond to
☒ ☐ ☐
the grievance by end of shift or within two (2)
days and resolution within five (5) days. All
were compliant with this expectation.
(1) The youth may elect to be present to explain
his/her version of the grievance to a person not Chapter 5, 5.15, G-6
☒ ☐ ☐
directly involved in the circumstances which led to
the grievance.
(2) Provision for a staff representative approved by
the facility administrator to assist the youth. ☒ ☐ ☐ Chapter 5, 5.15, C
(e) provision for a written response to the grievance
which includes the reasons for the decisions; ☒ ☐ ☐ Chapter 5, 5.15, G-7
(f) a system which provides that any appeal of a
grievance shall be heard by a person not directly Chapter 5, 5.15, F
☒ ☐ ☐
involved in the circumstances which led to the
grievance;
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(g) resolution of the grievance must occur within ten (10)
business days unless circumstances dictate a longer Chapter 5, 5.15, G-8
☒ ☐ ☐
time frame. The youth shall be notified of any delay;
and,
(h) the policy shall provide multiple internal and external
methods to report sexual abuse and sexual harassment. ☒ ☐ ☐ Chapter 5, 5.15, G-13
Whether or not associated with a grievance, concerns
of parents, guardians, staff or other parties shall be Chapter 5, 5.15, G-12
☒ ☐ ☐
addressed and documented in accordance with written
policies and procedures within a specified timeframe.
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1371 PROGRAMS, RECREATION, AND
EXERCISE. Chapter 6, 6.2 Programs, Recreation and
Exercise
The facility administrator shall develop and implement
written policies and procedures for programs,
Youth committed to CVA – SYTF are provided
recreation, and exercise for all youth. The intent is to
programming services from the San Luis
minimize the amount of time youth are in their rooms or
Obispo Behavior Health Clinicians,
their bed area.
Restorative Partners (RP), and agency staff.
Restorative Partners Inc. serves people
impacted by crime through a continuum of
services that focus on mind, body, and
spiritual transformation. Programming
opportunities include: Individual and Family
Counseling; a comprehensive Cognitive
Behavior Curriculum; Substance Abuse
treatment; Child and Family Team meetings;
Independent Living; Parent Education and
Support from the SLO Behavior Health staff.
Facility staff facilitate off-site Community
Activities; Community Work Service Projects;
Gardening; Culinary Activities; Video, Board,
and Card games; Movie Night; High
School/Birthday and Holiday celebrations; In-
house and outside employment opportunities;
Career Path Opportunities; Gender-specific
programming; and PBIS.
☒ ☐ ☐
RP services for CVA SYTF youth are similar to
JH youth and also include: gender-specific,
trauma-informed, and evidence-based
services to the youth population:
Sunday/Religious Service; Cooking
Programs; Crossroads (cognitive and
evidence-based curriculum specific to
offense); A Window between Worlds; Book
Club; Music Programs; West and CVA Garden
Program, Art and Creative Writing; Lumina
Alliance Group; Bible Study; Restorative
Justice; Chess Club; Sports Programs; AA
and NA; Meditation; Ping-Pong; and Tutoring.
RP also acknowledges youth Birthdays (one
time a month) and Peer Leader status
(weekly) with celebrations for the youth.
It is important to note the agency, in
coordination with the San Luis Obispo Office
of Education, has a Classified Coordinator
effective June 24, 2024, to assist graduated
students and those not wanting to complete
their K-12 education (age out and decline
services) with post-secondary opportunities
while in the facility.
Juvenile facilities shall provide the opportunity for
programs, recreation, and exercise a minimum of three Chapter 6, 6.2, A-1
hours a day during the week and five hours a day each
☒ ☐ ☐
Saturday, Sunday or other non-school days, of which
one hour shall be an outdoor activity, weather
permitting.
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A youth’s participation in programs, recreation, and
exercise may be suspended only upon a written finding Chapter 6, 6.2, A-2
by the administrator/manager or designee that a youth ☒ ☐ ☐
represents a threat to the safety and security of the
facility.
Such program, recreation, and exercise schedule shall
be posted in the living units. ☒ ☐ ☐ Chapter 6, 6.2, A-3
There will be a written annual review of the programs,
recreation, and exercise by the responsible agency to Chapter 6, 6.2, A-4
ensure content offered is current, consistent, and
relevant to the population. ☒ ☐ ☐ The most recent annual review of programs
was completed by Valerie Vega with
Restorative Partners in June 2024.
