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When a person is in crisis and considering harming themselves or others, family members and law enforcement are often the first people to see the warning signs. Red Flag laws empower those who recognize these warning signs to intervene in order to prevent people in crisis from accessing firearms. These laws can help de-escalate emergency situations and are a proven way to intervene before a firearm suicide or mass shooting takes more American lives. States around the country are turning to Red Flag laws as a common-sense way to help reduce gun violence.
Red Flag laws can save lives by creating a way for family members and law enforcement to act before warning signs escalate into tragedies. These laws permit immediate family members and law enforcement to petition a court for an order, commonly known as an extreme risk protection order (ERPO),These orders are sometimes also known as gun violence restraining orders (GVROs). to remove guns from dangerous situations. If a court finds that a person poses a serious risk of injuring themselves or others with a firearm, that person is temporarily prohibited from purchasing and possessing guns and is required to turn over their guns while the order is in effect.
Fourteen states and DC have enacted Red Flag laws.Cal. Penal Code § 18125; Cal. Penal Code § 18150; Cal. Penal Code § 18175; Conn. Gen. Stat. § 29-38c; 10 Del. C. 7701, et seq.; 2018 D.C. Act 22-629; Fla. Stat. § 790.401; 430 ILCS 67/1, et seq.; Ind. Code § 35-47-14-1; Ind. Code § 35-47-14-2; Ind. Code § 35-47-14-5; Ind. Code § 35-47-14-6; Ind. Code § 35-47-14-8; Md Public Safety Code 5-601, et seq; Mass. Gen. Laws ch. 140, § 121; Mass. Gen. Laws ch. 140, § 129B(C); Mass. Gen. Laws ch. 140, § 131(C); Mass. Gen. Laws ch. 140, §131R-Z; 2019 NY SB 2451; 2018 NJ A 1217; ORS 166.525, et seq.; 13 VSA 4051, et seq.; RI Gen Laws 8-8.3-1, et seq.; Wash. Rev. Code § 7.94.030; Wash. Rev. Code § 7.94.040; Wash. Rev. Code § 7.94.050; Wash. Rev. Code § 7.94.080. California, Connecticut, Delaware, DC, Florida, Illinois, Indiana, Maryland, Massachusetts, New Jersey, New York, Oregon, Rhode Island, Vermont, and Washington.
Under current federal law, a person is barred from having guns only if they fall into one of several categories of prohibited persons – such as those who have been convicted of certain crimes, adjudicated as mentally ill or involuntarily committed to a psychiatric hospital, or who are subject to a final domestic violence restraining order.18 U.S.C. § 922(d), (g). A person who displays warning signs that they’re considering suicide or other acts of violence, but who does not fall into any of the above categories or is otherwise not prohibited under current law, would still be able to legally buy and possess guns. Red Flag laws help to fill this gap and allow people in crisis the chance to seek the help they need.
Red Flag laws have been shown to reduce the risk of firearm suicide by temporarily removing guns from dangerous situations.
Firearm suicide is a significant public health crisis in the US.For more information on firearm suicide, see: https://everytownresearch.org/reports/disrupting-access/. Every year, over 22,000 Americans die by firearm suicide, including over 1,000 children and teens.Centers for Disease Control and Prevention. National Center for Injury Prevention and Control, Web-based Injury Statistics Query and Reporting System (WISQARS) Fatal Injury Reports. A yearly average was developed using five years of most recent available data: 2013 to 2017. Children and teens are defined as ages 0 to 19. Nearly two-thirds of all gun deaths in the US are suicides, an average of 61 deaths a day.Ibid. Firearm suicide to total suicide ratio and daily average developed using five years of most recent available data: 2013 to 2017.
A meta-analysis of 14 scientific studies revealed that having access to a firearm triples one’s risk of death by suicide. This elevated risk applies not only to the gun owner but also to everyone in the household.Anglemyer A, Horvath T, Rutherford G. The accessibility of firearms and risk for suicide and homicide victimization among household members: a systematic review and meta-analysis. Annals of Internal Medicine. 2014; 160: 101–110.
Among commonly used methods of self-harm, firearms are by far the most lethal, with a fatality rate of approximately 85 percent.Miller M, Azrael D, Barber C. Suicide mortality in the United States: the importance of attending to method in understanding population-level disparities in the burden of suicide. Annual Review of Public Health. 2012; 33: 393-408. Conversely, less than 5 percent of people who attempt suicide using other methods will die,Ibid. and the vast majority of all those who survive do not go on to die by suicide.Owens D, Horrocks J, House A. Fatal and non-fatal repetition of self-harm: systematic review. British Journal of Psychiatry. 2002; 181: 193-199. While firearms are used in less than 6 percent of suicide attempts, over half of suicide deaths are with firearms.Miller M, Azrael D, Barber C. Suicide mortality in the United States: the importance of attending to method in understanding population-level disparities in the burden of suicide. Annual Review of Public Health. 2012; 33: 393-408.
Following Connecticut’s increased enforcement of its Red Flag law,Conn. Gen. Stat. § 29-38c. one study found the law to be associated with a 14 percent reduction in the state’s firearm suicide rate.Kivisto AJ, Phalen PL. Effects of risk-based firearm seizure laws in Connecticut and Indiana on suicide rates, 1981-2015. Psychiatric Services. 2018; 69(8): 855-862. Another study in Connecticut found that one suicide was averted for approximately every 11 gun removals carried out under the law.Swanson JW, Norko M, Lin H, et al. Implementation and effectiveness of Connecticut’s risk-based gun removal law: Does it prevent suicides? Law and Contemporary Problems. 2017; 80: 179-208.
