BSCC
Santa Barbara Probation (2023-2024 inspection cycle)
Read the report at Santa Barbara Probation ↗
October 17, 2024
Holly Benton, Chief Probation Officer
Santa Barbara County Probation Department
117 E. Carrillo Street
Santa Barbara, CA 93101
2023-2024 TARGETED INSPECTION, WELFARE & INSTITUTIONS CODE SECTIONS
209 & 885, SANTA BARBARA COUNTY PROBATION DEPARTMENT DETENTION
FACILITIES
Dear Chief Benton:
A Targeted Inspection of the Santa Barbara County Probation Department has been
completed. The following facilities were inspected on/between Tuesday, July 23, 2024,
and Tuesday, July 25, 2024:
FACILITY NAME BSCC # FACILITY TYPE
Santa Maria Juvenile Justice Center (SMJJC) 7574 JH
Santa Barbara Secure Youth Treatment Facility 7575
SYTF
(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 Titles 15 and 24, California Code of Regulations.
INSPECTION RESULTS
We identified no items of noncompliance with Title 15 Minimum Standards.
An Exit Briefing with your staff was held on Thursday, July 25, 2024; BSCC staff
presented an inspection overview and discussed technical assistance and best practice
recommendations.
* * *
Please email me at ray.watson@bscc.ca.gov or call (916) 846-5986 if you have any
questions.
Holly Benton, Chief Probation Officer
Page 2
Sincerely,
RAY WATSON
Field Representative
Facilities Standards and Operations Division
Enclosures
Cc: Presiding Judge, Santa Barbara County Juvenile Court*
Chair, Juvenile Justice Commission, Santa Barbara County*
Chair, Board of Supervisors, Santa Barbara County*
County Administrator, Santa Barbara County*
Tiffany Phillips, Facility Manager, Santa Barbara Country Probation
Malinda Barrera, Deputy Chief, Santa Barbara County Probation
*Copies of the inspection are available upon request or online at www.bscc.ca.gov.
7574+ Santa Barbara Probation JH SYTF Targeted LTR 2024
JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS
Board of State and Community Corrections
PROCEDURES CHECKLIST1
BSCC Code: 7574
FACILITY NAME: Susan J. Gionfriddo Juvenile Justice Center, also referred to in FACILITY TYPE: JH
this report as the Santa Maria Juvenile Justice Center (SMJJC)
PERSON(S) INTERVIEWED: Holly Benton, Chief Probation Officer; Melinda Barrera, Deputy Chief Probation Officer; Tiffany
Phillips, Probation Manager; Crystal Crockett, Supervising Deputy Probation Officer; Sarah Miller, Supervising Deputy Probation
Officer; Paola Terronez, Administrative Office Professional; Kisha Ojeda, Behavioral Health Supervisor; Sam Moreno, Food Service
Supervisor; Matt Linton, Court and Community School Principal; Noah Spevak, Supervising Deputy Probation Officer; Wendy
Garcia, Senior JIO; one male youth age 19, one male youth age 18
FIELD REPRESENTATIVE: Ray Watson and Forrest Coleman DATE: July 23, 2024, through July 25, 2024.
TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1321 STAFFING Policy 4112 – Supervision of Youth, Section I, C, Pg.
2
Each juvenile facility shall:
(a) have an adequate number of personnel sufficient
BSCC staff reviewed the Santa Maria Juvenile Justice
to carry out the overall facility operation and its
Center’s (SMJJC) policies and procedures for
programming, to provide for safety and security of
compliance with Title 15 regulations including, but not
youth and staff, and meet established standards and
limited to, staffing. The agency staffs both the SMJJC
regulations;
and the Santa Barbara Secure Youth Treatment
Facility (SBSYTF), which are located on the same
campus within the same complex. The agency was
operating three living units with a combined
population of 36 youth at the time of inspection. There
was a mixture of JH and SYTF youth in each of the
three units. There is a Sr. JIO assigned to oversee
each unit daily.
☒ ☐ ☐ BSCC staff also reviewed two random weeks of staff
schedules from the months of May, June, and July.
We were also provided with a facility information
worksheet which included a staffing summary. At the
time of inspection, the agency had the following
positions filled:
• 1 Probation Manager
• 3 Supervising Probation Officers
• 5 Senior Deputy Probation Officers (Sr. DPO)
• 9 Senior Juvenile Institutions Officers (Sr.
JIO)
• 25 Juvenile Institutions Officers (JIO)
• 2 Extra Help Juvenile Institutions Officers
• 8 Support staff
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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During the inspection, the agency had several staff
out on approved leave of absence. This coupled with
continuous vacancies requires the use of mandated
overtime. However, the agency still maintains a PREA
staffing ratio of 1:8 during waking hours and 1:16
during sleeping hours.
(b) ensure that no required services shall be denied Policy 4112 – Supervision of Youth, Section I, C, Pg.
because of insufficient numbers of staff on duty 2
absent exigent circumstances;
☒ ☐ ☐
BSCC staff provided technical assistance with
eliminating outdated language that suggests
keeping youth in rooms if staffing is not sufficient.
(c) have a sufficient number of supervisory level staff Policy 4112 – Supervision of Youth, Section I, C, Pg.
to ensure adequate supervision of all staff members; 2
☒ ☐ ☐
After a review of the schedule, as well as interviews
with youth and staff, BSCC staff confirmed there is a
Sr. JIO or Sr. DPO present at the facility on each shift.
(d) have a clearly identified person on duty at all Policy 4112 – Supervision of Youth, Section I, A, Pg.
times who is responsible for operations and activities 1
and has completed the Juvenile Corrections Officer
Core Course and PC 832 training: ☒ ☐ ☐ BSCC staff provided the agency with technical
assistance in ensuring it is clearly indicated on the
shift schedule which staff person is in charge of
operations and activities on each shift.
(e) have at least one staff member present on each Policy 4112 – Supervision of Youth, Section II, H, 6-7,
living unit whenever there are youth in the living unit; Pg. 5
☒ ☐ ☐ Through direct observation and interviews with staff
and youth, the agency regularly ensures that there is
a staff present in the unit or where a youth is present.
Youth are never left unsupervised.
(f) have sufficient food service personnel relative to Policy 4112 – Supervision of Youth, Section I, C, Pg.
the number and security of living units, including staff 2
qualified and available to: plan menus meeting
nutritional requirements of youth; provide kitchen The agency contracts with a local vendor (VTC) who
supervision; direct food preparation and servings; prepares and delivers all meals to SMJJC. The food
☒ ☐ ☐
conduct related training programs for culinary staff; service personnel onsite consist of:
and maintain necessary records; or, a facility may
serve food that meets nutritional standards prepared • 1 Food Services Supervisor
by an outside source; • 1 Fulltime Food Service Worker
• 1 Extra Help Food Services Worker
(g) have sufficient administrative, clerical, Policy 4112 – Supervision of Youth, Section I, C, Pg.
recreational, medical, dental, mental health, building 2
maintenance, transportation, control room, facility
security and other support staff for the efficient Due to the closure of the youth camp, the agency has
management of the facility, and to ensure that youth increased staffing by reassigning staff from the camp
supervision staff shall not be diverted from to SMJJC. In addition to staff assigned to the housing
supervising youth; and, units, the agency provides robust staffing for medical,
☒ ☐ ☐
maintenance, transportation, and clerical services.
