BSCC
Orange County, Cypress Police Department (2018-2020 inspection cycle)
Read the report at Orange County, Cypress Police Department ↗
December 10, 2020
Rod Cox, Chief of Police
Cypress Police Department
5275 Orange Ave
Cypress, CA 90630
2018-2020 BIENNIAL INSPECTION 6031 PC and 209 WIC/JJDPA SECTION 6031
Dear Chief Cox
As you are aware, The Board of State and Community Corrections (BSCC) is statutory required to
inspect all Local detention facility’s biennial for compliance with the Minimum Standards for Local
Detention Facilities as outlined in Titles 15 and 24, California Code of Regulations, per Penal Code
Section 6031 and for Welfare and Institutions Code (WIC) Section 209.
Due to the coronavirus pandemic and the issuance of statewide and local shelter-in-place orders, BSCC
staff were prohibited from traveling and unable to complete on-site inspections from March 16 through
June 30, 2020, the end of the 2018/2020 biennial inspection cycle. BSCC staff conducted virtual
inspections via desk audit of all facilities originally scheduled for inspection during this time. Desk audits
are comprised of a comprehensive review of all applicable policies and procedures and documentation
your agency provided. BSCC staff intend to conduct comprehensive on-site inspections of all local
detention facilities as soon as travel restrictions are lifted.
The BSCC inspection report is enclosed and consists of this transmittal letter and the Procedures
Checklist outlining applicable Title 15 sections.
Local Inspection
In addition to a biennial inspection by the BSCC, inspections are also required annually by the County
Health Officer and biennially by the State Fire Marshal or an authorized representative (Health and
Safety Code Sections 101045 and 13146.1). Please consider our report in conjunction with these
reports for a comprehensive perspective of your facility.
There were no noncompliance issues as it relates to the fire inspection or the county health inspection.
Title 15, CCR Inspection
Our evaluation consisted of reviewing only those policies and procedures related specifically to the
applicable regulations included in Title 15, CCR. We found no items of noncompliance.
3630 Orange Cypress PD LTR 18-20
Rod Cox, Chief of Police
Page 2
Please refer to the Procedures Checklist for detailed information.
Title 24, CCR Inspection
BSCC was unable to physically review the physical plants during this inspection cycle. However, we
were informed that there were no new or remodel project concerning the jail facility. We will review the
physical plant during the 2020-2022 inspection cycle.
JUVENILE INSPECTION
In accordance with the JJDPA, BSCC monitors law enforcement facilities for compliance with three
core requirements of the Act: Deinstitutionalization of Status Offenders, Separation of Juveniles from
Incarcerated Adults, and Removal from Adult Jails and Lockups (6-hour secure detention limitation).
Secure youth will be detained in a lock interview room outside the jail facility.
CORRECTIVE ACTION PLAN
No areas of noncompliance were noted, and no corrective action is needed.
This concludes our inspection report for the 2018-2020 inspection cycle. We are hopeful that we can
return to our normal inspection processes during the 2020-2022 inspection cycle. Although we were
unable to provide your department with the services you are accustomed to, I want to assure you that
BSCC remain committed to be a resource to your agency regarding your custodial questions or
concerns. If you have any questions, or concerns, please contact our office at any time.
Sincerely,
MICHAEL J. BUSH
Field Representative
Facilities Standards and Operations Division
Enclosures
cc: Chair, City Council, City of Cypress *
City Manager, City of Cypress*
Presiding Judge, Superior Court, County of Orange*
Grand Jury Foreperson, Superior Court, County of Orange*
Greg Faessel, Sergeant, Cypress Police Department
*Copies of the report are located on BSCC website*
3630 Orange Cypress PD LTR 18-20
TEMPORARY HOLDING FACILITIES
Board of State and Community Corrections
PROCEDURES1
BSCC Code: 3630
FACILITY NAME: Cypress Police Department City Jail FACILITY TYPE: TH
PERSON(S) INTERVIEWED: Sergeant Greg Faessel
FIELD REPRESENTATIVE: Michael J. Bush DATE:
05/16/2020
TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1024 COURT HOLDING AND TEMPORARY All staff who have responsibility of supervising
HOLDING FACILITY TRAINING inmates have completed the initial mandatory
(8) hrs. of training.