In Indiana, in the 10 years after the state passed its Red Flag law in 2005,Ind. Code § 35-47-14-1, et seq. the state’s firearm suicide rate decreased by 7.5 percent.Kivisto AJ, Phalen PL. Effects of risk-based firearm seizure laws in Connecticut and Indiana on suicide rates, 1981-2015. Psychiatric Services. 2018; 69(8): 855-862.
Perpetrators of mass shootings and school shootings often display warning signs before committing violent acts. Interventions in states with Red Flag laws have already prevented these potential strategies.
An Everytown original analysis of mass shootings from 2009 to 2017 revealed that in 51 percent of incidents the shooter exhibited warning signs that they posed a risk to themselves or others before the shooting.Everytown for Gun Safety. Mass Shootings in the United States: 2009-2017. https://every.tw/1XVAmcc. December 2018. These warning signs are even more apparent among perpetrators of school violence.Everytown for Gun Safety. Keeping Our Schools Safe: A Plan to Stop Mass Shootings and End Gun Violence in American Schools. everytownresearch.org/reports/keeping-schools-safe. February 2019. The United States Secret Service and the United States Department of Education studied targeted school violence incidents and found behavioral warning signs that caused others to be concerned in 93 percent of cases. They also found that in 81 percent of incidents, other people, most often the shooter’s peers, had some type of knowledge about the shooter’s plans.United States Secret Service and United States Department of Education. Prior knowledge of potential school-based violence: information students learn may prevent a targeted attack. https://bit.ly/2MPrOoL. May 2008.
For example, students and teachers reported that the mass shooter in the February 2018 Parkland, FL, tragedy displayed threatening behavior. His mother had contacted law enforcement on multiple occasions regarding his behavior, and he was known to possess firearms.Marjory Stoneman Douglas High School Public Safety Commission. Initial report submitted to the Governor, Speaker of the House of Representatives and Senate President. http://www.fdle.state.fl.us/MSDHS/CommissionReport.pdf. January 2, 2019. In response to that tragedy, Florida passed its own Red Flag law.Fla. Stat. § 790.401.
Likewise, the shooter in the May 2014 Isla Vista, CA shooting displayed numerous warning signs, including homicidal and suicidal threats. His parents had alerted law enforcement, but he did not meet the criteria for emergency mental health commitment.Pickert K. Mental-health lessons emerge from Isla Vista slayings. Time. May 27, 2014. https://goo.gl/UL5jLX. As a result, he kept his guns, which he used in the killing spree three weeks later. In response to that tragic shooting, California passed its own Red Flag law.Cal. Penal Code § 18125; Cal. Penal Code § 18150; Cal. Penal Code § 18175.
In 51% of mass shootings, the shooter exhibited dangerous warning signs before the shooting.
In Maryland, a 2018 Red Flag law has been invoked in at least four cases involving “significant threats” against schools, according to the leaders of the Maryland Sheriffs’ Association.Broadwater L. Sheriff: Maryland's 'red flag' law prompted gun seizures after four 'significant threats' against schools. The Baltimore Sun. January 15, 2019. https://bit.ly/2Gdf6Qi.
In Florida, a Red Flag law passed in 2018 has been invoked in multiple cases of potential school violence, including in the case of a student who was accused of stalking an ex-girlfriend and threatening to kill himself,Kennedy E. Tate student's AR-15, father's 54 guns removed under new red flag law. Pensacola News Journal. July 9, 2018. https://bit.ly/2UHmaba. and in another in which a potential school shooter said killing people would be “addicting.”Lipscomb J. Florida's post-Parkland "Red Flag" law has taken guns from dozens of dangerous people. Miami New Times. August 7, 2018. https://bit.ly/2ORW56U.
In Seattle, a coalition of city and county officialsThe coalition included the Seattle City Attorney’s Office, Seattle Police Department, King County Prosecuting Attorney's Office, and King County Sheriff’s Office. launched a regional firearms enforcement unit that supports, tracks, and enforces all firearm surrender orders issued within the county. In the unit’s first year, it recovered 200 firearms as a result of 48 ERPOs. According to the City Attorney’s Office, the use of ERPOs has been effective in temporarily preventing access to firearms by students who threatened violence against themselves, the school, and other students.12-month period from January 2018 to December 2018. Acquired via correspondence with Christopher Anderson, director of the Domestic Violence Unit of the Seattle City Attorney’s Office.
Red Flag laws have robust due-process protections. Those who request an ERPO must present evidence to a judge that demonstrates a person poses a significant danger of injuring themselves or others with a firearm. A judge can issue an emergency ERPO before a full hearing is held, but only upon clear evidence of immediate danger; this order typically lasts only 14 to 21 days. The final ERPO, generally lasting up to one year, can be issued only following a hearing of which the person is given notice and during which they have an opportunity to be heard and respond to evidence. Many of these laws also include strong provisions that deter people from misusing the ERPO process.
The emerging body of research concurs that Red Flag laws work to prevent firearm suicide, and they can also help prevent would-be mass shooters from committing violence. An overwhelming majority of Americans on both sides of the aisle support Red Flag laws. In a recent survey, 89 percent of likely voters favored Congress passing a Red Flag law.
Click here to download the appendix of stories that illustrate the importance of Red Flag legislation in removing firearms from dangerous situations.


Page 427, line 52, strike "$109,826,612" and insert "$109,841,612".
Page 430, line 22, strike the second "$85,000" and insert "$100,000".