Behavioral Health is staffed with 1 Supervisor, 2
Clinicians, and 1 Psychiatric Tech.
BSCC staff conducted interviews with medical,
behavioral health, administrative, and detention staff
to ensure compliance with this regulation.
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(h) assign sufficient youth supervision staff to provide Policy 4112 – Supervision of Youth, Section II, H, 4-6,
continuous wide awake supervision of youth, subject Pg. 4-5
to temporary variations in staff assignments to meet
☒ ☐ ☐
special program needs. Staffing shall be in
compliance with a minimum youth-staff ratio for the
following facility types:
(1) Juvenile Halls Policy 4112 – Supervision of Youth, Section II, H, 4, 1,
(A) during the hours that youth are awake, Pg. 4
one wide-awake youth supervision staff ☒ ☐ ☐
member on duty for each 10 youth in The agency operates with PREA staffing ratios of 1
detention; youth supervision staff to 8 youth during awake hours.
(B) during the hours that youth are confined to Policy 4112 – Supervision of Youth, Section II, H, 2,
their room for the purpose of sleeping, one Pg. 4
wide-awake youth supervision staff member
☒ ☐ ☐
on duty for each 30 youth in detention; The agency operates with PREA staffing ratios of 1
youth supervision staff to 16 youth during sleeping
hours.
(C) at least two wide-awake youth supervision Policy 4112 – Supervision of Youth, Section II, H, 3,
staff members on duty at all times, regardless Pg. 4
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 Policy 4112 – Supervision of Youth, Section II, H, 3,
member on duty who is the same gender as ☒ ☐ ☐ Pg. 4
youth housed in the facility.
(E) personnel with primary responsibility for Policy 4112 – Supervision of Youth, Section I, C, Pg
other duties such as administration, 2.
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 The facility is not a Special Purpose Juvenile Hall.
(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 N/A
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 N/A
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 N/A
member on duty who is the same gender as ☐ ☐ ☒
youth housed in the facility.
(E) personnel with primary responsibility for N/A
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.
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(3) Camps The facility is not a camp.
(A) during the hours that youth are awake,
one 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 N/A
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 N/A
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 N/A
member on duty who is the same gender as ☐ ☐ ☒
youth housed in the facility;
(E) in addition to the minimum staff to youth N/A
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 N/A
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 Policy 4112 – Supervision of Youth, Section II, I Pg. 5
The facility administrator shall develop and
BSCC staff reviewed safety check logs for the months
implement policy and procedures that provide for
of May, June, and July 2024.
direct visual observation of youth at a minimum of
every 15 minutes, at random or varied intervals
In review of safety check documentation, safety
during hours when youth are asleep or when youth
checks are being completed at a minimum of every 15
are in their rooms, confined in holding cells or
minutes and at random and varied intervals during the
confined to their bed in a dormitory. Supervision is
hours youth are confined to their rooms. However, we
not replaced, but may be supplemented by, an
discussed the importance of clearly documenting
audio/visual electronic surveillance system
when youth are in and out of their rooms. We provided
designed to detect overt, aggressive or assaultive
examples of how the current Welfare Check Log can
behavior and to summon aid in emergencies. All
be used to provide clearer documentation of the
safety checks shall be documented with the actual
actual times when youth are in and out of their rooms.
time the check is completed.
☒ ☐ ☐ Although the safety checks appeared to be random
and varied, we discussed with the agency the
importance of staff using a standard format when
documenting safety checks. Per policy, the Sr. JIO or
Sr. DPO performs daily inspections of the Welfare
Check Log on each shift to ensure compliance with
Title 15 regulation.
The agency’s policy states staff use the Guard 1
electronic system to record safety checks. After
reviewing documentation and touring the facility,
BSCC staff determined safety checks are being
recorded using handwritten logs. BSCC staff provided
technical assistance to update policies and
procedures to ensure safety checks are being
recorded in accordance with policy.
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1354.5 ROOM CONFINEMENT Policy 4110 - Room Confinement Status
(a) The facility administrator shall develop and
BSCC reviewed 15 incidents of Room Confinement
implement written policies and procedures
Status (RCS) for the months of May, June, and July
addressing the confinement of youth in their room
2024. We also reviewed policy and procedure, and
that are consistent with Welfare and Institutions
interviewed detention staff, collaborative partners,
Code Section 208.3. The placement of a youth in
and youth housed in the facility.
room confinement shall be accomplished in
accordance with the following guidelines:
BSCC staff provided technical assistance related to
the agency updating RCS policy 4110 and supporting
documents to ensure RCS procedures and the due
process procedure are not co-mingled together. We
provided clarification in distinguishing the due process
from room confinement, in that, the due process is
☒ ☐ ☐ associated with a disciplinary sanction given to the
youth, while room confinement shall not be used for
disciplinary sanctions/punishment. Therefore, due
process should be removed from RCS
documentation.
We also strongly encouraged the agency to ensure
there is adherence to policy and procedure when
administering, reviewing, and documenting incidents
of RCS. We discussed how each youth should be
individually assessed every hour, as per policy,
leading up to the first four hours of RCS.
BSCC also discussed best practice verbiage options
to eliminate the “time out” language in policy.
(1) Room confinement shall not be used before Policy 4110 - Room Confinement Status, Section II, B,
other, less restrictive, options have been 2, Pg. 4
attempted 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 Policy 4110 - Room Confinement Status, Section II, B,
purposes of punishment, coercion, ☒ ☐ ☐ 3, Pg. 4
convenience, or retaliation by staff.
(3) Room confinement shall not be used to the Policy 4110 - Room Confinement Status, Section II, B,
extent that it compromises the mental and ☒ ☐ ☐ 3, Pg. 4
physical health of the youth.
(b) A youth may be held up to four hours in room Policy 4110 - Room Confinement Status, Section II, B,
confinement. After the youth has been held in room 3, Pg. 4
confinement for a period of four hours, staff shall do
one or more of the following: ☒ ☐ ☐ BSCC staff reviewed incident reports and RCS review
sheets and interviewed detention staff, collaborative
partners, and youth housed in the facility. Youth are
not routinely held in RCS for more than four hours.
Policy 4110 - Room Confinement Status, Section II,
(1) Return the youth to general population. ☒ ☐ ☐
Pg. 4-6
Policy 4110 - Room Confinement Status, Section II,
Pg. 4-6
(2) Consult with mental health or medical staff. ☒ ☐ ☐
Youth are assessed by medical and mental health
staff within four hours, after being placed on RCS.
(3) Develop an individualized plan that includes Policy 4110 - Room Confinement Status, Section II,
the goals and objectives to be met in order to Pg. 4-6
reintegrate the youth to general population.
☒ ☐ ☐
The Individualized plan is comprehensive and
includes the goals and objectives to be met in order to
reintegrate youth back into general population.
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(4) If room confinement must be extended Policy 4110 - Room Confinement Status, Section II,
beyond four hours, staff shall do each of the Pg. 4-6
following:
(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 Policy 4110 - Room Confinement Status, Section II, B,
includes the goals and objectives to be met 3, C, iii, Pg. 6
☒ ☐ ☐
in order to integrate the youth to general
population.