(a) Programs. All youth shall be provided with the
opportunity for at least one hour of daily programming to
include, but not be limited to, trauma focused, cognitive, Chapter 6, 6.2, B-1, a – c
evidence-based, best practice interventions that are
culturally relevant and linguistically appropriate, or pro-
social interventions and activities designed to reduce
recidivism. These programs should be based on the
youth’s individual needs as required by Sections 1355
and 1356. Such programs may be provided under the
direction of the Chief Probation Officer or the County
Office of Education and can be administered by county
partners such as mental health agencies, community
based organizations, faith-based organizations or
Probation staff.
Programs may include but are not limited to:
(1) Cognitive Behavior Interventions;
(2) Management of Stress and Trauma; ☒ ☐ ☐
(3) Anger Management;
(4) Conflict Resolution;
(5) Juvenile Justice System;
(6) Trauma-related interventions;
(7) Victim Awareness;
(8) Self-Improvement;
(9) Parenting Skills and support;
(10) Tolerance and Diversity;
(11) Healing Informed Approaches;
(12) Interventions by Credible Messengers;
(13) Gender Specific Programming;
(14) Art, creative writing, or self-expression;
(15) CPR and First Aid training;
(16) Restorative Justice or Civic Engagement;
(17) Career and leadership opportunities; and,
(18) Other topics suitable to the youth population.
(b) Recreation. All youth shall be provided the opportunity
for at least one hour of daily access to unscheduled Chapter 6, 6.2, C-1
activities such as leisure reading, letter writing, and ☒ ☐ ☐
entertainment. Activities shall be supervised and include
orientation and may include coaching of youth.
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(c) Exercise. All youth shall be provided with the
opportunity for at least one hour of large muscle activity Chapter 6, 6.2, D-1
each day.
Youth in each program participate in one (1)
hour of Physical Education during the school
☒ ☐ ☐
day facilitated by the SLOCOE. Because
graduated youth are still in the classroom,
they participate in exercise with Court School
youth.
The administrator/manager may suspend, for a period
not to exceed 24 hours, access to recreation and Chapter 6, 6.2, D-3
programs. The administrator/manager shall document ☒ ☐ ☐
the reasons why suspension of recreation and programs
occurs.
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JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS
Board of State and Community Corrections
PROCEDURES CHECKLIST1
BSCC Code: 7543
FACILITY NAME: San Luis Obispo Juvenile Services Center FACILITY TYPE: SYTF
Juvenile Hall Secure Youth Treatment Facility - SOAR
PERSON(S) INTERVIEWED: Marguerite Harris – Chief Deputy Probation Officer, Superintendent; Robert Reyes, Chief
Probation Officer; Tom Milder, Assistant Chief Probation Officer; Jennifer Gonzales, Supervisor; Seth Price, Supervisor;
Laureen Kilenberger, Supervisor; Youth: Thomas, age 18.
FIELD REPRESENTATIVE: Elizabeth Gong DATE: June 19, 2024
TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1321 STAFFING
Chapter 3, 3.2 Staffing
Each juvenile facility shall:
Chapter 3, 3.2, A-2
(a) have an adequate number of personnel sufficient to
carry out the overall facility operation and its
The facility has 34 Juvenile Supervision
programming, to provide for safety and security of youth
Officers (JSO), four (4) JSO III filled positions,
and staff, and meet established standards and
and three (3) Supervising Deputy Probation
regulations;
Officers (SDPO). There are two (2) vacancies
in this series. Of the 34 JSO I/II, four (4) work
☒ ☐ ☐ control and one (1) is a new hire just
completing Core Training.
The staffing patterns remain at 12-hour shifts:
6am to 6pm; 6pm to 6am; 8am to 8pm; 9am
to 9pm; and 10am to 10pm. This allows for
maximum coverage during waking hours to
complete programming and other T15
responsibilities.
(b) ensure that no required services shall be denied
because of insufficient numbers of staff on duty absent Chapter 3, 3.2, A-1
exigent circumstances;
The agency has sufficient staffing levels to
☒ ☐ ☐
meet the needs of this population. On the day
of the inspection, there were 15 youth in
custody, four (4) in JH SYTF (SOAR).
(c) have a sufficient number of supervisory level staff to
ensure adequate supervision of all staff members; Chapter 3, 3.2, A-12
There are three (3) SDPO’s assigned to the
☒ ☐ ☐
facility. The graveyard supervisory staff is a
JSO III who maintains supervision of overall
operations of the facility during their shift.