Authority: Title 9.1, Chapter 1, Code of Virginia.
A.1. This appropriation includes an estimated $4,800,000 the first year and an estimated $4,800,000 the second year from federal funds pursuant to the Omnibus Crime Control Act of 1968, as amended. Of these amounts, nine ten percent is available for administration, and the remainder is available for grants to state agencies and local units of government. The remaining federal funds are to be passed through as grants to localities, with a required 25 percent local match. Also included in this appropriation is $452,128 the first year and $452,128 the second year from the general fund for the required matching funds for state agencies.
2. The Department of Criminal Justice Services shall provide a summary report on federal anti-crime and related grants which will require state general funds for matching purposes during FY 2013 and beyond. The report shall include a list of each grant and grantee, the purpose of the grant, and the amount of federal and state funds recommended, organized by topical area and fiscal period. The report shall indicate whether each grant represents a new program or a renewal of an existing grant. Copies of this report shall be provided to the Chairmen of the Senate Finance and House Appropriations Committees and the Director, Department of Planning and Budget by January 1 of each year.
1.a. Regional training academies for criminal justice training, $1,001,074 the first year and $1,001,074 the second year from the general fund and an estimated $1,649,315 the first year and an estimated $1,649,315 the second year from nongeneral funds. The Criminal Justice Services Board shall adopt such rules as may reasonably be required for the distribution of funds and for the establishment, operation and service boundaries of state-supported regional criminal justice training academies.
b. The Board of Criminal Justice Services, consistent with § 9.1-102, Code of Virginia, and § 6VAC-20-20-61 of the Administrative Code, shall not approve or provide funding for the establishment of any new criminal justice training academy from July 1, 2018, through June 30, 2020.
c. Notwithstanding subsection B.1.b. of this item, the Board of Criminal Justice Services may approve a new regional criminal justice academy serving the Counties of Clarke, Frederick, and Warren; the City of Winchester; the Towns of Berryville, Front Royal, Middletown, Stephens City and Strasburg; the Northwestern Adult Detention Center; and, the Frederick County Emergency Communications Center, to be established and operated consistent with a written agreement, provided to the Board, between the local governing bodies, chief executive officers, and chief law enforcement officers of the aforementioned localities, and the Rappahannock Regional Criminal Justice Academy. The new academy shall be eligible to receive state funding in a manner consistent with the currently existing regional criminal justice training academies. However, no current existing regional criminal justice training academy other than the Rappahannock Regional Criminal Justice Academy will receive less funding as a result of the creation of the new regional academy.
2. Virginia Crime Victim-Witness Fund, $5,692,738 the first year and $5,692,738 the second year from dedicated special revenue, and $943,700 the first year and $943,700 the second year from the general fund. The Department of Criminal Justice Services shall provide a report on the current and projected status of federal, state and local funding for victim-witness programs supported by the Fund. Copies of the report shall be provided annually to the Secretary of Public Safety and Homeland Security, the Department of Planning and Budget, and the Chairmen of the Senate Finance and House Appropriations Committees by October 16 of each year.
3.a. Court Appointed Special Advocate (CASA) programs, $1,615,000 the first year and $1,615,000 the second year from the general fund.
b. In the event that the federal government reduces or removes support for the CASA programs, the Governor is authorized to provide offsetting funding for those impacted programs out of the unappropriated balances in this Act.
4. Domestic Violence Fund, $3,000,000 the first year and $3,000,000 the second year from the dedicated special revenue fund to provide grants to local programs and prosecutors that provide services to victims of domestic violence.
5. Pre and Post-Incarceration Services (PAPIS), $2,286,144 the first year and $2,286,144 the second year from general fund to support pre and post incarceration professional services and guidance that increase the opportunity for, and the likelihood of, successful reintegration into the community by adult offenders upon release from prisons and jails.
6. To the Department of Behavioral Health and Developmental Services for the following activities and programs: (i) a partnership program between a local community services board and the district probation and parole office for a jail diversion program; (ii) forensic discharge planners; (iii) advanced training on veterans' issues to local crisis intervention teams; and (iv) cross systems mapping targeting juvenile justice and behavioral health.
7. To the Department of Corrections for the following activities and programs: (i) community residential re-entry programs for female offenders; (ii) establishment of a pilot day reporting center; and (iii) establishment of a pilot program whereby non-violent state offenders would be housed in a local or regional jail, rather than a prison or other state correctional facility, with rehabilitative services provided by the jail.
8. To Drive to Work, $75,000 the first year and $75,000 the second year from the general fund and $75,000 the first year and $75,000 the second year from such federal funds as may be available to provide assistance to low income and previously incarcerated persons to restore their driving privileges so they can drive to work and keep a job.
9. For model addiction recovery programs administered in local or regional jails, $153,600 the first year and $153,600 the second year from the general fund. The Department of Criminal Justice Services, consistent with the provisions of Chapter 758, 2017 Acts of Assembly, shall award grants not to exceed $38,400 to four pilot programs selected in consultation with the Department of Behavioral Health and Developmental Services.
C.1. Out of this appropriation, $25,390,378 the first year and $25,390,378 the second year from the general fund is authorized to make discretionary grants and to provide technical assistance to cities, counties or combinations thereof to develop, implement, operate and evaluate programs, services and facilities established pursuant to the Comprehensive Community Corrections Act for Local-Responsible Offenders (§§ 9.1-173 through 9.1-183 Code of Virginia) and the Pretrial Services Act (§§ 19.2-152.2 through 19.2-152.7, Code of Virginia). Out of these amounts, the Director, Department of Criminal Justice Services, is authorized to expend no more than five percent per year for state administration of these programs.