(C) Obtain documented authorization by the Policy 4110 - Room Confinement Status, Section II, B,
facility superintendent or his or her designee 3, C Pg. 5-6
every four hours thereafter.
☒ ☐ ☐
Per SMJJC policy, staff shall obtain approval from the
facility director every four hours that room
confinement is continued.
(5) This section is not intended to limit the use of Policy 4110 - Room Confinement Status, Section II, B,
single-person rooms or cells for the housing of 3, C, Pg. 5-6
☒ ☐ ☐
youth in juvenile facilities and does not apply to
normal sleeping hours.
(6) This section does not apply to youth or wards Policy 4110 - Room Confinement Status, Section II, B,
☒ ☐ ☐
in court holding facilities or adult facilities. 3, C, Pg. 5-6
(7) Nothing in this section shall be construed to Policy 4110 - Room Confinement Status, Section II, B,
conflict with any law providing greater or ☒ ☐ ☐ 3, C, Pg. 5-6
additional protections to youth.
(8) This section does not apply during an Policy 4110 - Room Confinement Status, Section D,
extraordinary emergency circumstance that Pg. 8
requires 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 Policy 4110 - Room Confinement Status, Section D,
placed in a locked cell or sleeping room to treat Pg. 8
and 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.
1357 USE OF FORCE Policy 4121 – Use of Force
The facility administrator, in cooperation with the
BSCC staff reviewed policy and procedure and 10
responsible physician, shall develop and implement
Use of Force (UOF) incident reports for April, May,
written policies and procedures for the use of force,
which may include chemical agents. Force shall ☒ ☐ ☐ and June 2024. We also interviewed detention staff
and youth housed at the facility.
never be applied as punishment, discipline,
retaliation or treatment.
(a) At a minimum, each facility shall develop The facility is compliant with this regulation.
policies and procedures which:
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(1) restricts the use of force to that which is Policy 4121 – Use of Force, Section I, A, 2, Pg. 1
deemed reasonable and necessary, as defined in
☒ ☐ ☐
Section 1302 to ensure the safety and security of
youth, staff, others and the facility.
(2) outline the force options available to staff Policy 4121 – Use of Force, Section III, H, Pg. 8
including both physical and non-physical options
and define when those force options are Force options allowed include, but are not limited to,
appropriate. the following:
Non-physical options:
☒ ☐ ☐
• Staff Presence
• Verbal Command
Physical options:
• Mechanical restraints
• Unarmed defensive tactics
• Oleoresin Capsicum (OC)
(3) describe force options or techniques that are Policy 4122 – Use of Physical Restraints, Section II,
☒ ☐ ☐
expressly prohibited by the facility. C, D, Pg. 2
(4) describe the requirements of staff to report Policy 4121 – Use of Force, Section II, 4-5, a-d, Pg.
any inappropriate use of force, and to take ☒ ☐ ☐ 3-4
affirmative action to immediately stop it.
(5) define a standardized reporting format that Policy 4121 – Use of Force, Section IV, E, Pg. 15-16
includes time period and procedure for
documenting and reporting the use of force, Per SMJJC policy, all UOF events are logged and
including reporting requirements of management tracked by a designated Administrative Office
and line staff and procedures for reviewing and Professional.
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 Policy 4121 – Use of Force, Section IV, F, Pg. 17
for investigating unreasonable use of force.
BSCC staff confirmed compliance with policy that
indicates use of force events are reviewed monthly on
☒ ☐ ☐
a department level by the Use of Force Review
Committee. The committee is comprised of Deputy
Chiefs, Managers, SPOs, and training officers for the
facilities.
(7) define the role, notification, and follow-up Policy 4121 – Use of Force, Section IV, Pg. 17
procedures required after use of force incidents
☒ ☐ ☐
for medical, mental health staff and parents or
legal guardians.
(8) describe the limitations of use of force on Policy 4121 – Use of Force, Section IV, 8, Pg. 17
pregnant youth in accordance with Penal Code
☒ ☐ ☐
Section 6030(f) and Welfare and Institutions
Code Section 222.
(b) Facilities that authorize chemical agents as a Policy 4121 – Use of Force, Section IV, D, 8, 9, 12,
force option shall include policies and procedures Pg. 10-11
that:
(1) identify who is approved to carry and/or utilize ☒ ☐ ☐
chemical agents in the facility and the type, size
and the approved method of deployment for
those chemical agents.
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(2) mandate that chemical agents only be used Policy 4121 – Use of Force, Section IV, D, 5, Pg. 9
when there is an imminent threat to the youth’s
safety or the safety of others and only when de- ☒ ☐ ☐ The agency has developed policy and procedures
escalation efforts have been unsuccessful or are which outline the elements of this regulation.
not reasonably possible.
(3) outline the facility’s approved methods and Policy 4121 – Use of Force, Section IV, 14, a-l, Pg. 12-
timelines for decontamination from chemical 14
agents. This shall include that youth who have
been exposed to chemical agents shall not be left ☒ ☐ ☐ BSCC staff interviewed detention staff and youth
unattended until that youth is fully housed in the facility. Youth are not left unattended
decontaminated or is no longer suffering the until they are fully decontaminated and are no longer
effects of the chemical agent. suffering the effects of the chemical agent.
(4) define the role, notification, and follow-up Policy 4121 – Use of Force, Section IV, 12, e, Pg. 13
procedures required after use of force incidents
involving chemical agents for medical, mental ☒ ☐ ☐ BSCC staff interviewed medical services and
health staff and parents or legal guardians. behavioral health services staff to aid in confirming
compliance with this subsection of the regulation.
(5) provide for the documentation of each Policy 4121 – Use of Force, Section IV, E, Pg. 15-16
incident of use of chemical agents, including the
reasons for which it was used, efforts to de- Per SMJJC policy, staff are to write a Worker’s Special
escalate prior to use, youth and staff involved, Report (WSR) to include the elements in this
☒ ☐ ☐
the date, time and location of use, regulation.
decontamination procedures applied and
identification of any injuries sustained as a result
of such use.
(c) Facilities shall develop policies and procedure Policy 4121 – Use of Force, Section IV, C, 6, C, Pg.
which require that agencies provide initial and 4/Section IV, D, 8, Pg. 9
regular training in use of force and chemical agents
when appropriate that address: ☒ ☐ ☐
(1) known medical and behavioral health
conditions that would contraindicate certain
types of force;
(2) acceptable chemical agents and the Policy 4121 – Use of Force, Section IV, C, 6, Pg. 4
☒ ☐ ☐
methods of application.
(3) signs or symptoms that should result in Policy 4121 – Use of Force, Section IV, C, 6, Pg. 5
immediate referral to medical or behavioral ☒ ☐ ☐
health.
(4) instruction on the Constitutional Limitations Policy 4121 – Use of Force, Section IV, C, 6(4), Pg. 5
☒ ☐ ☐
of Use of Force.
(5) physical training force options that may Policy 4121 – Use of Force, Section IV, C, 6, Pg. 4
☒ ☐ ☐
require the use of perishable skills.
