7. Eto2v: Everybody Turn-Out To Vote

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  Social media The CGJ notes that older voters habitually fulfill their civic duty and are among the most reliable voters. The younger generation, however, receives its motivation to vote in a different manner, although a recent report by the Secretary of State highlighted that thousands of young California voters registered to vote online in recent months,11 indicating perhaps that the Presidential General Election itself is inspiring the new registrations. With younger voters in mind, the CGJ discussed the use of social media with RR/CC and is encouraged that several platforms (Facebook, Twitter, etc.) are already used to spread registration and election-related information to Los Angeles County voters. The CGJ notes that social media was used quite effectively in Los Angeles Mayor Garcetti’s You Tube video to inform Los Angeles drivers about freeway closures required for the recent demolition of the 6th Street Bridge in downtown Los Angeles. The Mayor used a video format in a very catchy manner -- very smooth, “Barry White style” comments while being backed by the Roosevelt High School Jazz Band – and the video was “shared” by thousands of You Tube viewers in Los Angeles and around the country. This approach could be a cost effective way for RR/CC to promote its election-related information to younger voters. With the limited resources that have been made available to RR/CC to promote the turn-out to vote campaign, it would be prudent to use these resources to promote voting to the young citizens on social media. RR/CC has a budget for FY 2015-2016 of $500,000 and has requested a budget of $750,000 for FY 2016-
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  Public service announcements The promotion of a turn-out to vote marketing campaign through the use of PSAs is most effective when they play to the largest possible segment of the population. 11White, Jeremy B., “Youth Vote Boosted by Online Registration in California,” Sacramento Bee (March 30, 2016) http://www.sacbee.com/news/politics-government/capitol-alert/article69108612.html 12 http://www.youtube.com/watch?v=Us-TVg40ExM&sns=em 13 On his website, Mr. Lear expresses his interest in being a person for change in America and he also might be willing to assist with the development of one of these videos to promote the get out to vote campaign. www.normanlear.com 136 2015-2016 LOS ANGELES COUNTY CIVIL GRAND JURY FINAL REPORT Marketing campaigns for public information purposes, however, as opposed to paid campaign advertising, are diminished by the off-hour times these types of advertisements are aired. PSAs can be self-produced. They must be submitted by Internal Revenue Code Section 501(c)(3) nonprofit organizations or a government entity. For a minimal fee, the medium that will broadcast the PSA will also produce it to be read on the radio or shown on television. This market is limited by the reduced air time given to these unpaid messages whether they are played on the radio or television.14 In Los Angeles County, the prime drive-time advertising slots on the radio – 6 a.m. to 9 a.m. and 5 p.m. to 8 p.m. -- are nearly always reserved for paid advertising. In the rare instance when there is air time available during those hours, however, radio stations charge $350 - $400 to read a PSA on the air.15 Consequently, the only times slots routinely available for PSAs are very late at night until 5 a.m. The airing of PSAs on television is even less likely to happen during the prime time hours of 6 p.m. to 10 p.m. because the earlier hours are filled with paid advertising purchased months in advance by local advertisers and the later hours with advertising by national interests. Local television stations quoted prices that started at $20,000 per 30 seconds of advertising for local programs and substantially more for advertisements that air during nationally televised programming.16 Messaging of this type is not likely to be a cost effective way to reach potential voters. C. Vote By Mail In the United States absentee balloting was introduced by President Lincoln. During the Civil War soldiers in the field cast ballots in the 1864 election. During the early part of the 20th Century many states adopted this type of voting to limited segments of the population including railroad workers, government employees out of state, military voters away from home, the sick and elderly included. By World War II almost every state had adopted some form of absentee voting. Until quite recently most states required voters to explain to election officials why they were unable to get to the polls and some voters were requested to sign notarized affidavits. Prior to 1965, just 5% of voters nationwide cast absentee ballots in all elections.17 The Voting Rights Act of 1965, and later amendments, led to a broader interpretation of the right to vote and restrictions on absentee voting no longer exist in most states. In the 1970s a number of states, particularly in the West, began to loosen existing requirements on voters. In 1978, for example, California extended absentee voting to any voter “on request” and in 2001 extended permanent “no-excuse” voting to any voter who simply wished to bypass the polls on Election Day. Interviews with various station managers in the Los Angeles media market. Ibid. Ibid. 17Espejo, Roman, Voter Fraud , Greenhaven Press (2010), p. 60. 