2. The Department of Criminal Justice Services, in conjunction with the Office of the Executive Secretary of the Supreme Court and the Virginia Criminal Sentencing Commission, shall conduct information and training sessions for judges and other judicial officials on the programs, services and facilities available through the Pretrial Services Act and the Comprehensive Community Corrections Act for Local-Responsible Offenders.
D.1. Out of this appropriation, $225,000 the first year and $225,000 the second year from the general fund is provided for Comprehensive Community Corrections and Pretrial Services Programs for localities that belong to the Central Virginia Regional Jail Authority. These amounts are seventy-five percent of the costs projected in the community-based corrections plan submitted by the Authority. The localities shall provide the remaining twenty-five percent as a condition of receiving these funds.
2. Out of this appropriation, $600,000 the first year and $600,000 the second year from the general fund is provided for Comprehensive Community Corrections and Pretrial Services Programs for localities that belong to the Southwest Virginia Regional Jail Authority. These amounts are seventy-five percent of the costs projected in the community-based corrections plan submitted by the Authority. The localities shall provide the remaining twenty-five percent as a condition of receiving these funds.
E. In the event the federal government should make available additional funds pursuant to the Violence Against Women Act, the department shall set aside 33 percent of such funds for competitive grants to programs providing services to domestic violence and sexual assault victims.
F.1. Out of this appropriation, $3,000,000 the first year and $1,700,000 the second year from the general fund and $1,710,000 the first year and $1,710,000 the second year from such federal funds as are available shall be deposited to the School Resource Officer Incentive Grants Fund established pursuant to § 9.1-110, Code of Virginia.
2.a. The Director, Department of Criminal Justice Services, is authorized to expend $410,877 the first year and $410,877 the second year from the School Resource Officer Incentive Grants Fund to operate the Virginia Center for School Safety, pursuant to § 9.1-110, Code of Virginia.
b. The Center for School Safety shall provide a grant of $85,000 in the first year and $85,000 in the second year to the York County-Poquoson Sheriff's Office for the statewide administration of the Drug Abuse Resistance Education (DARE) program. The Center for School Safety shall conduct an evaluation of the effectiveness of the program, along with an assessment of other evidence-based drug education programs, and shall provide a report on its findings to the Secretary of Public Safety and Homeland Security, the Director of the Department of Planning and Budget, and the Chairmen of the House Appropriations and Senate Finance Committees by January 1, 2018.
3. Subject to the development of criteria for the distribution of grants from the fund, including procedures for the application process and the determination of the actual amount of any grant issued by the department, the department shall award grants to either local law-enforcement agencies, where such local law-enforcement agencies and local school boards have established a collaborative agreement for the employment of school resource officers, as such positions are defined in § 9.1-101, Code of Virginia, for the employment of school resource officers, or to local school divisions for the employment of school security officers, as such positions are defined in § 9.1-101, Code of Virginia, for the employment of school security officers in any public school. The application process shall provide for the selection of either school resource officers, school security officers, or both by localities. The department shall give priority to localities requesting school resource officers, school security officers, or both where no such personnel are currently in place. Localities shall match these funds based on the composite index of local ability-to-pay.
4. Included in this appropriation is $202,300 the first year and $202,300 the second year from the general fund for the implementation of a model critical incident response training program for public school personnel and others providing services to public schools, and the maintenance of a model policy for the establishment of threat assessment teams for each public school, including procedures for the assessment of and intervention with students whose behavior poses a threat to the safety of public school staff or other students.
G. Included in the amounts appropriated in this Item is $2,500,000 the first year and $2,500,000 the second year from the general fund for grants to local sexual assault crisis centers (SACCs) and domestic violence programs to provide core and comprehensive services to victims of sexual and domestic violence, including ensuring such services are available and accessible to victims of sexual assault and dating violence committed against college students on- and off-campus.
H.1. Out of the amounts appropriated for this Item, $2,658,420 the first year and $2,658,420 the second year from nongeneral funds is provided, to be distributed as follows: for the Southern Virginia Internet Crimes Against Children Task Force, $1,450,000 the first year and $1,450,000 the second year; and, for the creation of a grant program to law enforcement agencies for the prevention of internet crimes against children, $1,208,420 the first year and $1,208,420 the second year.
2. The Southern Virginia and Northern Virginia Internet Crimes Against Children Task Forces shall each provide an annual report, in a format specified by the Department of Criminal Justice Services, on their actual expenditures and performance results. Copies of these reports shall be provided to the Secretary of Public Safety and Homeland Security, the Chairmen of the Senate Finance and House Appropriations Committees, and Director, Department of Planning and Budget prior to the distribution of these funds each year.
3. Subject to compliance with the reports and distribution thereof as required in paragraph 2 above, the Governor shall allocate all additional funding, not to exceed actual collections, for the prevention of Internet Crimes Against Children, pursuant to § 17.1-275.12, Code of Virginia.
I. Out of the amounts appropriated for this item, $50,000 the first year and $50,000 the second year from the general fund is provided for training to local law enforcement to aid in their identifying and interacting with individuals suffering from Alzheimer's and/or dementia.
J. Included in the appropriation for this Item is $2,500,000 the first year and $2,500,000 the second year from the general fund to continue the pilot programs authorized in Item 398, Chapter 836, 2017 Acts of Assembly. Based on its assessment of the progress of the programs, the agency may expand the number of pilot sites supported with this appropriation.