(6) timelines the facility uses to define regular Policy 4121 – Use of Force, Section IV, C, 6, Pg. 4-5
☒ ☐ ☐
training.
1361 GRIEVANCE PROCEDURE Policy 4123 – Grievances
The facility administrator shall develop and
BSCC staff reviewed a random selection of youth
implement written policies and procedures whereby
grievances from the months of May, June, and July
any youth may appeal and have resolved
2024. BSCC staff also interviewed youth housed at
grievances relating to any condition of confinement,
the facility, as well as detention staff. All the
including but not limited to health care services,
grievances we reviewed were resolved within the
classification decisions, program participation, ☒ ☐ ☐
timeframe indicated in Title 15 regulation.
telephone, mail or visiting procedures, food,
clothing, bedding, mistreatment, harassment or
violations of the nondiscrimination policy. There
shall be no time limit on filing grievances. Policies
and procedures shall include provisions whereby
the facility manager ensures:
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(a) a grievance form and instructions for registering Policy 4123 – Grievances, Section XI, Pg. 12-14
a grievance, which includes provisions for the youth
☒ ☐ ☐
to have free access to the form; During our tour of the facility, BSCC staff observed
grievance forms accessible to youth in the living units.
(b) the youth shall have the option to confidentially Policy 4123 – Grievances, Section XI, Pg. 12-14
file the grievance or to deliver the form to any youth
supervision staff working in the facility; ☒ ☐ ☐ There is also a grievance lockbox in each living unit
for the youth to confidentially file a grievance if
needed.
(c) resolution of the grievance at the lowest Policy 4123 – Grievances, Section XI, Pg. 12-14
appropriate staff level; ☒ ☐ ☐
(d) provision for a prompt review and initial Policy 4123 – Grievances, Section XI, Pg. 12-14
response to grievances within three (3) business
days, grievances that relate to health and safety ☒ ☐ ☐ BSCC staff interviewed youth housed in the facility
issues must be addressed immediately; and detention staff. The facility responds to each
grievance within three business days.
(1) The youth may elect to be present to explain Policy 4123 – Grievances, Section XI, Pg. 12-14
his/her version of the grievance to a person not
☒ ☐ ☐
directly involved in the circumstances which led
to the grievance.
(2) Provision for a staff representative approved Policy 4123 – Grievances, Section XI, Pg. 12-14
☒ ☐ ☐
by the facility administrator to assist the youth.
(e) provision for a written response to the grievance Policy 4123 – Grievances, Section XI, Pg. 12-14 s
☒ ☐ ☐
which includes the reasons for the decisions;
(f) a system which provides that any appeal of a Policy 4123 – Grievances, Section XI, Pg. 12-14
grievance shall be heard by a person not directly
☒ ☐ ☐
involved in the circumstances which led to the
grievance;
(g) resolution of the grievance must occur within ten Policy 4123 – Grievances, Section XI, Pg. 12-14
(10) business days unless circumstances dictate a
longer time frame. The youth shall be notified of ☒ ☐ ☐ BSCC staff interviewed youth housed in the facility
any delay; and, and detention staff. The facility resolves each
grievance within ten business days.
(h) the policy shall provide multiple internal and Policy 4123 – Grievances, Section XI, Pg. 12-14
external methods to report sexual abuse and sexual ☒ ☐ ☐
harassment.
Whether or not associated with a grievance, Policy 4123 – Grievances, Section XI, Pg. 12-14
concerns of parents, guardians, staff or other
parties shall be addressed and documented in ☒ ☐ ☐
accordance with written policies and procedures
within a specified timeframe.
1371 PROGRAMS, RECREATION, AND Policy 4113 – Programs, Recreation and Exercise for
EXERCISE. Youth
The facility administrator shall develop and
BSCC staff reviewed policies and procedures related
implement written policies and procedures for
to Programs, Recreation, and Exercise for youth. We
programs, recreation, and exercise for all youth. ☒ ☐ ☐
also reviewed daily programming logs and other
The intent is to minimize the amount of time youth
supporting documentation for the months of May,
are in their rooms or their bed area.
June, and July 2024.
The facility is in compliance with this regulation.
Juvenile facilities shall provide the opportunity for Policy 4113 – Programs, Recreation and Exercise for
programs, recreation, and exercise a minimum of Youth, Section I, Pg. 1
three hours a day during the week and five hours a
☒ ☐ ☐
day each Saturday, Sunday or other non-school BSCC staff interviewed youth housed in the facility to
days, of which one hour shall be an outdoor activity, ensure compliance with this regulation.
weather permitting.
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A youth’s participation in programs, recreation, and Policy 4113 – Programs, Recreation and Exercise for
exercise may be suspended only upon a written Youth, Section I, D, Pg.1
finding 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 Policy 4113 – Programs, Recreation and Exercise for
shall be posted in the living units. Youth, Section I, E, Pg. 1
Program schedules are posted in each living unit.
☒ ☐ ☐
BSCC staff provided technical assistance by
suggesting the program schedules include time
blocks indicating when each program will take place
each day.
There will be a written annual review of the Policy 4113 – Programs, Recreation and Exercise for
programs, recreation, and exercise by the Youth, Section I, F, Pg.1
responsible agency to ensure content offered is
☒ ☐ ☐
current, consistent, and relevant to the population. An annual memorandum provided by Facility
Manager Tiffany Phillips addressed all the elements
of this regulation.
(a) Programs. All youth shall be provided with the Policy 4113 – Programs, Recreation and Exercise for
opportunity for at least one hour of daily Youth, Section III, Pg. 9
programming to include, but not be limited to, trauma
focused, cognitive, evidence-based, best practice The agency contracts with Community Solutions Inc.
interventions that are culturally relevant and (CSI) which is a community-based organization to
linguistically appropriate, or pro-social interventions provide programs in the facility. There is also a Youth
and activities designed to reduce recidivism. These Specialist and a Conflict Resolution Specialist that
programs should be based on the youth’s individual come in to facilitate programming for youth. A list of
needs as required by Sections 1355 and 1356. Such programs offered by the facility include, but are not
programs may be provided under the direction of the limited to:
Chief Probation Officer or the County Office of
Education and can be administered by county • Conflict Resolution
partners such as mental health agencies, community • Seeking Safety
based organizations, faith-based organizations or • SUD Counselling
Probation staff. • PEP – Creative Expressions
Programs may include but are not limited to:
• Joven Noble
(1) Cognitive Behavior Interventions;
☒ ☐ ☐ • Creative Network
(2) Management of Stress and Trauma;
• ARISE Gang Intervention
(3) Anger Management;
• Life Skills
(4) Conflict Resolution;
• Moral Reconation Therapy
(5) Juvenile Justice System;
• Restorative Approaches Circles
(6) Trauma-related interventions;
(7) Victim Awareness;
BSCC staff interviewed youth housed in the facility as
(8) Self-Improvement;
well as detention staff and collaborative partners to
(9) Parenting Skills and support;
confirm compliance with this regulation. The youth
(10) Tolerance and Diversity;
interviewed indicate they participate in several
(11) Healing Informed Approaches;
different programs each week. Most youth we spoke
(12) Interventions by Credible Messengers;
with feel the programs are helpful and relevant to the
(13) Gender Specific Programming;
current population.