1 This document is intended for use as a tool during the targeted inspection process; this worksheet may not contain each Title 15
regulation that is required. Additionally, many regulations on this worksheet are SUMMARIES of the regulation; the text on this
worksheet may not contain the entire text of the actual regulation. Please refer to the complete California Code of Regulations,
Title 15, Minimum Standards for Juvenile Facilities, Division 1, Chapter 1, Subchapter 5 for the complete list and text of
regulations.
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(d) have a clearly identified person on duty at all times
who is responsible for operations and activities and has Chapter 3, 3.2, A-3
completed the Juvenile Corrections Officer Core Course
☒ ☐ ☐
and PC 832 training; There is always a SDPO or JSO III on duty
and in charge of the facility.
(e) have at least one staff member present on each living
unit whenever there are youth in the living unit; ☒ ☐ ☐ Chapter 3, 3.2, A-4
(f) have sufficient food service personnel relative to the
number and security of living units, including staff The facility contracts with the SLO County Jail
qualified and available to: plan menus meeting nutritional to provide food services.
requirements of youth; provide kitchen supervision; direct
☒ ☐ ☐
food preparation and servings; conduct related training
programs for culinary staff; and maintain necessary
records; or, a facility may serve food that meets nutritional
standards prepared by an outside source;
(g) have sufficient administrative, clerical, recreational,
medical, dental, mental health, building maintenance, Chapter 3, 3.2, A-7
transportation, control room, facility security and other
☒ ☐ ☐
support staff for the efficient management of the facility, Ancillary personnel are not responsible for
and to ensure that youth supervision staff shall not be youth supervision.
diverted from supervising youth; and,
(h) assign sufficient youth supervision staff to provide
continuous wide awake supervision of youth, subject to Chapter 3, 3.2, A-6
temporary variations in staff assignments to meet special
program needs. Staffing shall be in compliance with a ☒ ☐ ☐ The facility schedules a minimum of 10 JSO’s
minimum youth-staff ratio for the following facility types: during waking hours and six (6) during
sleeping hours.
(1) Juvenile Halls
(A) during the hours that youth are awake, one Chapter 3, 3.2, A-8
☒ ☐ ☐
wide-awake youth supervision staff member on
duty for each 10 youth in detention;
(B) during the hours that youth are confined to their
room for the purpose of sleeping, one wide-awake Chapter 3, 3.2, A-9
☒ ☐ ☐
youth supervision staff member on duty for each
30 youth in detention;
(C) at least two wide-awake youth supervision staff
members on duty at all times, regardless of the Chapter 3, 3.2, A-6
number of youth in detention, unless an
arrangement has been made for backup support SYTF youth are initially placed in the West
services which allow for immediate response to Unit, along with Detention Youth, for the first
emergencies; and, phase of their SOAR Commitment with the
☒ ☐ ☐
same staff-to-youth ratio of 1:10.
The facility operates with a minimum of one
(1) supervisor/shift leader and six (6) JSO’s on
duty.
(D) at least one youth supervision staff member on
duty who is the same gender as youth housed in ☒ ☐ ☐ Chapter 3, 3.2, A-10
the facility.
(E) personnel with primary responsibility for other
duties such as administration, supervision of Chapter 3, 3.2, B-3, 4
personnel, academic or trade instruction, clerical, ☒ ☐ ☐
kitchen or maintenance shall not be classified as
youth supervision staff positions.
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(2) Special Purpose Juvenile Halls
(A) during hours that youth are awake, one wide- The JH SYTF Program is not Special
☐ ☐ ☒
awake youth supervision staff member on duty for Purpose.
each 10 youth in detention;
(B) during the hours that youth are confined to their
room for the purpose of sleeping, one wide-awake
☐ ☐ ☒
youth supervision staff member on duty for each
30 youth in detention;
(C) at least two wide-awake youth supervision staff
members on duty at all times, regardless of the
number of youth in detention, unless an
☐ ☐ ☒
arrangement has been made for backup support
services which allow for immediate response to
emergencies; and,
(D) at least one youth supervision staff member on
duty who is the same gender as youth housed in ☐ ☐ ☒
the facility.
(E) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical, ☐ ☐ ☒
kitchen or maintenance shall not be classified as
youth supervision staff positions.
(3) Camps
(A) during the hours that youth are awake, one The JH SYTF Program is not a Camp.