Custodial personnel who supervise inmates in, and
supervisors of, a Court Holding or Temporary Holding
facility shall complete 8 hours of specialized training. Such
training shall include, but not be limited to:
(a) applicable minimum jail standards;
(b) jail operations liability; ☒ ☐ ☐
(c) inmate segregation;
(d) emergency procedures and planning, fire and life
safety; and,
(e) suicide prevention.
Each agency shall determine if additional training is needed
based upon, but not limited to, the complexity of the facility,
the number of inmates, the employees' level of experience
and training, and other relevant factors
Such training shall be completed as soon as practical, but in
any event not more than six months after the date of assigned
responsibility, or the effective date of this regulation.
Successful completion of Core training or supplemental ☒ ☐ ☐
Core training, pursuant to Section 1020, Corrections Officer
Core Course, may be substituted for the initial eight hours of
training.
Eight hours of refresher training shall be completed once All staff who have responsibility of supervising
every two years. Successful completion of the requirements inmates have completed the mandatory (8) hrs.
☒ ☐ ☐
in Section 1025, Continuing Professional Training may be refresher training through the Orange Co.
substituted for the eight hour refresher. Sheriff’s Department.
1027 NUMBER OF PERSONNEL In addition to the implementation and operation
of all programs and activities required by the
regulations, another predicator for compliance
A sufficient number of personnel shall be employed in each
local detention facility to ensure the implementation and
☒ ☐ ☐ with this section is the availability of staff to
complete and document at least hourly safety
operation of the programs and activities required by these
checks.
regulations.
1 This document is intended for use as a tool during the 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 Local Facilities, Division 1, Chapter 1, Subchapter 4 for the complete list and text of regulations.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
Whenever there is an inmate in custody, there shall be at 100.6
least one employee on duty at all times in a local detention At least one Police Services Officer (PSO)
facility or in the building which houses a local detention whenever an inmate is in custody. The
☒ ☐ ☐
facility who shall be immediately available and accessible to assigned PSO shall complete booking
inmates in the event of an emergency. procedures, house and transport inmates,
prepare and serve inmate meals, conduct safety.
Such an employee shall not have any other duties which 102.1
would conflict with the supervision and care of inmates in ☒ ☐ ☐
the event of an emergency.
Whenever one or more female inmates are in custody, there 102.1
shall be at least one female employee who shall be PSO, sworn female police officer or matron is
☒ ☐ ☐
immediately available and accessible to such females. always present in the building.
Note: Reference PC§ 4021.
To determine if there is a sufficient number of personnel for
a specific facility, the facility administrator shall prepare and
retain a staffing plan indicating the personnel assigned in the
facility and their duties. Such a staffing plan shall be
☒ ☐ ☐
reviewed by the Board staff at the time of their biennial
inspection. The results of such a review and
recommendations shall be reported to the local jurisdiction
having fiscal responsibility for the facility.
1027.5 SAFETY CHECKS 102.1
The Watch Commander shall ensure that the
Safety checks shall be conducted at least hourly through ☒ ☐ ☐ inmate has at least an hourly safety check
direct visual observation of all inmates. There shall be no through direct visual supervision. This safety
more than a 60-minute lapse between safety checks. check shall be documented on the detention
facility log.
There is a written plan that includes the documentation of Reviewed three months of safety checks. all
☒ ☐ ☐
routine safety checks. within the standards time frame.
1028 FIRE AND LIFE SAFETY STAFF This requirement is included in the officers
initial training.
Whenever there is an inmate in custody, there shall be at
☒ ☐ ☐
least one person on duty at all times who meets the training
standards established by the BSCC for general fire and life
safety. (Penal Code section 6030[e])
The facility manager shall ensure that there is at least one
person on duty who trained in fire and life safety procedures ☒ ☐ ☐
that relate specifically to the facility.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1029 POLICY AND PROCEDURES MANUAL 2 Unless otherwise stated, all policies reviewed
were contained within the Cypress Police
Department Detention Facility Policy and
Facility administrator(s) shall develop and publish a manual
Procedure Manual.
of policy and procedures for the facility. The policy and
procedures manual shall address all applicable Title 15 and
Title 24 regulations and shall be comprehensively reviewed
and updated at least every two years. Such a manual shall be
made available to all employees.