2. The Department of Criminal Justice Services, in consultation with the Department of Behavioral Health and Developmental Services, shall evaluate the implementation and effectiveness of the pilot programs and submit reports to the Governor; the Secretaries of Health and Human Resources and Public Safety and Homeland Security, and the Chairmen of the House Appropriations Committee and the Senate Finance Committee by October 15, 2018 and by June 30, 2020.
K. Included in the appropriations for this Item is $100,000 each year from the general fund for the Department of Criminal Justice Services to make competitive grants to nonprofit organizations to support services for law enforcement, including post critical incident seminars and peer-supported critical incident stress management programs to promote officer safety and wellness, under guidelines to be established by the Department. The Department shall evaluate the effectiveness of the program and report on its findings to the Secretary of Public Safety and Homeland Security, the Director of the Department of Planning and Budget, and the Chairmen of the House Appropriations and Senate Finance Committees by July 1, 2020.


On October 6, 2009, two individuals who had their DNA collected pursuant to a California statute filed this class action lawsuit in the U.S. District Court for the Northern District of California under 42 U.S.C. § 1983. Plaintiffs challenged a provision of California law which mandates the DNA collection of any individual arrested for or charged with a felony. The plaintiffs, represented by public interest counsel, sought declaratory and injunctive relief, and claimed that the practice violates substantive and procedural Due Process, as well as the right to be free from unreasonable searches and seizures. Specifically, the plaintiffs claimed that the practice infringes on rights guaranteed by the Fourth and Fourteenth Amendments of the U.S. Constitution because it mandates the DNA collection of all persons arrested for a felony--without requiring a warrant or that the individual actually be charged with or convicted of a felony.
In 2004, California passed Proposition 69, which expanded the scope of the state's mandatory DNA collection laws, Cal. Penal Code. §§ 295 et seq. Prior to the enactment of Proposition 69, California law provided that only persons convicted of certain felonies were subject to the mandatory DNA testing program. Under the revised statute, which took effect on January 1, 2009, any individual arrested for a felony must provide their DNA for analysis and storage in a national database accessible by federal, state and local law enforcement agencies. Proposition 69 also eliminated language in the statute which provided for the automatic expungement of a person's DNA samples and database entries if that individual's conviction was reversed.
On December 1, 2009, the plaintiffs filed an amended complaint that added two more plaintiffs, bringing the total plaintiffs to four. None of the plaintiffs were convicted of charges related to the arrests which led to the collection of their DNA; three never had charges filed, and one had his case dismissed.
On December 23, 2009, the District Court (Judge Charles R. Breyer) denied the plaintiffs' motion for a preliminary injunction. Haskell v. Brown, 677 F. Supp. 2d 1187, 1190 (N.D. Cal. 2009), aff'd sub nom. Haskell v. Harris, 669 F.3d 1049 (9th Cir. 2012). The court found that although the plaintiffs had established that arrestees have greater privacy interests than convicted felons, they had failed to show that this interest outweighs the government's compelling interest in using arrestees' DNA to solve past crimes. The court reasoned that as a result, the plaintiffs had failed to establish a likelihood of success on the merits or that the balance of equities tipped in their favor.
On January 29, 2010--shortly after denying the plaintiffs' motion for a preliminary injunction--the District Court granted the motion for class certification. Minute Entry Granting Mot. for Class Certification. In doing so, the court adopted plaintiffs' proposed class description. This class description is "all persons who have been, are, or will be, compelled to submit to the search and seizure of their body tissue and DNA pursuant to California Penal Code § 296(a)(2)(C) solely because they have been arrested for, or charged with, a felony offense." Proposed Order Granting Mot. for Class Certification.
The plaintiffs appealed the District Court's denial of the preliminary injunction, but on February 23, 2012, a divided three-judge panel of the Ninth Circuit (Judge Milan D. Smith, Jr. writing for the majority) affirmed the District Court's denial of plaintiffs' motion for a preliminary injunction. Haskell v. Harris, 669 F.3d 1049, 1051 (9th Cir. 2012). The majority applied a "totality of the circumstances" test, balancing arrestees' privacy interests against the government's need for their DNA samples. The court concluded that "the Government's compelling interests far outweigh arrestees' privacy concerns," and affirmed on that basis. Id.
Judge William A. Fletcher filed a dissenting opinion, in which he analogized the collection of arrestees' DNA to taking their fingerprints. Judge Fletcher argued that because in the absence of a warrant or reasonable suspicion an arrestee's fingerprints may only be taken for identification purposes--and not solely for an investigative purpose--the same logic applied to the collection of an arrestee's DNA. Id. at 1066. Judge Fletcher felt that this made Proposition 69 unconstitutional, rendering the majority's "totality of the circumstances" test irrelevant. Id. at 1080. However, he also noted that if he were to apply that test, he would find the "strength of plaintiffs' privacy interests much stronger." Id.
After the Ninth Circuit panel affirmed the District Court's decision, the plaintiffs petitioned the Ninth Circuit to rehear the appeal en banc. On July 25, 2012, the Ninth Circuit granted rehearing en banc. Haskell v. Harris, 686 F.3d 1121 (9th Cir. 2012). After oral argument on the rehearing, the Ninth Circuit issued an order stating that it would not rule on the appeal until the U.S. Supreme Court decided a related issue in Maryland v. King. In that case, Maryland's DNA collection laws were being challenged.