☐ ☐ ☒
wide-awake youth supervision staff member on
duty for each 15 youth in the camp population;
(B) during the hours that youth are confined to their
room for the purpose of sleeping, one wide-awake
☐ ☐ ☒
youth supervision staff member on duty for each
30 youth present in the facility;
(C) at least two wide-awake youth supervision staff
members on duty at all times, regardless of the
number of youth in residence, unless
☐ ☐ ☒
arrangements have been made for backup support
services which allow for immediate response to
emergencies;
(D) at least one youth supervision staff member on
duty who is the same gender as youth housed in ☐ ☐ ☒
the facility;
(E) in addition to the minimum staff to youth ratio
required in (h)(3)(A)-(B), consideration shall be
given to the size, design, and location of the camp;
types of youth committed to the camp; and the ☐ ☐ ☒
function of the camp in determining the level of
supervision necessary to maintain the safety and
welfare of youth and staff;
(F) personnel with primary responsibility for other
duties such as administration, supervision of
personnel, academic or trade instruction, clerical, ☐ ☐ ☒
farm, forestry, kitchen or maintenance shall not be
classified as youth supervision staff positions.
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1328 SAFETY CHECKS
Chapter 3, 3.15 Safety Checks
The facility administrator shall develop and implement
policy and procedures that provide for direct visual
The facility uses the Guard 1/Pipe Electronic
observation of youth at a minimum of every 15 minutes,
safety check system. The policy includes an
at random or varied intervals during hours when youth
audit process and staff expectations in terms
are asleep or when youth are in their rooms, confined in
of ‘random and varied’ specific language.
holding cells or confined to their bed in a dormitory.
Operationally, the policy provides direction for
Supervision is not replaced, but may be supplemented
staff in how to use and download the
by, an audio/visual electronic surveillance system
information before, during, and after their shift
designed to detect overt, aggressive or assaultive
to ensure the correct officer is associated with
behavior and to summon aid in emergencies. All safety
the check.
checks shall be documented with the actual time the
check is completed.
Facility administration audits and reviews all
safety checks daily, handling late checks by
staff through a counseling, documented
memo, or other measures internally.
☒ ☐ ☐
The Juvenile Services Center encompasses
JH, CVA, and SYTF. Facility-wide, there were
six (6) late checks in January 2024, nine (9) in
March 2024, and six (6) in May 2024, of a
minimum of 3240 checks. We reviewed each
accompanying memo associated with the late
check, which included a video review of the
circumstances. Of the 21 late checks, the
agency found operator or electronic errors of
the system in five (5) instances.
Facility Administration continues to
acknowledge 100% compliance with policy by
recognizing staff who had no late checks in a
given month. In the months reviewed above,
18 staff had perfect checks in January 2024,
19 in March, and 18 in May.
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1354.5 ROOM CONFINEMENT
Chapter 5, 5.8 Room Confinement (RC)
(a) The facility administrator shall develop and
Chapter 5, 5.8, C Procedure for
implement written policies and procedures addressing
implementation of RC
the confinement of youth in their room that are
consistent with Welfare and Institutions Code Section
We reviewed all three (3) incidents of Room
208.3. The placement of a youth in room confinement
Confinement for JH SYTF youth from January
shall be accomplished in accordance with the following
2024 to the date of the inspection. All three (3)
guidelines:
were the same youth and involved aggressive
or assaultive behavior.
The staff monitor the behavior by having
discussions with the youth at minimum of
every 15 minutes and documenting the point
when a youth no longer poses a threat,
demonstrating he or she is ready to
reintegrate and come out of their room. Since
the last inspection, staff no longer wait for BH
staff to remove a youth but rather the on-duty
☒ ☐ ☐ JSO III meets with the youth to establish a
reintegration plan as soon as the youth is
ready.
The implementation and continued use of the
PBIS model of behavior modification allows
youth to confront negative behaviors by
reflection and discussion before a situation
escalates. Facility staff are trained to de-
escalate issues through counseling and
understanding the triggers which escalate bad
behavior. Allowing a youth to self-separate to
take a time out and work on calming behaviors
has been an effective tool as well.
Our review indicated all three (3) incidents of
RC did not go beyond four (4) hours but rather
1 hour and 25 minutes; 2 hours; and 3 hours
and 15 minutes.
(1) Room confinement shall not be used before
other, less restrictive, options have been attempted Chapter 5, 5.8, C-1
and exhausted, unless attempting those options ☒ ☐ ☐
poses a threat to the safety or security of any youth
or staff.