☒ ☐ ☐
The policies and procedures required in subsections (a)(6)
and (a)(7) may be placed in a separate manual to ensure
confidentiality. Subsections c and d do not apply and have
been deleted.
(a) The manual for Temporary Holding, Type I, II, and III
facilities shall provide for, but not be limited to, the
following:
(1) Table of organization, including channels of 100
☒ ☐ ☐
communications.
(2) Inspections and operations reviews by the facility 100.6
☒ ☐ ☐
administrator/manager.
(3) Policy on the use of force. ☒ ☐ ☐ Department policy.
(4) Policy on the use of restraint equipment, including the 106.21
restraint of pregnant inmates as referenced in Penal Code ☒ ☐ ☐ The restraint of pregnant arrestees is covered in
Section 3407. section 6030 of the department manual.
(5) Procedure and criteria for screening newly received 108.3 & 108.4
inmates for release per Penal Code sections 849(b)(2) and
☒ ☐ ☐
853.6, and any other such processes as the facility
administrator is empowered to use.
(6) Security and control including: Due to the limited number of inmates, counts
☒ ☐ ☐
occur during safety checks.
(A) physical counts of inmates, In practice, this occurs when each PSO comes
☒ ☐ ☐
on duty.
(B) searches of the facility and inmates, ☒ ☐ ☐ 106.2
(C) contraband control, and, ☒ ☐ ☐ 106.3
(D) key control. ☒ ☐ ☐ 104.1
Each facility administrator shall, at least annually, review, 100.6
evaluate, and make a record of security measures. The review
and evaluation shall include internal and external security ☒ ☐ ☐
measures of the facility including security measures specific
to prevention of sexual abuse and sexual harassment.
(7) Emergency procedures include:
(A) fire suppression preplan as required by section ☐ ☐ ☐
1032 of these regulations;
(B) escape, disturbances, and the taking of hostages; 113.4
☒ ☐ ☐ 103.7
113.4
(C) mass arrests; ☒ ☐ ☐ 113.4
(D) natural disasters; ☒ ☐ ☐ 113.7
(E) periodic testing of emergency equipment; and, ☒ ☐ ☐ 113.3
2 Procedures related to security and emergency response may be in a separate manual to ensure confidentiality by limiting general access.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(F) storage, issue, and use of weapons, ammunition, 104.3
☒ ☐ ☐
chemical agents, and related security devices.
(8) Suicide Prevention. ☒ ☐ ☐ 114
(9) Segregation of Inmates. ☒ ☐ ☐ 109
(10) Zero tolerance in the prevention of sexual abuse and New Regulations, please add to policy.
☐ ☐ ☐
sexual harassment.
(11) Policy and procedure to detect, prevent, and respond New Regulations, please add to policy.
to retaliation against any staff or inmate after reporting ☐ ☐ ☐
any abuse.
(e) The manual for Temporary Holding, Court Holding, New Regulations, please add to policy.
Type I, II, III, and IV facilities shall provide for, but not be
limited to, the following:
(1) multiple internal ways for inmates to privately report
sexual abuse and sexual harassment, retaliation by other ☐ ☐ ☐
inmates or staff for reporting sexual abuse and sexual
harassment, and staff neglect or violation of
responsibilities that may have contributed to such
incidents,
(2) a method for uninvolved inmates, family, New Regulations, please add to policy.
community members, and other interested third-parties
to report sexual abuse or sexual harassment. The ☐ ☐ ☐
method for reporting shall be publicly posted at the
facility.
1030 SUICIDE PREVENTION PROGRAM 114
Any inmate deemed a suicide risk will be
The facility shall have a comprehensive written suicide transported to Orange County Jail or to a
prevention program developed by the facility administrator, psychiatric assessment center immediately. At
in conjunction with the health authority and mental health the time of receiving, the booking officer will
director, to identify, monitor, and provide treatment to those alert to any symptoms that may indicate that an
inmates who present a suicide risk. The program shall inmate is a suicide risk. These symptoms
☒ ☐ ☐
include the following: include refusal to communicate, marked
depression, verbal threats to kill oneself, or
unusual behavior that may indicate that the
inmate may harm him or herself while in
custody.