(14) Art, creative writing, or self-expression;
(15) CPR and First Aid training;
The facility is in compliance with this regulation.
(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 Policy 4113 – Programs, Recreation and Exercise for
opportunity for at least one hour of daily access to Youth, Section II, Pg. 2
unscheduled activities such as leisure reading, letter
writing, and entertainment. Activities shall be ☒ ☐ ☐ Recreation activities include Legos, board games,
supervised and include orientation and may include movies, puzzles, card games, and art activities.
coaching of youth. Interviews with youth indicate they have the
opportunity to choose their recreational activity.
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(c) Exercise. All youth shall be provided with the Policy 4113 – Programs, Recreation and Exercise for
opportunity for at least one hour of large muscle Youth, Section II, Pg. 2
activity each day.
☒ ☐ ☐
BSCC staff interviewed youth housed in the facility
and reviewed daily activities logs to confirm
compliance with this regulation.
The administrator/manager may suspend, for a Policy 4113 – Programs, Recreation and Exercise for
period not to exceed 24 hours, access to recreation Youth, Section II, Pg. 4
and 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: 7575
FACILITY NAME: Santa Barbara Secure Youth Treatment Facility (SYTF) FACILITY TYPE: SYTF
PERSON(S) INTERVIEWED: Holly Benton, Chief Probation Officer; Melinda Barrera, Deputy Chief Probation Officer; Tiffany Phillips,
Probation Manager; Crystal Crockett, Supervising Deputy Probation Officer; Sarah Miller, Supervising Deputy Probation Officer;
Paola Terronez, Administrative Office Professional; Kisha Ojeda, Behavioral Health Supervisor; Sam Moreno, Food Service
Supervisor; Matt Linton, Court and Community School Principal; Noah Spevak, Supervising Deputy Probation Officer; Wendy Garcia,
Senior JIO; one female youth age 19
FIELD REPRESENTATIVE: Ray Watson and Forrest Coleman DATE: July 23, 2024, through July 25, 2024
TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1321 STAFFING Policy 4112 – Supervision of Youth, Section I, C, Pg.
2
Each juvenile facility shall:
(a) have an adequate number of personnel sufficient
BSCC staff reviewed the Santa Maria Juvenile Justice
to carry out the overall facility operation and its
Center’s (SMJJC) policies and procedures for
programming, to provide for safety and security of
compliance with Title 15 regulations including, but not
youth and staff, and meet established standards and
limited to, staffing. The agency staffs both the SMJJC
regulations;
and the Santa Barbara Secure Youth Treatment
Facility (SBSYTF), which are located on the same
campus within the same complex. The agency was
operating three living units with a combined
population of 36 youth at the time of inspection. There
was a mixture of JH and SYTF youth in each of the
three units. There is a Sr. JIO assigned to oversee
each unit daily.
BSCC staff also reviewed two random weeks of staff
☒ ☐ ☐ schedules from the months of May, June, and July.
We were also provided with a facility information
worksheet which included a staffing summary. At the
time of inspection, the agency had the following
positions filled:
• 1 Probation Manager
• 3 Supervising Probation Officers
• 5 Senior Deputy Probation Officers (Sr. DPO)
• 9 Senior Juvenile Institutions Officers (Sr.
JIO)
• 25 Juvenile Institutions Officers (JIO)
• 2 Extra Help Juvenile Institutions Officers
• 8 Support staff
During the inspection, the agency had several staff
out on approved leave of absence. This coupled with
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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continuous vacancies requires the use of mandated
overtime. However, the agency still maintains a PREA
staffing ratio of 1:8 during waking hours and 1:16
during sleeping hours.
(b) ensure that no required services shall be denied Policy 4112 – Supervision of Youth, Section I, C, Pg.
because of insufficient numbers of staff on duty 2
absent exigent circumstances;
☒ ☐ ☐ BSCC staff provided technical assistance with
eliminating language that suggests keeping youth in
rooms if staffing is not sufficient.
(c) have a sufficient number of supervisory level staff Policy 4112 – Supervision of Youth, Section I, C, Pg.
to ensure adequate supervision of all staff members; 2
☒ ☐ ☐ After a review of the schedule, as well as interviews
with youth and staff, BSCC staff confirmed there is a
Sr. JIO or Sr. DPO present at the facility on each shift.
(d) have a clearly identified person on duty at all Policy 4112 – Supervision of Youth, Section I, A, Pg.
times who is responsible for operations and activities 1
and has completed the Juvenile Corrections Officer
Core Course and PC 832 training: BSCC staff provided the agency with technical
☒ ☐ ☐
assistance in ensuring it is clearly indicated on the
shift schedule which staff person is in charge of
operations and activities on each shift.
(e) have at least one staff member present on each Policy 4112 – Supervision of Youth, Section II, H, 6-7,
living unit whenever there are youth in the living unit; Pg. 5
Through direct observation and interviews with staff
☒ ☐ ☐
and youth, the agency regularly ensures that there is
a staff present in the unit or where a youth is present.
Youth are never left unsupervised.
(f) have sufficient food service personnel relative to Policy 4112 – Supervision of Youth, Section I, C, Pg.
the number and security of living units, including staff 2
qualified and available to: plan menus meeting
nutritional requirements of youth; provide kitchen The agency contracts with a local vendor (VTC) who
supervision; direct food preparation and servings; prepares and delivers all meals to SMJJC. The food
conduct related training programs for culinary staff; ☒ ☐ ☐ service personnel onsite consist of:
and maintain necessary records; or, a facility may
serve food that meets nutritional standards prepared • 1 Food Services Supervisor
by an outside source; • 1 Fulltime Food Service Worker
• 1 Extra Help Food Services Worker
(g) have sufficient administrative, clerical, Policy 4112 – Supervision of Youth, Section I, C, Pg.
recreational, medical, dental, mental health, building 2
maintenance, transportation, control room, facility
security and other support staff for the efficient Due to the closure of the youth camp, the agency has
management of the facility, and to ensure that youth increased staffing by reassigning staff from the camp
supervision staff shall not be diverted from to SMJJC. In addition to staff assigned to the housing
supervising youth; and, units, the agency provides sufficient staff for medical,
☒ ☐ ☐ maintenance, transportation, and clerical services.
Behavioral Health is staffed with 1 Supervisor, 2
Clinicians, and 1 Psychiatric Tech.
BSCC staff conducted interviews with medical,
behavioral health, administrative, and detention staff
to ensure compliance with this regulation.
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(h) assign sufficient youth supervision staff to provide Policy 4112 – Supervision of Youth, Section II, H, 4-6,
continuous wide-awake supervision of youth, subject Pg. 4-5
to temporary variations in staff assignments to meet
special program needs. Staffing shall be in ☒ ☐ ☐
compliance with a minimum youth-staff ratio for the
following facility types:
(1) Juvenile Halls Policy 4112 – Supervision of Youth, Section II, H, 4, 1,
(A) during the hours that youth are awake, Pg. 4
one wide-awake youth supervision staff
☒ ☐ ☐
member on duty for each 10 youth in The agency operates with PREA staffing ratios of 1
detention; youth supervision staff to 8 youth during awake hours.