2015-2016 LOS ANGELES COUNTY CIVIL GRAND JURY FINAL REPORT 137 By 2012, 51% of all votes cast in California in the Presidential General Election were on VBM Ballots.18 There may be a generational tilt toward their use by older voters. The founding director of the University of California, Davis “California Civic Engagement Project” also concluded that for many young voters “the idea of putting a postage stamp on the envelope is an odd concept.”19 There is no question, however, that VBM presents a convenient way for a majority of voters to cast their ballots. There are approximately 4.8 million registered voters in Los Angeles County, and nearly 1.5 million of them, or 31%, are designated as permanent VBM. In the 2012 General Election 975,828 VBM ballots were returned to the RR/CC.20 A recent change in California law, effective January 1, 2015, allows a three-day grace period for VBM ballots to reach RR/CC and still be counted, if they are postmarked no later than Election Day,21 a reform which is intended to assure that as many votes are counted as possible. Another such reform permits RR/CC to contact voters up to seven days following Election Day to correct a missing or non-matching signature.22 RR/CC is in the process of developing a new vote by mail packet in response to feedback on the usability of the current VBM packet and ballot. This involves a new, larger format allowing voters to mark the ballot directly next to the relevant races, which will be grouped by each local, state and federal contest; judicial contests; ballot measures; and county, school and other district offices. This layout dispenses with the “computer card” ballot entirely and is larger and easier to read. Also involved are upgrades regarding simplicity of instructions, size of the security sleeve, and testing of overall voter success in returning a completed ballot. This process is in the final stages and has been presented to selected interested members of the community for their comments. Three states -- Oregon, Washington and Colorado -- conduct all of their elections by mail. None of them, however, has an electorate that is as large as that in Los Angeles County.23 The RR/CC stated the size and population of Los Angeles County prohibits a 100% VBM election, and he is committed to running “dual elections.” Suggestions to send VBM ballots to all registered voters have been abandoned. 18 http://elections.cdn.sos.ca.gov/sov/2012-general/03-voter-participation-stats-by-county.pdf 19 Ibid. Of those, 5,596 ballots, or 0.96%, were challenged. The number of VBM ballots challenged was supplied by RR/CC. Based on these figures the CGJ estimates that the number of disqualified votes in Los Angeles County VBM ballots is very small. RR/CC has said most challenged votes relate to either a lack of signature or a signature which does not match records. Attempts are then made to reach the voter and have the voter file a new affidavit or cast his or her vote in time for Election Day. Cal. Elections Code section 4103. Cal. Elections Code section 3019 “(f)(1) (A) Notwithstanding any other law, if an elections official determines that a voter has failed to sign the identification envelope, the elections official shall not reject the vote by mail ballot if the voter does any of the following: (i) Signs the identification envelope at the office of the elections official during regular business hours before 5 p.m. on the eighth day after the election. (ii) Before 5 p.m. on the eighth day after the election, completes and submits an unsigned ballot statement . . . (iii) Before the close of the polls on election day, completes and submits an unsigned ballot statement, in the form described in clause (ii), to a polling place within the county or a ballot dropoff box.” 23 The most recent update of registered voters in Los Angeles was 4.8 million voters. http://elections.cdn.sos.ca.gov//ror/ror- pages/county.pdf Washington has 4.0 million registered voters. http://www.sos.wa.gov/elections/ Colorado has 2.9 million registered voters. http://www.sos.state.co.us/pubs/elections/VoterRegNumbers/VoterRegNumbers.html Oregon has 2.2 million registered voters. http://sos.oregon.gov/elections/Pages/electionsstatistics.aspx 138 2015-2016 LOS ANGELES COUNTY CIVIL GRAND JURY FINAL REPORT D. Development of Updated Ballot Marking Devices: New Voting Machines and a New Voting Experience for Voters
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  Beyond “one man, one vote”: random electors Another model imagines that a pre-determined number of voting citizens, selected at random, would become electors with the power to vote in a given election. The government would pay each elector a substantial sum to ensure their voting.29 The exact details are not important here. The important idea is that a small number, but not too small, of registered voters be selected and given the right to vote. They will then be paid to vote. Using voter registration rolls for selecting “electors” could additionally and dramatically increase the number of citizens who register to vote. Many changes to voting laws at all government levels would, of course, be necessary to implement this idea, but if voter turn-out 29 Jason Brennan, Lisa Hill, Compulsory Voting: For and Against, Cambridge University Press (2014), Chapter 2. (“In a voting lottery, all citizens have the same equal fundamental political status. While in universal suffrage, every citizen has one equal vote, in a voting lottery, every citizen has equal eligibility to vote. Elections proceed normally, with candidates working to gain support from voting-lottery eligible citizens. Shortly before the election, the system selects a pre-determined number of citizens at random. These citizens—and these citizens only—become “electors”, imbued with the power to vote. To ensure turnout, the government pays each elector a substantial sum to vote. [footnote omitted] They are not forced to vote. We might perhaps ask them to sign a contract committing them to voting (in exchange for the payment), and then allow them to be punished for breach of contract if they renege. This involves compulsion, but only compulsion to which citizens genuinely consent.”) 