Remainder of standards deleted.
1032 FIRE SUPPRESSION PREPLANNING 113
Pursuant to Penal Code Section 6031.1(b), the facility
administrator shall consult with the local fire department ☒ ☐ ☐
having jurisdiction over the facility, with the State Fire
Marshal, or both, in developing a plan for fire suppression
which shall include, but not be limited to:
(a) a fire suppression pre-plan developed with the local fire
department to be included as part of the policy and procedures
☒ ☐ ☐
manual (Title 15, California Code of Regulations Section
1029);
(b) regular fire prevention inspections by facility staff on a 113.3 C.
monthly basis with two-year retention of the inspection ☒ ☐ ☐
record;
(c) fire prevention inspections as required by Health and
Safety Code Section 13146.1(a) and (b) which requires ☐ ☐ ☐
inspections at least once every two years;
(d) an evacuation plan; and, ☒ ☐ ☐ 113.2 B.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
(e) a plan for the emergency housing of inmates in the case of 114.2 C. 3. The Orange County Jail would be
☒ ☐ ☐
fire. used in this event.
1044 INCIDENT REPORTS 102.2
Each facility administrator shall develop written policies and
procedures for the maintenance of written records and ☒ ☐ ☐
reporting of all incidents which result in physical harm, or
serious threat of physical harm, to an employee or inmate of
a detention facility or other person.
Such records shall include the names of the persons
involved, a description of the incident, the actions taken, and ☒ ☐ ☐
the date and time of the occurrence.
Such a written record shall be prepared by the staff assigned
to investigate the incident and submitted to the facility ☒ ☐ ☐
manager or his/her designee.
1046 DEATH IN CUSTODY 107.4
(a) Death in Custody Reviews for Adults and Minors.
The facility administrator, in cooperation with the health
administrator, shall develop written policy and procedures ☒ ☐ ☐
to ensure that there is an initial review of every in-custody
death within 30 days. The review team shall include the
facility administrator and/or the facility manager, the health
administrator, the responsible physician and other health
care and supervision staff who are relevant to the incident.
Deaths shall be reviewed to determine the appropriateness of
clinical care; whether changes to policies, procedures, or
☒ ☐ ☐
practices are warranted; and to identify issues that require
further study.
(b) Death of a Minor 324.7.5
In any case in which a minor dies while detained in a jail, ☒ ☐ ☐
lockup, or court holding facility:
(1) The administrator of the facility shall provide to the
Board a copy of the report submitted to the Attorney
General under Government Code Section 12525. A copy ☒ ☐ ☐
of the report shall be submitted within 10 calendar days
after the death.
(2) Upon receipt of a report of death of a minor from the
administrator, the Board may within 30 calendar days
inspect and evaluate the jail, lockup, or court holding
☒ ☐ ☐
facility pursuant to the provisions of this subchapter. Any
inquiry made by the Board shall be limited to the
standards and requirements set forth in these regulations.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
1050 CLASSIFICATION PLAN 109.2
(a) Each administrator of a temporary holding, Type I, II, or
III facility shall develop and implement a written
classification plan designed to properly assign inmates to
housing units and activities according to the categories of sex,
age, criminal sophistication, seriousness of crime charged,
physical or mental health needs, assaultive/non-assaultive
behavior, risk of being sexually abused, or sexually harassed
and other criteria which will provide for the safety of the
☒ ☐ ☐
inmates and staff. Such housing unit assignment shall be
accomplished to the extent possible within the limits of the
available number of distinct housing units or cells in a facility.
The written classification plan shall be based on objective
criteria and include receiving screening performed at the time
of intake by trained personnel, and a record of each inmate's
classification level, housing restrictions, and housing
assignments.
(Subsection b does not apply and has been deleted.)
(c) In deciding whether to assign an inmate to a housing area 109.4 A Segregation Screening Form is used.
for male or female inmates, and in making other housing and
programming assignments, the agency shall consider on a
case-by-case basis whether a placement would ensure the
☒ ☐ ☐
inmate's health and safety, and whether the placement would
present management or security problems. An inmate's own
views with respect to his or her own safety shall be given
serious consideration.