(B) during the hours that youth are confined to Policy 4112 – Supervision of Youth, Section II, H, 2,
their room for the purpose of sleeping, one Pg. 4
wide-awake youth supervision staff member
on duty for each 30 youth in detention; ☒ ☐ ☐ The agency operates with PREA staffing ratios of 1
youth supervision staff to 16 youth during sleeping
hours.
(C) at least two wide-awake youth supervision Policy 4112 – Supervision of Youth, Section II, H, 3,
staff members on duty at all times, regardless Pg. 4
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 Policy 4112 – Supervision of Youth, Section II, H, 3,
member on duty who is the same gender as Pg. 4
☒ ☐ ☐
youth housed in the facility.
(E) personnel with primary responsibility for Policy 4112 – Supervision of Youth, Section I, C, Pg
other duties such as administration, 2.
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 The facility is not a Special Purpose Juvenile Hall.
(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 N/A
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 N/A
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 N/A
member on duty who is the same gender as
☐ ☐ ☒
youth housed in the facility.
(E) personnel with primary responsibility for N/A
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.
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(3) Camps The facility is not a camp.
(A) during the hours that youth are awake,
one 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 N/A
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 N/A
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 N/A
member on duty who is the same gender as
☐ ☐ ☒
youth housed in the facility;
(E) in addition to the minimum staff to youth N/A
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 N/A
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 Policy 4112 – Supervision of Youth, Section II, I Pg. 5
The facility administrator shall develop and
BSCC staff reviewed safety check logs for the months
implement policy and procedures that provide for
of May, June, and July 2024.
direct visual observation of youth at a minimum of
every 15 minutes, at random or varied intervals
In review of safety check documentation, safety
during hours when youth are asleep or when youth
checks are being completed at a minimum of every 15
are in their rooms, confined in holding cells or
minutes and at random and varied intervals during the
confined to their bed in a dormitory. Supervision is
hours youth are confined to their rooms. However, we
not replaced, but may be supplemented by, an
discussed the importance of clearly documenting
audio/visual electronic surveillance system
when youth are in and out of their rooms. We provided
designed to detect overt, aggressive or assaultive
examples of how the current Welfare Check Log can
behavior and to summon aid in emergencies. All
be used to provide clearer documentation of the
safety checks shall be documented with the actual
actual times when youth are in and out of their rooms.
time the check is completed.
Although the safety checks appeared to be random
☒ ☐ ☐
and varied, we discussed with the agency the
importance of staff using a standard format when
documenting safety checks. Per policy, the Sr. JIO or
Sr. DPO performs daily inspections of the Welfare
Check Log on each shift to ensure compliance with
Title 15 regulation.
The agency’s policy states staff use the Guard 1
electronic system to record safety checks. After
reviewing documentation and touring the facility,
BSCC staff determined safety checks are being
recorded using handwritten logs. BSCC staff provided
technical assistance to update policies and
procedures to ensure safety checks are being
recorded in accordance with policy.
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1354.5 ROOM CONFINEMENT Policy 4110 - Room Confinement Status
(a) The facility administrator shall develop and
BSCC reviewed five incidents of Room Confinement
implement written policies and procedures
Status (RCS) for the months of May, June, and July
addressing the confinement of youth in their room
2024. We also reviewed policy and procedure, and
that are consistent with Welfare and Institutions
interviewed detention staff, collaborative partners,
Code Section 208.3. The placement of a youth in
and youth housed in the facility.
room confinement shall be accomplished in
accordance with the following guidelines:
BSCC staff provided technical assistance related to
the agency updating RCS policy 4110 and supporting
documents to ensure RCS procedures and the due
process procedure are not co-mingled together. We
provided clarification in distinguishing the due process
from room confinement, in that, the due process is
associated with a disciplinary sanction given to the
☒ ☐ ☐
youth, while room confinement shall not be used for
disciplinary sanctions/punishment. Therefore, due
process should be removed from RCS
documentation.
We also strongly encouraged the agency to ensure
there is adherence to policy and procedure when
administering, reviewing, and documenting incidents
of RCS. We discussed how each youth should be
individually assessed every hour, as per policy,
leading up to the first four hours of RCS.
BSCC staff also discussed best practice verbiage
options to eliminate the “time out” language in policy.
(1) Room confinement shall not be used before Policy 4110 - Room Confinement Status, Section II, B,
other, less restrictive, options have been 2, Pg. 4
attempted 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 Policy 4110 - Room Confinement Status, Section II, B,
purposes of punishment, coercion, 3, Pg. 4
convenience, or retaliation by staff. ☒ ☐ ☐
(3) Room confinement shall not be used to the Policy 4110 - Room Confinement Status, Section II, B,
extent that it compromises the mental and 3, Pg. 4
☒ ☐ ☐
physical health of the youth.
(b) A youth may be held up to four hours in room Policy 4110 - Room Confinement Status, Section II, B,
confinement. After the youth has been held in room 3, Pg. 4
confinement for a period of four hours, staff shall do
one or more of the following: BSCC staff reviewed incident reports and RCS review
☒ ☐ ☐
sheets and interviewed detention staff, collaborative
partners, and youth housed in the facility. Youth are
not routinely held in RCS for more than four hours.
Policy 4110 - Room Confinement Status, Section II,
(1) Return the youth to general population.
☒ ☐ ☐ Pg. 4-6
Policy 4110 - Room Confinement Status, Section II,
Pg. 4-6
(2) Consult with mental health or medical staff.
☒ ☐ ☐
Youth are assessed by medical and mental health
staff within four hours, after being placed on RCS.
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(3) Develop an individualized plan that includes Policy 4110 - Room Confinement Status, Section II,
the goals and objectives to be met in order to Pg. 4-6
reintegrate the youth to general population.
☒ ☐ ☐ The Individualized plan is comprehensive and
includes the goals and objectives to be met in order to
reintegrate youth back into general population.
(4) If room confinement must be extended Policy 4110 - Room Confinement Status, Section II,
beyond four hours, staff shall do each of the Pg. 4-6
following:
(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 Policy 4110 - Room Confinement Status, Section II, B,
includes the goals and objectives to be met 3, C, iii, Pg. 6
in order to integrate the youth to general ☒ ☐ ☐
population.
(C) Obtain documented authorization by the Policy 4110 - Room Confinement Status, Section II, B,
facility superintendent or his or her designee 3, C Pg. 5-6
every four hours thereafter.
☒ ☐ ☐ Per SMJJC policy, staff shall obtain approval from the
facility director every four hours that room
confinement is continued.
(5) This section is not intended to limit the use of Policy 4110 - Room Confinement Status, Section II, B,
single-person rooms or cells for the housing of 3, C, Pg. 5-6
youth in juvenile facilities and does not apply to ☒ ☐ ☐
normal sleeping hours.
(6) This section does not apply to youth or wards Policy 4110 - Room Confinement Status, Section II, B,
in court holding facilities or adult facilities. ☒ ☐ ☐ 3, C, Pg. 5-6
(7) Nothing in this section shall be construed to Policy 4110 - Room Confinement Status, Section II, B,
conflict with any law providing greater or 3, C, Pg. 5-6
☒ ☐ ☐
additional protections to youth.