(2) Room confinement shall not be used for the
purposes of punishment, coercion, convenience, or ☒ ☐ ☐ Chapter 5, 5.8, C-2
retaliation by staff.
(3) Room confinement shall not be used to the extent
that it compromises the mental and physical health ☒ ☐ ☐ Chapter 5, 5.8, C-3
of the youth.
(b) A youth may be held up to four hours in room
confinement. After the youth has been held in room Chapter 5, 5.8, C-8
☒ ☐ ☐
confinement for a period of four hours, staff shall do one
or more of the following:
(1) Return the youth to general population. ☒ ☐ ☐ Chapter 5, 5.8, C-8
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Chapter 5, 5.8, C-5, b
(2) Consult with mental health or medical staff. ☒ ☐ ☐ The facility behavior health staff are notified
when a youth is placed on RC and respond
immediately.
(3) Develop an individualized plan that includes the
goals and objectives to be met in order to reintegrate ☒ ☐ ☐ Chapter 5, 5.8, D
the youth to general population.
(4) If room confinement must be extended beyond
four hours, staff shall do each of the following: Chapter 5, 5.8, D-2
(A) Document the reasons for room confinement
and the basis for the extension, the date and time ☒ ☐ ☐
the youth was first placed in room confinement,
and when he or she is eventually released from
room confinement.
(B) Develop an individualized plan that includes
the goals and objectives to be met in order to ☒ ☐ ☐ Chapter 5, 5.8, D-3
integrate the youth to general population.
(C) Obtain documented authorization by the
facility superintendent or his or her designee ☒ ☐ ☐ Chapter 5, 5.8, D-1
every four hours thereafter.
(5) This section is not intended to limit the use of
single-person rooms or cells for the housing of youth Chapter 5, 5.8, A and B-1
☒ ☐ ☐
in juvenile facilities and does not apply to normal
sleeping hours.
(6) This section does not apply to youth or wards in
court holding facilities or adult facilities. ☒ ☐ ☐ Chapter 5, 5.8, B-2
(7) Nothing in this section shall be construed to
conflict with any law providing greater or additional ☒ ☐ ☐
protections to youth.
(8) This section does not apply during an
extraordinary emergency circumstance that requires Chapter 5, 5.8, B-3
a significant departure from normal institutional
operations, including a natural disaster or facility-
☒ ☐ ☐
wide threat that poses an imminent and substantial
risk of harm to multiple staff or youth. This exception
shall apply for the shortest amount of time needed to
address this imminent and substantial risk of harm.
(9) This section does not apply when a youth is
placed in a locked cell or sleeping room to treat and Chapter 5, 5.8, B-4
protect against the spread of a communicable
disease for the shortest amount of time required to
reduce the risk of infection, with the written approval
of a licensed physician or nurse practitioner, when
the youth is not required to be in an infirmary for an ☒ ☐ ☐
illness. Additionally, this section does not apply when
a youth is placed in a locked cell or sleeping room for
required extended care after medical treatment with
the written approval of a licensed physician or nurse
practitioner, when the youth is not required to be in
an infirmary for illness.
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1357 USE OF FORCE
Chapter 5, 5.11 Use of Force (UF)
The facility administrator, in cooperation with the
Chapter 5, 5.11, D-2 General Provisions
responsible physician, shall develop and implement
Chapter 5, 5.11, L Chemical Agents
written policies and procedures for the use of force,
which may include chemical agents. Force shall never
We reviewed both UF incidents since January
be applied as punishment, discipline, retaliation or
2024 for JH SYTF youth. Staff are trained in
treatment.
UF and PBIS to prevent the need for force
(a) At a minimum, each facility shall develop policies and
unless no other options are available. Both
procedures which:
incidents involved the same youth and we
note neither involved the use of OC spray.
☒ ☐ ☐
The incidents reviewed provided clear
documentation of events leading to the force
option, including attempts to de-escalate.
When medical and mental health staff are on-
site, they respond immediately. It is noted all
UF incidents are administratively reviewed,
including video review, to determine if the
force was necessary. Each of the incidents
were determined that appropriate force was
used.
(1) restricts the use of force to that which is deemed
reasonable and necessary, as defined in Section 1302 Chapter 5, 5.11, D-5
☒ ☐ ☐
to ensure the safety and security of youth, staff, others
and the facility.