1051 COMMUNICABLE DISEASES 106.1 & 109.3 B.
The facility administrator, in cooperation with the
responsible physician, shall develop written policies and ☒ ☐ ☐
procedures specifying those symptoms that require
segregation of an inmate until a medical evaluation is
completed.
At the time of intake into the facility, an inquiry shall be 106.1
made of the person being booked as to whether or not he/she Reviewed medical screening forms (PD 117).
has or has had any communicable diseases, such as
tuberculosis or has observable symptoms of tuberculosis or ☒ ☐ ☐
any other communicable diseases, or other special medical
problem identified by the health authority. The response
shall be noted on the booking form and/or screening device.
1052 MENTALLY DISORDERED INMATES 109.3 C.
The facility administrator, in cooperation with the Mentally disordered individuals are
☐ ☐ ☒
responsible physician, shall develop written policies and immediately transported to an appropriate
procedures to identify and evaluate all mentally disordered facility and not housed at this facility.
inmates, and may include telehealth.
If an evaluation from medical or mental health staff is not
readily available, an inmate shall be considered mentally
disordered for the purpose of this section if he or she appears
to be a danger to himself/herself or others or if he/she
appears gravely disabled. ☐ ☐ ☒
An evaluation from medical or mental health staff shall be
secured within 24 hours of identification or at the next daily
sick call, whichever is earliest.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
Segregation may be used if necessary to protect the safety of
☒ ☐ ☐
the inmate or others.
1053 ADMINISTRATIVE SEGREGATION 109.1
Except in Type IV facilities, each facility administrator shall
develop written policies and procedures which provide for
the administrative segregation of inmates who are
determined to be prone to: promote activity or behavior that
is criminal in nature or disruptive to facility operations;
demonstrate influence over other inmates, including
influence to promote or direct action or behavior that is ☒ ☐ ☐
criminal in nature or disruptive to the safety and security of
other inmates or facility staff, as well as to the safe operation
of the facility; escape; assault, attempted assault, or
participation in a conspiracy to assault or harm other inmates
or facility staff; or likely to need protection from other
inmates, if such administrative segregation is determined to
be necessary in order to obtain the objective of protecting
the welfare of inmates and staff.
Administrative segregation shall consist of separate and Will be separated prior to being transferred to
secure housing but shall not involve any other deprivation of being transported to the county jail.
☒ ☐ ☐
privileges than is necessary to obtain the objective of
protecting the inmates and staff.
1055 USE OF SAFETY CELL No Safety Cell
The balance of the regulation has been deleted.
The safety cell described in Title 24, Part 2, Section
☐ ☐ ☒
1231.2.5, shall be used to hold only those inmates who
display behavior which results in the destruction of property
or reveals an intent to cause physical harm to self or others.
1056 USE OF SOBERING CELL 110.1
The sobering cell described in Title 24, Part 2, Section
1231.2.4, shall be used for the holding of inmates who are a ☒ ☐ ☐
threat to their own safety or the safety of others due to their
state of intoxication and pursuant to written policies and
procedures developed by the facility administrator.
Such inmates shall be removed from the sobering cell as they 106.4
are able to continue in the processing. Inmates who are so intoxicated that they cannot
answer medical questions, should be considered
☒ ☐ ☐
in need of medical care and supervision during
their sobering, and should therefore be
transferred to a hospital without delay.
In no case shall an inmate remain in a sobering cell over six
hours without an evaluation by a medical staff person or an
evaluation by custody staff, pursuant to written medical
☒ ☐ ☐
procedures in accordance with section 1213 of these
regulations, to determine whether the prisoner has an urgent
medical problem.
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TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS
At 12 hours from the time of placement, all inmates will 110.2
receive an evaluation by responsible health care staff. When an inmate has been housed for a period of
six (6) hours, the on-duty watch commander or
supervisor will be notified. The Watch
commander or supervisor will evaluate the
☒ ☐ ☐ sobriety or medical condition of the inmate. The
Orange County Fire Authority paramedics will
then be requested to medically evaluate the
inmate, or the inmate will be transported to a
local hospital for a medical evaluation and
treatment.