(8) This section does not apply during an Policy 4110 - Room Confinement Status, Section D,
extraordinary emergency circumstance that Pg. 8
requires 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 Policy 4110 - Room Confinement Status, Section D,
placed in a locked cell or sleeping room to treat Pg. 8
and 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 Policy 4121 – Use of Force
The facility administrator, in cooperation with the
BSCC staff reviewed policy and procedure and 3 Use
responsible physician, shall develop and implement
of Force (UOF) incident reports for the months of April
written policies and procedures for the use of force,
and July 2024. We also interviewed detention staff
which may include chemical agents. Force shall
☒ ☐ ☐ and youth housed at the facility.
never be applied as punishment, discipline,
retaliation or treatment.
The facility is compliant with this regulation.
(a) At a minimum, each facility shall develop
policies and procedures which:
(1) restricts the use of force to that which is Policy 4121 – Use of Force, Section I, A, 2, Pg. 1
deemed reasonable and necessary, as defined in
Section 1302 to ensure the safety and security of ☒ ☐ ☐
youth, staff, others and the facility.
(2) outline the force options available to staff Policy 4121 – Use of Force, Section III, H, Pg. 8
including both physical and non-physical options
and define when those force options are Force options allowed include, but are not limited to,
appropriate. the following:
Non-physical options:
☒ ☐ ☐ • Staff Presence
• Verbal Command
Physical options:
• Mechanical restraints
• Unarmed defensive tactics
• Oleoresin Capsicum (OC)
(3) describe force options or techniques that are Policy 4122 – Use of Physical Restraints, Section II,
expressly prohibited by the facility. ☒ ☐ ☐ C, D, Pg. 2
(4) describe the requirements of staff to report Policy 4121 – Use of Force, Section II, 4-5, a-d, Pg.
any inappropriate use of force, and to take 3-4
☒ ☐ ☐
affirmative action to immediately stop it.
(5) define a standardized reporting format that Policy 4121 – Use of Force, Section IV, E, Pg. 15-16
includes time period and procedure for
documenting and reporting the use of force, Per SMJJC policy, all UOF events are logged and
including reporting requirements of management tracked by a designated Administrative Office
and line staff and procedures for reviewing and Professional.
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 Policy 4121 – Use of Force, Section IV, F, Pg. 17
for investigating unreasonable use of force.
BSCC staff confirmed compliance with policy that
indicates use of force events are reviewed monthly on
☒ ☐ ☐ a department level by the Use of Force Review
Committee. The committee is comprised of Deputy
Chiefs, Managers, SPOs, and training officers for the
facilities.
(7) define the role, notification, and follow-up Policy 4121 – Use of Force, Section IV, Pg. 17
procedures required after use of force incidents
for medical, mental health staff and parents or ☒ ☐ ☐
legal guardians.
(8) describe the limitations of use of force on Policy 4121 – Use of Force, Section IV, 8, Pg. 17
pregnant youth in accordance with Penal Code
Section 6030(f) and Welfare and Institutions ☒ ☐ ☐
Code Section 222.
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(b) Facilities that authorize chemical agents as a Policy 4121 – Use of Force, Section IV, D, 8, 9, 12,
force option shall include policies and procedures Pg. 10-11
that:
(1) identify who is approved to carry and/or utilize
☒ ☐ ☐
chemical agents in the facility and the type, size
and the approved method of deployment for
those chemical agents.
(2) mandate that chemical agents only be used Policy 4121 – Use of Force, Section IV, D, 5, Pg. 9
when there is an imminent threat to the youth’s
safety or the safety of others and only when de- The agency has developed policy and procedures
☒ ☐ ☐
escalation efforts have been unsuccessful or are which outline the elements of this regulation.
not reasonably possible.
(3) outline the facility’s approved methods and Policy 4121 – Use of Force, Section IV, 14, a-l, Pg. 12-
timelines for decontamination from chemical 14
agents. This shall include that youth who have
been exposed to chemical agents shall not be left BSCC staff interviewed detention staff and youth
☒ ☐ ☐
unattended until that youth is fully housed in the facility. Youth are not left unattended
decontaminated or is no longer suffering the until they are fully decontaminated and are no longer
effects of the chemical agent. suffering the effects of the chemical agent.
(4) define the role, notification, and follow-up Policy 4121 – Use of Force, Section IV, 12, e, Pg. 13
procedures required after use of force incidents
involving chemical agents for medical, mental BSCC staff interviewed medical services and
☒ ☐ ☐
health staff and parents or legal guardians. behavioral health services staff to aid in confirming
compliance with this subsection of the regulation.
(5) provide for the documentation of each Policy 4121 – Use of Force, Section IV, E, Pg. 15-16
incident of use of chemical agents, including the
reasons for which it was used, efforts to de- Per SMJJC policy, staff are to write a Worker’s Special
escalate prior to use, youth and staff involved, Report (WSR) to include the elements in this
the date, time and location of use, ☒ ☐ ☐ regulation.
decontamination procedures applied and
identification of any injuries sustained as a result
of such use.
(c) Facilities shall develop policies and procedure Policy 4121 – Use of Force, Section IV, C, 6, C, Pg.
which require that agencies provide initial and 4/Section IV, D, 8, Pg. 9
regular training in use of force and chemical agents
when appropriate that address:
☒ ☐ ☐
(1) known medical and behavioral health
conditions that would contraindicate certain
types of force;
(2) acceptable chemical agents and the Policy 4121 – Use of Force, Section IV, C, 6, Pg. 4
methods of application. ☒ ☐ ☐
(3) signs or symptoms that should result in Policy 4121 – Use of Force, Section IV, C, 6, Pg. 5
immediate referral to medical or behavioral
☒ ☐ ☐
health.
(4) instruction on the Constitutional Limitations Policy 4121 – Use of Force, Section IV, C, 6(4), Pg. 5
of Use of Force. ☒ ☐ ☐
(5) physical training force options that may Policy 4121 – Use of Force, Section IV, C, 6, Pg. 4
require the use of perishable skills. ☒ ☐ ☐
(6) timelines the facility uses to define regular Policy 4121 – Use of Force, Section IV, C, 6, Pg. 4-5
training. ☒ ☐ ☐
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1361 GRIEVANCE PROCEDURE Policy 4123 –Grievances
The facility administrator shall develop and
BSCC staff reviewed a random selection of youth
implement written policies and procedures whereby
grievances from the months of May, June, and July
any youth may appeal and have resolved
2024. BSCC staff also interviewed youth housed at
grievances relating to any condition of confinement,
the facility, as well as detention staff. All the
including but not limited to health care services,
grievances we reviewed were resolved within the
classification decisions, program participation,
☒ ☐ ☐ timeframe indicated in Title 15 regulation.
telephone, mail or visiting procedures, food,
clothing, bedding, mistreatment, harassment or
violations of the nondiscrimination policy. There
shall be no time limit on filing grievances. Policies
and procedures shall include provisions whereby
the facility manager ensures:
(a) a grievance form and instructions for registering Policy 4123 –Grievances, Section XI, Pg. 12-14
a grievance, which includes provisions for the youth
to have free access to the form; ☒ ☐ ☐ During our tour of the facility, BSCC staff observed
grievance forms accessible to youth in the living units.