(2) outline the force options available to staff including
both physical and non-physical options and define Chapter 5, 5.11, D-3, 4 and 5
when those force options are appropriate. Chapter 5, 5.11, E Control and Compliance
☒ ☐ ☐ Holds
Chapter 5, 5.11, F Other Hand to Hand Force
Methods
(3) describe force options or techniques that are
expressly prohibited by the facility. Chapter 5, 5.11, D -13 Carotid Hold
☒ ☐ ☐
Chapter 5, 5.11, F-3 Kicking and punching.
(4) describe the requirements of staff to report any
inappropriate use of force, and to take affirmative Chapter 5, 5.11, D-10
☒ ☐ ☐
action to immediately stop it. Chapter 5, 5.11, O-8
(5) define a standardized reporting format that
includes time period and procedure for documenting Chapter 5, 5.11, P-1 through 5
and reporting the use of force, including reporting
requirements of management and line staff and
procedures for reviewing and tracking use of force
incidents by supervisory and or management staff, ☒ ☐ ☐
which include procedures for debriefing a particular
incident with staff and/or youth for the purposes of
training as well as mitigating the effects of trauma that
may have been experienced by staff and /or the youth
involved.
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(6) Include an administrative review and a system for
investigating unreasonable use of force. Chapter 5, 5.11, P-5
The Chief Deputy conducts an independent
☒ ☐ ☐ review of all UF incidents to determine the
need for internal investigation. Their review
includes submitted recommendations by the
supervisor who reviewed video of the incident.
(7) define the role, notification, and follow-up
procedures required after use of force incidents for Chapter 5, 5.11, D-15 Medical and Mental
medical, mental health staff and parents or legal Health
guardians. ☒ ☐ ☐ Chapter 5, 5.11, L-7 OC Spray notifications
Chapter 5, 5.11, L, O-10 Parent notification of
UF
(8) describe the limitations of use of force on pregnant
youth in accordance with Penal Code Section 6030(f) Chapter 5, 5.11, C-1, a
and Welfare and Institutions Code Section 222.
☒ ☐ ☐
This policy addresses known medical
conditions, including pregnant youth.
(b) Facilities that authorize chemical agents as a force
option shall include policies and procedures that: Chapter 5, 5.11, L Chemical Agents
(1) identify who is approved to carry and/or utilize Chapter 5, 5.11, L-1 Trained staff only
chemical agents in the facility and the type, size and ☒ ☐ ☐
the approved method of deployment for those It is noted there have been no incidents of OC
chemical agents. spray use in 2024.
(2) mandate that chemical agents only be used when
there is an imminent threat to the youth’s safety or the Chapter 5, 5.11, L-2
safety of others and only when de-escalation efforts ☒ ☐ ☐
have been unsuccessful or are not reasonably
possible.
(3) outline the facility’s approved methods and
timelines for decontamination from chemical agents. Chapter 5, 5.11, L-6
This shall include that youth who have been exposed Chapter 5, 5.11, L-8
to chemical agents shall not be left unattended until
☒ ☐ ☐
that youth is fully decontaminated or is no longer Policies provide youth are provided a change
suffering the effects of the chemical agent. of clothes within one (1) hour of the incident
and are not left unattended.
(4) define the role, notification, and follow-up
procedures required after use of force incidents Chapter 5, 5.11, L-7 OC Spray notifications
☒ ☐ ☐
involving chemical agents for medical, mental health Chapter 5, 5.11, O-10 Parent notification of UF
staff and parents or legal guardians.
(5) provide for the documentation of each incident of
use of chemical agents, including the reasons for Chapter 5, 5.11, O-2, a-h
which it was used, efforts to de-escalate prior to use,
youth and staff involved, the date, time and location ☒ ☐ ☐
of use, decontamination procedures applied and
identification of any injuries sustained as a result of
such use.
(c) Facilities shall develop policies and procedure which
require that agencies provide initial and regular training Chapter 5, 5.11, C Training
in use of force and chemical agents when appropriate Chapter 5, 5.11, C-1, a
☒ ☐ ☐
that address:
(1) known medical and behavioral health conditions
that would contraindicate certain types of force;
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(2) acceptable chemical agents and the methods of
application. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(3) signs or symptoms that should result in
immediate referral to medical or behavioral health. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(4) instruction on the Constitutional Limitations of
Use of Force. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(5) physical training force options that may require
the use of perishable skills. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
(6) timelines the facility uses to define regular
training. ☒ ☐ ☐ Chapter 5, 5.11, C-1, a
1361 GRIEVANCE PROCEDURE
Chapter 5, 5.15 Grievance Procedure
The facility administrator shall develop and implement
Chapter 5, 5.15 A
written policies and procedures whereby any youth may
appeal and have resolved grievances relating to any
We reviewed all seven (7) Grievances
condition of confinement, including but not limited to
submitted by youth from January 2024 to the
health care services, classification decisions, program
date of the inspection for JH, none were filed
participation, telephone, mail or visiting procedures,
from SYTF youth.