Intermittent direct visual observation of inmates held in the Intermittent direct visual observation of inmates
sobering cell shall be conducted no less than every half hour. held in the sobering cell shall be conducted no
Such observation shall be documented. less than every half-hour. Each inmate shall be
awakened at least every 30 minutes to assure that
☐ ☐ ☐ he or she is not in need of medical attention. This
check shall be documented in the Detention
Facility Log Book.
Will review on-site.
1057 DEVELOPMENTALLY DISABLED 109.5
INMATES Arrestees determined to be developmentally
disabled are not housed at this facility.
The facility administrator, in cooperation with the
☐ ☐ ☒
responsible physician, shall develop written policies and
procedures for the identification and evaluation, appropriate
classification and housing, protection, and
nondiscrimination of all developmentally disabled inmates.
The health authority or designee shall contact the regional
center on any inmate suspected or confirmed to be
developmentally disabled for the purposes of diagnosis ☐ ☐ ☒
and/or treatment within 24 hours of such determination,
excluding holidays and weekends.
1058 USE OF RESTRAINT DEVICES 106.21
Restraints for this purpose are not used. Inmates
The facility administrator, in cooperation with the requiring this type of restraint are immediately
responsible physician, shall develop written policies and ☐ ☐ ☒ transported to an appropriate facility.
procedures for the use of restraint devices and may delegate
authority to place an inmate in restraints to a responsible Remainder of standard is deleted.
health care staff.
1058.5 RESTRAINTS AND PREGNANT INMATES 162
Restraints for this purpose are not used. Inmates
The facility administrator, in cooperation with the requiring this type of restraint are immediately
responsible physician, shall develop written policies and ☐ ☐ ☒ transported to an appropriate facility.
procedures for the use of restraint devices on pregnant
inmates. In accordance with Penal Code 3407 the policy Remainder of standard is deleted.
shall include reference to the following:
1067 ACCESS TO TELEPHONE 102.11
Every inmate detained in the detention
The facility administrator shall develop written policies and facility, whether adult or juvenile, shall be
procedures which allow reasonable access to a telephone ☒ ☐ ☐ entitled to three (3) completed calls
beyond those telephone calls which are required by Section immediately upon being booked, and no later
than three (3) hours after arrest, as per Section
851.5 of the Penal Code.
851.5 of the Penal Code.
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1068 ACCESS TO COURTS AND COUNSEL 102.9
The facility is not equipped to provide
The facility administrator shall develop written policies and ☒ ☐ ☐ confidential, non-recorded access to Counsel.
procedures to ensure inmates have access to the court and to In order to accommodate such access to an
legal counsel. Such access shall consist of: attorney, arrestees will be transferred to another
jail facility such as Orange County Jail.
(a) unlimited mail as provided in Section 1063 of these
☐ ☐ ☒
regulations, and,
(b) confidential consultation with attorneys. ☐ ☐ ☒
1080 RULES AND DISCIPLINARY PENALTIES 102.22
Discipline is not administered at this facility.
Wherever discipline is administered, each facility ☐ ☐ ☒
administrator shall establish written rules and disciplinary
penalties to guide inmate conduct.
DETENTION OF MINORS
YES NO COMMENTS
Are minors held in this facility? Minors are not securely detained within the secure
perimeter of the jail.
The Juvenile Justice and Delinquency Prevention Act
(JJDPA) establishes the following federal standards on the
detention of minors:
(1) Deinstitutionalization of Status Offenders ☐ ☒
(2) Separation
(3) Jail Removal (6-hour limit)
The JJDPA requires an annual inspection on the federal
standards for facilities that hold minors in secure detention.
Are minors held in the jail cells?
Penal Code Section 6030 and 6031.4 require the biennial
inspection of local detention facilities that hold minors in
secure detention in the jail. Title 15, Article 9 establishes
the minimum standards of how facilities hold minors in ☐ ☒
temporary custody in the jail.
Facilities that do not hold minors in the jail are not subject
to Title 15, Article 9 biennial inspections.
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