In June 2013, the Supreme Court, by a vote of 5-4, held that Maryland's DNA collection laws were constitutional. The Ninth Circuit subsequently ordered both sides to submit supplemental briefs and scheduled additional oral argument for December 2013. Haskell v. Harris, 727 F.3d 916 (9th Cir. 2013).
On March 20, 2014, the en banc court affirmed the district court's denial of a preliminary injunction. In a per curiam opinion, the appeals court held that after Maryland v. King, California's DNA collection scheme was constitutional. Further, the appeals court declined the plaintiffs' request to enter a preliminary injunction applicable to only a smaller class consisting of individuals arrested for certain felonies not covered by King. Haskell v. Harris, 745 F.3d 1269 (9th Cir. 2014).
crime. Proposed subclass B would include only persons arrested for non-serious, non-violent felonies who were not actually charged.
On that same date, the state filed a motion for judgment on the pleadings, arguing that because California's DNA collection law was materially indistinguishable from the Maryland law upheld in King, neither the plaintiffs nor any possible class fell outside the wide parameters of King and the case was therefore over.
On December 3, 2014, however, the district court stayed the case pending final resolution of a similar challenge to California's DNA Act in state court. In April 2018, the California Supreme Court upheld the state's DNA Act under both federal and California law as to the felony arrestee in that case. People v. Buza, 4 Cal. 5th 658 (2018).
automatically expunged in California. The court held that none of these three differences were constitutionally significant.
Plaintiff Description Plaintiffs are four individuals who had their DNA collected pursuant to a California statute mandating DNA collection from anyone arrested for a felony.


Until 1997, no special estate tax rules existed for family-owned businesses. Limited relief was available under §2010, (unified credit), the special use valuation of qualified real estate under IRC §2032A, and the deferral of estate taxes under §6166. In 1997, Congress granted further relief by enacting §2057, which provides for a “qualified family-owned business deduction” (QFOB). Requiring an election by the estate, the deduction augments benefits provided by §§ 2010, 2032A and 6166.
§2057 establishes a maximum QFOB deduction of $675,000. The statute is also closely coordinated with the unified credit (now applicable exclusion amount or AEA): The combined QFOB deduction and AEA limit is $1.3 million. Therefore, if a decedent dies in the year 2006 with a gross estate worth $2 million entirely comprised of a family-owned business, the QFOB deduction would be $675,000. However, since the maximum QFOB and AEA is $1.3 million, the AEA would be limited to $625,000 (despite an AEA of $1 million in 2006).
If a family-owned business is worth less than $675,000, then the QFOB deduction is that amount. However, a preadjusted AEA of $625,000 is adjusted upward by the difference between $675,000 and the value of the family owned business, with one proviso: The “adjusted” AEA cannot exceed the AEA as provided by §2010 for the year of the decedent’s death. To illustrate, assume the decedent dies in 2006 with a family-owned business worth $500,000. The QFOB deduction would in that case be $500,000. The difference between $675,000 and $500,000 is $175,000. The “adjusted” AEA would be $625,000 plus $175,000, which is $800,000. Since $800,000 does not exceed $1,000,000, i.e., the AEA for 2006, the full adjustment is taken. However, if the same decedent died in the year 2000, then the “adjusted” AEA, still $800,000, would exceed the AEA for the year 2000, which is $675,000. This is where the proviso applies: The “adjusted” AEA would be limited to $675,000.
¶ First, the adjusted value of the decedent’s (a U.S. citizen or resident) QFOB interests must equal at least 50% of the decedent’s adjusted gross estate. In calculating this fraction, the numerator is determined by aggregating (i) the adjusted value of all family-owned business interests passing to qualified heirs and (ii) the total adjusted taxable gifts of QFOB interests made by the decedent to family members; and then by subtracting (i) all indebtedness of the decedent’s estate, except qualified personal residence indebtedness or indebtedness incurred for medical or educational expenses.
The denominator of the fraction is the decedent’s gross estate, decreased by (i) §2053(a)(3) claims against the estate and §2053(a)(4) indebtedness of the estate; and increased by: (i) lifetime transfers to family members of continuously held QFOB interests; (ii) transfers by the decedent to his spouse within 10 years of death; and (iii) any other transfers by decedent within 3 years of his death (except annual exclusion transfers to family members).
Maximizing the value of the fraction entails (i) increasing the size of the active QFOB; (ii) eliminating QFOB gifts to nonfamily members and to the spouse; (iii) ensuring that QFOB gifts to children are retained; (iv) eliminating taxable gifts (other than §2503(b) gifts) within 3 years of death; (v) decreasing value of gifts to the spouse within 10 years of death; (vi) decreasing the value of the estate’s non-QFOB assets, cash, marketable securities, passive assets; and (vii) reducing general indebtedness but increasing indebtedness for a qualified residence, for medical or educational expenses, or to acquire a business.
¶ Second, during 8-year period ending on the decedent’s death, there must have been periods aggregating 5 years or more during which the decedent (or family members) owned and materially participated in the QFOB. Material participation is defined by reference to §1402(a), i.e., net earnings from self-employment. Since the decedent or family member who materially participates must pay self-employment taxes, this may occasion the relinquishment of social security benefits.
§2057 imposes a recapture penalty in the form of an additional estate tax (equal to the 100% of estate tax saved) if a “recapture event” occurs within 10 years following the decedent’s death. The proscribed events include (i) lack of material participation by a family member of the decedent and (ii) disposal of the QFOB by a family member to a person other than a family member. The recapture percentage is 100% in years 1 through 6, 80% in year seven, 60% in year eight, etc. Thus, the QFOB election is only sensible where it is probable that the decedent’s family will actively manage and own the family business for at least 10 years after the decedent’s death. Note further that the qualified heir is personally liable for the payment of recapture tax unless a bond has been furnished, and §6324B imposes a special lien for estate taxes on the QFOB.