food, clothing, bedding, mistreatment, harassment or ☒ ☐ ☐
violations of the nondiscrimination policy. There shall be
The agency policy requires response within
no time limit on filing grievances. Policies and
two (2) days and resolution with five (5) days.
procedures shall include provisions whereby the facility
Facility staff have conversations with the
manager ensures:
youth and review video as a matter of
procedure, to ensure the youth understands
and accepts the outcome.
(a) a grievance form and instructions for registering a
grievance, which includes provisions for the youth to ☒ ☐ ☐ Chapter 5, 5.15, A
have free access to the form;
(b) the youth shall have the option to confidentially file
the grievance or to deliver the form to any youth ☒ ☐ ☐ Chapter 5, 5.15, G-3
supervision staff working in the facility;
(c) resolution of the grievance at the lowest appropriate
staff level; ☒ ☐ ☐ Chapter 5, 5.15, G
(d) provision for a prompt review and initial response to
grievances within three (3) business days, grievances Chapter 5, 5.15, E and G
that relate to health and safety issues must be
addressed immediately; ☒ ☐ ☐ The facility has an expectation to respond to
the grievance by end of shift or within two (2)
days and resolution within five (5) days.
(1) The youth may elect to be present to explain
his/her version of the grievance to a person not Chapter 5, 5.15, G-6
☒ ☐ ☐
directly involved in the circumstances which led to
the grievance.
(2) Provision for a staff representative approved by
the facility administrator to assist the youth. ☒ ☐ ☐ Chapter 5, 5.15, C
(e) provision for a written response to the grievance
which includes the reasons for the decisions; ☒ ☐ ☐ Chapter 5, 5.15, G-7
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(f) a system which provides that any appeal of a
grievance shall be heard by a person not directly Chapter 5, 5.15, F
☒ ☐ ☐
involved in the circumstances which led to the
grievance;
(g) resolution of the grievance must occur within ten (10)
business days unless circumstances dictate a longer Chapter 5, 5.15, G-8
☒ ☐ ☐
time frame. The youth shall be notified of any delay;
and,
(h) the policy shall provide multiple internal and external
methods to report sexual abuse and sexual harassment. ☒ ☐ ☐ Chapter 5, 5.15, G-13
Whether or not associated with a grievance, concerns
of parents, guardians, staff or other parties shall be Chapter 5, 5.15, G-12
☒ ☐ ☐
addressed and documented in accordance with written
policies and procedures within a specified timeframe.
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1371 PROGRAMS, RECREATION, AND
EXERCISE. Chapter 6, 6.2 Programs, Recreation and
Exercise
The facility administrator shall develop and implement
written policies and procedures for programs,
Programs for the SYTF youth in JH are
recreation, and exercise for all youth. The intent is to
facilitated by Restorative Partners (RP), an In-
minimize the amount of time youth are in their rooms or
Custody and Reentry Program for San Luis
their bed area.
Obispo County. Restorative Partners Inc.
serves people impacted by crime through a
continuum of services that focus on mind,
body, and spiritual transformation. The
programs include evidence-based, trauma-
informed approaches that increase self-
esteem, pro-social skills, multi-cultural and
non-violent communication, and life and job
skills. The nonprofit agency offers a
continuum of services to meet the needs in the
community for both youth and adult
populations. The goal for the juvenile facility is
to include gender-specific, trauma-informed,
and evidence-based services to the youth
population.
RP offers a comprehensive program schedule
with numerous opportunities for youth
participation, including: Sunday/Religious
Service; Cooking Programs; Crossroads
(cognitive and evidence-based curriculum
specific to offense); A Window between
Worlds; Book Club; Music Programs; West
☒ ☐ ☐ Garden Program, Art and Creative Writing;
Lumina Alliance Group; Bible Study;
Restorative Justice; Chess Club; Sports
Programs; AA and NA; Meditation; Ping-Pong;
and Tutoring. RP also acknowledges youth
Birthdays (one time a month) and Peer Leader
status (weekly) with celebrations for the youth.
The agency is in the middle of hiring a new
Program Manager for RP at the facility to
coordinate all the youth activities.