(b) the youth shall have the option to confidentially Policy 4123 –Grievances, Section XI, Pg. 12-14
file the grievance or to deliver the form to any youth
supervision staff working in the facility; ☒ ☐ ☐ There is also a grievance lockbox in each living unit to
confidentially file a grievance if needed.
(c) resolution of the grievance at the lowest Policy 4123 –Grievances, Section XI, Pg. 12-14
appropriate staff level; ☒ ☐ ☐
(d) provision for a prompt review and initial Policy 4123 –Grievances, Section XI, Pg. 12-14
response to grievances within three (3) business
days, grievances that relate to health and safety BSCC staff interviewed youth housed in the facility
☒ ☐ ☐
issues must be addressed immediately; and detention staff. The facility responds to each
grievance within three business days.
(1) The youth may elect to be present to explain Policy 4123 –Grievances, Section XI, Pg. 12-14
his/her version of the grievance to a person not
directly involved in the circumstances which led ☒ ☐ ☐
to the grievance.
(2) Provision for a staff representative approved Policy 4123 –Grievances, Section XI, Pg. 12-14
by the facility administrator to assist the youth. ☒ ☐ ☐
(e) provision for a written response to the grievance Policy 4123 –Grievances, Section XI, Pg. 12-14 s
which includes the reasons for the decisions; ☒ ☐ ☐
(f) a system which provides that any appeal of a Policy 4123 –Grievances, Section XI, Pg. 12-14
grievance shall be heard by a person not directly
involved in the circumstances which led to the ☒ ☐ ☐
grievance;
(g) resolution of the grievance must occur within ten Policy 4123 –Grievances, Section XI, Pg. 12-14
(10) business days unless circumstances dictate a
longer time frame. The youth shall be notified of BSCC staff interviewed youth housed in the facility
☒ ☐ ☐
any delay; and, and detention staff. The facility resolves each
grievance within ten business days.
(h) the policy shall provide multiple internal and Policy 4123 –Grievances, Section XI, Pg. 12-14
external methods to report sexual abuse and sexual
☒ ☐ ☐
harassment.
Whether or not associated with a grievance, Policy 4123 –Grievances, Section XI, Pg. 12-14
concerns of parents, guardians, staff or other
parties shall be addressed and documented in
☒ ☐ ☐
accordance with written policies and procedures
within a specified timeframe.
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1371 PROGRAMS, RECREATION, AND Policy 4113 – Programs, Recreation and Exercise for
EXERCISE. Youth
The facility administrator shall develop and
BSCC staff reviewed policies and procedures related
implement written policies and procedures for
to Programs Recreation and Exercise for youth. We
programs, recreation, and exercise for all youth.
☒ ☐ ☐ also reviewed daily programming logs and other
The intent is to minimize the amount of time youth
supporting documentation for the months of May,
are in their rooms or their bed area.
June, and July 2024.
The facility is in compliance with this regulation.
Juvenile facilities shall provide the opportunity for Policy 4113 – Programs, Recreation and Exercise for
programs, recreation, and exercise a minimum of Youth, Section I, Pg. 1
three hours a day during the week and five hours a
day each Saturday, Sunday or other non-school ☒ ☐ ☐ BSCC staff interviewed youth housed in the facility to
days, of which one hour shall be an outdoor activity, ensure compliance with this regulation.
weather permitting.
A youth’s participation in programs, recreation, and Policy 4113 – Programs, Recreation and Exercise for
exercise may be suspended only upon a written Youth, Section I, D, Pg.1
finding 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 Policy 4113 – Programs, Recreation and Exercise for
shall be posted in the living units. Youth, Section I, E, Pg. 1
Program schedules are posted in each living unit.
☒ ☐ ☐ BSCC staff provided technical assistance by
suggesting the program schedules include time
blocks indicating when each program will take place
each day.
There will be a written annual review of the Policy 4113 – Programs, Recreation and Exercise for
programs, recreation, and exercise by the Youth, Section I, F, Pg.1
responsible agency to ensure content offered is
current, consistent, and relevant to the population. ☒ ☐ ☐ An annual memorandum provided by Facility
Manager Tiffany Phillips addressed all the elements
of this regulation.
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(a) Programs. All youth shall be provided with the Policy 4113 – Programs, Recreation and Exercise for
opportunity for at least one hour of daily Youth, Section III, Pg. 9
programming to include, but not be limited to, trauma
focused, cognitive, evidence-based, best practice The agency contracts with Community Solutions Inc.
interventions that are culturally relevant and (CSI) which is a community-based organization to
linguistically appropriate, or pro-social interventions provide programs in the facility. There is also a Youth
and activities designed to reduce recidivism. These Specialist and a Conflict Resolution Specialist that
programs should be based on the youth’s individual come in to facilitate programming for youth. A list of
needs as required by Sections 1355 and 1356. Such programs offered by the facility include, but are not
programs may be provided under the direction of the limited to:
Chief Probation Officer or the County Office of
Education and can be administered by county • Conflict Resolution
partners such as mental health agencies, community • Seeking Safety
based organizations, faith-based organizations or • SUD Counselling
Probation staff. • PEP – Creative Expressions
Programs may include but are not limited to:
• Joven Noble
(1) Cognitive Behavior Interventions;
• Creative Network
(2) Management of Stress and Trauma; ☒ ☐ ☐
• ARISE Gang Intervention
(3) Anger Management;
• Life Skills
(4) Conflict Resolution;
• Moral Reconation Therapy
(5) Juvenile Justice System;
• Restorative Approaches Circles
(6) Trauma-related interventions;
(7) Victim Awareness;
BSCC staff interviewed youth housed in the facility as
(8) Self-Improvement;
well as detention staff and collaborative partners to
(9) Parenting Skills and support;
confirm compliance with this regulation. The youth
(10) Tolerance and Diversity;
interviewed indicate they participate in several
(11) Healing Informed Approaches;
different programs each week. Most youth we spoke
(12) Interventions by Credible Messengers;
with feel the programs are helpful and relevant to the
(13) Gender Specific Programming;
current population.
(14) Art, creative writing, or self-expression;
(15) CPR and First Aid training;
The facility is in compliance with this regulation.
(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 Policy 4113 – Programs, Recreation and Exercise for
opportunity for at least one hour of daily access to Youth, Section II, Pg. 2
unscheduled activities such as leisure reading, letter
writing, and entertainment. Activities shall be Recreation activities include Legos, board games,
☒ ☐ ☐
supervised and include orientation and may include movies, puzzles, card games, and art activities.
coaching of youth. Interviews with youth indicate they have the
opportunity to choose their recreational activity.
(c) Exercise. All youth shall be provided with the Policy 4113 – Programs, Recreation and Exercise for
opportunity for at least one hour of large muscle Youth, Section II, Pg. 2
activity each day.
☒ ☐ ☐ BSCC staff interviewed youth housed in the facility
and reviewed daily activities logs to confirm
compliance with this regulation.
The administrator/manager may suspend, for a Policy 4113 – Programs, Recreation and Exercise for
period not to exceed 24 hours, access to recreation Youth, Section II, Pg. 4
and programs. The administrator/manager shall
☒ ☐ ☐
document the reasons why suspension of recreation
and programs occurs.
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