Under the regulations, material participation must occur pursuant to a formal arrangement, although it need not be memorialized. The owner or family member must regularly participate in a substantial number of management decisions and must have a financial interest in the business (whether ownership is direct or indirect through an entity). The business owner should also (i) pay self-employment taxes on income; (ii) hold an office commensurate with material involvement; (iii) be at risk with respect to the investment; and (iv) execute an agreement requiring the decedent or family member to materially participate.
To maximize the likelihood of satisfying the Business Control test, the that a family business will be a QFOB, the owner should (1) avoid ownership with unrelated parties; (2) ensure that the business is active; and (3) distribute excess cash from the entity to avoid the excess cash rule.
The QFOB deduction may have a significant impact on marital deduction planning, and on particular formulas. For example, assume the decedent dies in 2000 with an estate valued at $2 million, all of which qualifies for the QFOB. If the applicable exclusion amount of $675,000, as well as the QFOB deduction of $625,000 are both claimed, the taxable estate will be reduced to $700,000. If the Will called for the marital trust to be allocated the minimum amount necessary required to eliminate the estate tax, then the marital trust would be allocated $700,000.
After death, QFOB interests receive a basis step-up to FMV, despite the fact that QFOB property is excluded from the gross estate. Another odd twist in post-mortem planning: In order to pass the 50% liquidity test, the estate may claim less of a valuation discount for the QFOB than does the IRS.


text:
[303 U.S. 59, 60] Mr. M. G. Adams, of Beaumont, Tex., for petitioner.
Mr. Oliver J. Todd, of Beaumont, Tex., for respondents.
The question for decision is whether the action, in this case, of the Texas state courts, in dismissing a suit founded upon a judgment of the Supreme Court of California, denied to the judgment the faith and credit which the Constitution, article 4, 1, commands.
Petitioner, as assignee of a California judgment against the Beaumont Export & Import Company, a Texas corporation, brought the present suit in the Texas state district court against respondents, directors of the corporation acting as its trustees in dissolution, and against its stockholders as transferees of corporate assets, to collect the judgment. His petition sets out in detail the circumstances attending the rendition of the California judg- [303 U.S. 59, 61] ment and incorporates by reference a duly attested copy of the judgment roll.
It appears that the corporation brought suit in the superior court of California, a court of general jurisdiction, against Montes, petitioner's predecessor in interest, to recover a money judgment for goods sold and delivered. Thereupon Montes, following what is alleged to be the California practice, with leave of the court brought a cross-action against the corporation, by service of a cross-complaint upon the corporation's attorney of record in the pending suit, to recover for the conversion of chattels. Judgment in the cross-action, taken by default, was followed by dismissal of the corporation's suit and is the judgment which is the subject of the present suit. A motion to open the default and to be allowed to defend, made later on behalf of the corporation, was contested and was denied by the court, the issue being whether the cross- complaint was in fact served on the plaintiff's attorney.
The trial court sustained a general demurrer to the complaint and gave judgment dismissing the cause, which the Texas Court of Civil Appeals affirmed, 101 S.W.2d 1046. Petition to the Texas Supreme Court for a writ of error was denied for want of jurisdiction. We granted certiorari, 302 U.S. 668 , 58 S.Ct. 28, 82 L.Ed. --; cf. Bain Peanut Co. v. Pinson, 282 U.s,. 499, 51 S.Ct. 228, the question being an important one of constitutional law. Our writ is properly directed to the Texas Court of Civil Appeals, it being the highest court of the state in which a judgment could be had. Bacon v. Texas, 163 U.S. 207, 215 , 16 S.Ct. 1023; Sullivan v. Texas, 207 U.S. 416 , 28 S.Ct. 215; San Antonio Railway Co. v. Wagner, 241 U.S. 476 , 36 S.Ct. 626; American Railway Express Co. v. Levee, 263 U.S. 19 , 44 S.Ct. 11.
The Texas Court of Civil Appeals rested its decision on a single ground, want of jurisdiction of the California court over the corporation in the cross-action in which the judgment was rendered. Construing the California statutes [303 U.S. 59, 62] and decisions which the complaint set out, it concluded that they did not authorize service of the complaint in the cross-action upon the plaintiff's attorney of record. It held further that in any case as the corporation was not present within the state no jurisdiction could be acquired over it by the substituted service, and the California judgment was consequently without due process and a nullity beyond the protection of the full faith and credit clause. To review these rulings we brought the case here. Cf. Ward v. Love County, 253 U.S. 17, 25 , 40 S.Ct. 419, 422; Indiana ex rel. Anderson v. Brand, 303 U.S. 95 , 58 S.Ct. 443, decided this day.