A new program planned for this population,
Kid CAT (Kids Creating Awareness Together),
is designed by a formerly subject-involved
person, to assist in the development of long-
term commitments and how to understand life
development.
Youth also receive programming services
from the San Luis Obispo Behavior Health
Clinicians and agency staff. These
opportunities include: Individual and Family
Counseling; a comprehensive Cognitive
Behavior Curriculum; Substance Abuse
Treatment; Child and Family Team meetings;
Independent Living; Parent Education and
Support; Off-site Community Activities;
Community Work Service Projects;
Gardening; Culinary Activities; Video, Board,
and Card games; Movie Night; High
School/Birthday and Holiday celebrations; In-
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house employment opportunities; Career Path
Opportunities; Gender-specific programming;
and PBIS.
It is important to note the agency, coordinated
with the San Luis Obispo Office of Education,
has a Classified Coordinator effective June
24, 2024, to assist graduated students and
those not wanting to complete their K-12
education (age out and decline services) with
post-secondary opportunities while in the
facility.
Our interview with the SYTF youth Thomas
revealed he graduated in March and is
currently enrolled in Cuesta College. He
indicated he participates in almost all
programming with his favorite being the
Crossroads Program. It is his plan to be a
Screen Writer and he is excited to be taking a
Critical Thinking English class next quarter.
Juvenile facilities shall provide the opportunity for
programs, recreation, and exercise a minimum of three Chapter 6, 6.2, A-1
hours a day during the week and five hours a day each
☒ ☐ ☐
Saturday, Sunday or other non-school days, of which
one hour shall be an outdoor activity, weather
permitting.
A youth’s participation in programs, recreation, and
exercise may be suspended only upon a written finding Chapter 6, 6.2, A-2
by the administrator/manager or designee that a youth ☒ ☐ ☐
represents a threat to the safety and security of the
facility.
Such program, recreation, and exercise schedule shall
be posted in the living units. ☒ ☐ ☐ Chapter 6, 6.2, A-3
There will be a written annual review of the programs,
recreation, and exercise by the responsible agency to Chapter 6, 6.2, A-4
ensure content offered is current, consistent, and
relevant to the population. ☒ ☐ ☐ The most recent annual review of programs
was completed by Valerie Vega, Restorative
Justice Manager II, completed in June 2024.
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(a) Programs. All youth shall be provided with the
opportunity for at least one hour of daily programming to Chapter 6, 6.2, B-1, a - c
include, but not be limited to, trauma focused, cognitive,
evidence-based, best practice interventions that are
culturally relevant and linguistically appropriate, or pro-
social interventions and activities designed to reduce
recidivism. These programs should be based on the
youth’s individual needs as required by Sections 1355
and 1356. Such programs may be provided under the
direction of the Chief Probation Officer or the County
Office of Education and can be administered by county
partners such as mental health agencies, community
based organizations, faith-based organizations or
Probation staff.
Programs may include but are not limited to:
(1) Cognitive Behavior Interventions;
(2) Management of Stress and Trauma; ☒ ☐ ☐
(3) Anger Management;
(4) Conflict Resolution;
(5) Juvenile Justice System;
(6) Trauma-related interventions;
(7) Victim Awareness;
(8) Self-Improvement;
(9) Parenting Skills and support;
(10) Tolerance and Diversity;
(11) Healing Informed Approaches;
(12) Interventions by Credible Messengers;
(13) Gender Specific Programming;
(14) Art, creative writing, or self-expression;
(15) CPR and First Aid training;
(16) Restorative Justice or Civic Engagement;
(17) Career and leadership opportunities; and,
(18) Other topics suitable to the youth population.
(b) Recreation. All youth shall be provided the opportunity
for at least one hour of daily access to unscheduled Chapter 6, 6.2, C-1
activities such as leisure reading, letter writing, and ☒ ☐ ☐
entertainment. Activities shall be supervised and include
orientation and may include coaching of youth.
(c) Exercise. All youth shall be provided with the
opportunity for at least one hour of large muscle activity Chapter 6, 6.2, D-1
each day.
Youth in each program participate in one (1)
hour of Physical Education during the school
☒ ☐ ☐
day facilitated by the SLOCOE. Because
graduated youth are still in the classroom,
they participate in exercise with Court School
youth.
The administrator/manager may suspend, for a period
not to exceed 24 hours, access to recreation and Chapter 6, 6.2, D-3
programs. The administrator/manager shall document ☒ ☐ ☐
the reasons why suspension of recreation and programs
occurs.
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