By R.S. 905, 28 U.S.C. 687, 28 U.S.C.A. 687, enacted under authority of the full faith and credit clause, article 4, section 1, of the Constitution, the duly attested record of the judgment of a state is entitled to such faith and credit in every court within the United States as it has by law or usage in the state from which it is taken. If it appears on its face to be a record of a court of general jurisdiction, such jurisdiction over the cause and the parties is to be presumed unless disproved by extrinsic evidence, or by the record itself. Hanley v. Donoghue, 116 U.S. 1 , 6 S.Ct. 242; Knowles v. Logansport Gaslight & Coke Co., 19 Wall. 58; Settlemier v. Sullivan, 97 U.S. 444 . But in a suit upon the judgment of another state the jurisdiction of the court which rendered it is open to judicial inquiry, Chicago Life Insurance Co. v. Cherry, 244 U.S. 25 , 37 S.Ct. 492, and when the matter of fact or law on which jurisdiction depends was not litigated in the original suit it is a matter to be adjudicated in the suit founded upon the judgment. Thompson v. Whitman, 18 Wall. 457. Here the fact of the service of the complaint upon the attorney is alleged by the petitioner and admitted by the demurrer, but the court's conclusion that the California court was without jurisdiction, resting in part upon its construction of the California statutes, presents an issue not litigated in the California suit which must be determined in the present one. [303 U.S. 59, 63] Congress has not prescribed the manner in which the legal effect of the judgment and the proceedings on which it is founded in the state where rendered are to be ascertained by the courts of another state. It has left that to the applicable procedure of the courts in which they are drawn in question. Where they are in issue this Court, in the exercise of its appellate jurisdiction to review cases coming to it from state courts, takes judicial notice of the law of the several states to the same extent that such notice is taken by the court from which the appeal is taken. 'Whatever was matter of law in the court appealed from is matter of law here, and whatever was matter of fact in the court appealed from is matter of fact here.' Hanley v. Donoghue, supra, 116 U.S. 1 , at page 6, 6 S.Ct. 242, 245.
According to Texas law the legal effect of the judgment of another state, on which suit is brought is to be determined by the court, not the jury. But a suitor who asserts that the force and effect of the judgment is different from that of a similar judgment of the courts of the state is required to allege specifically and prove as matter of fact the particular laws or usage on which he relies to establish the difference, and on demurrer only the law or usage specifically alleged will be considered in determining whether the law of another state differs from that of Texas. Porcheler v. Bronson, 50 Tex. 555; Gill v. Everman, 94 Tex. 209, 59 S.W. 531; National Bank of Commerce v. Kenney, 98 Tex. 293, 83 S.W. 368.
While this Court re-examines such an issue with deference after its determination by a state court, it cannot, if the laws and Constitution of the United States are to be observed, accept as final the decision of the state tribunal as to matters alleged to give rise to the asserted federal right. This is especially the case where the decision is rested, not on local law or matters of fact of the usual type, which are peculiarly within the cognizance of the local courts, but upon the law of another state, as readily determined here as in a state court. Huntington v. Attrill, 146 U.S. 657, 684 , 13 S.Ct. 224; Yarborough v. Yarborough, 168 S.C. 46, 166 S.E. 877; Id., 290 U.S. 202 , 54 S.Ct. 181, 90 A.L.R. 924.
But the question presented by the pleadings is the status of a cross- action under the California statutes, not under those of Texas. We think its status is adequately disclosed by the California statutes and decisions pleaded by petitioner, and is that for which he contends.
Section 442 of the California Code of Civil Procedure specifically provides that a defendant may secure affirmative relief upon 'cross- complaint' which 'must be served upon the parties affected thereby,' and requires service of 'summons upon the cross-complaint' only upon such parties as 'have not appeared in the action.' 1 Arguing that 'action' means only 'cross-action' and not the original action brought by the plaintiff, the Texas court con- [303 U.S. 59, 66] cluded that a plaintiff who has not appeared in the cross-action must be served with summons 'as upon the commencement of an original action.' But the word 'action,' even if susceptible of such meaning, cannot be so interpreted in the face of the pleaded California decisions which hold that a cross-complaint may be served on the attorney of one who is already a party to the original action. Farrar v. Steenbergh, 173 Cal. 94, 159 P. 707; Wood v. Johnston, 8 Cal.App. 258, 96 P. 508; Ritter v. Braash, 11 Cal. App. 258, 104 P. 592.
The question whether section 1015 does forbid service of a cross- complaint on the attorney has been definitely answered in the negative by the Supreme Court of California, which, in Farrar v. Steenbergh, supra, 173 Cal. 94, 97, 159 P. 707, 708, held, 'Service of a cross-complaint upon a plaintiff who appears by an attorney is not made by a summons to the plaintiff, but by delivery of a copy of the cross-complaint to the attorney.' Upon this ground the California District Court of Appeals, in cases, on which petitioner relies, has sustained judgments taken upon default in a cross-action begun by service of the cross-complaint on the plaintiff's attorney. Ritter v. Braash, supra; Wood v. Johnston, supra. Upon all the pleaded evidence of the California law, to the consideration of which we are restricted by the present state of the record, we think the only inference to be drawn is that the service in the California suit was authorized by California law.
There is nothing in the Fourteenth Amendment to prevent a state from adopting a procedure by which a judgment in personam may be rendered in a cross-action against a plaintiff in its courts, upon service of process or of appropriate pleading upon his attorney of record. The plaintiff having, by his voluntary act in demanding justice from the defendant, submitted himself to the jurisdiction of the court, there is nothing arbitrary or unreasonable in treating him as being there for all purposes [303 U.S. 59, 68] for which justice to the defendant requires his presence. It is the price which the state may exact as the condition of opening its courts to the plaintiff. Young Company v. McNeal-Edwards Co., 283 U.S. 398, 400 , 51 S.Ct. 538, 539; compare Chicago & Northwestern Railway Co. v. Lindell, 281 U.S. 14, 17 , 50 S.Ct. 200, 201.
[ Footnote * ] Rehearing denied 303 U.S. 666 , 58 S.Ct. 640, 82 L.Ed. --; Mandate conformed to 119 S.W.2d 687.

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