2015-2016 LOS ANGELES COUNTY CIVIL GRAND JURY FINAL REPORT 143 languishes we may as a society need to completely reform how decision making takes place. III. METHODS AND PROCEDURES The CGJ conferenced on several occasions with the RR/CC and visited that department’s headquarters in Norwalk. Presentations, reports, exemplars, and other documents provided by the department were reviewed. Members read academic research and reviewed studies pertaining to the voting experience in California and other states. Members contacted media companies and inquired about their policies and procedures with regard to public service announcements. IV. FINDINGS
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  The RR/CC has formed a working group to study expanding Early Voting in Los Angeles County before Election Day.
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  A pilot project may be put in place to open one or two “will call” ballot pick up centers in each of the supervisorial districts for the June 2016 primary.
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  8, to evaluate and make appropriate recommendations to the Los Angeles County Board of Supervisors and affected school districts about school bond indebtedness. 6.10 Los Angeles County should authorize the committee formed in
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  Radio and television stations charge for advertisements depending on the popularity of the show during which the advertisement is to run. Public service announcements are also run, but only when other advertisers have not purchased time slots. 144 2015-2016 LOS ANGELES COUNTY CIVIL GRAND JURY FINAL REPORT
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  The RR/CC’s budget for voter outreach is $500,000 for the fiscal year ending June 30, 2016. The RR/CC is requesting $750,000 for fiscal year 2016-2017. This amount is still not enough to promote the turn-out to vote campaign on television, radio, and other forms of communication mediums.
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  The RR/CC has negotiated package deals with media companies that include placement of turn-out-related “branded” announcements on a range of locations: billboards, kiosks, etc., across a range of businesses in the county.
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  The California Secretary of State has negotiated a deal with Metro to provide coordinated “branded” voter outreach messaging on bus shelters and buses.
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  Vote By Mail (VBM) ballots are most commonly challenged for lack of a voter signature on the return envelope.
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  If a voter’s signature does not compare with the signature affidavit on file (according to the automated signature verification software), the envelope is reviewed manually. Voters in this situation are contacted and provided the opportunity to sign a new affidavit. A new state law, codified in California Elections Code section 3019 (f)(1) (A), permits the RR/CC to request such a new affidavit up to seven (7) days following Election Day.
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  A recent change in California law, codified in California Elections Code section 4103, permits VBM ballots postmarked on Election Day to be counted if they are received no later than three days after Election Day.
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  New VBM ballots are being designed and may be used in the 2018 election cycle.
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  When implemented, the new interactive sample ballot (ISB) is planned to be able to automatically populate a voter’s ballot with his or her choices before the voter enters the vote center. Changes to those choices can be later made by the voter when he or she is using the completely redeveloped ballot marking device (BMD), before the official paper ballot is generated.
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  When implemented, the new voting experience is planned to include the ISB, expanded Early Voting (including weekend voting), Election Day registration, vote centers to replace precinct polling places, and new BMDs.
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  After implementation of the new BMD, Early Voting is planned at numerous locations around the county. For about 10 days before Election Day, there will be many early/weekend vote centers available, the quantity of which will more than double on Election Day.
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  Voting roll books are planned to be replaced by real-time electronic voter rolls to verify voter eligibility. 2015-2016 LOS ANGELES COUNTY CIVIL GRAND JURY FINAL REPORT 145
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  Many special requirements are planned to be accommodated on the new BMD such as a touchscreen interface, language selection, audio input, headphones, a tactile keypad and ports for voters to connect assistive technology devices. The new BMD is planned to be completely accessible and provide a private voting experience for each voter
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  The new BMD is planned to replace the currently-used InkaVote machines. The new machines are being developed using federal Help America Vote Act (HAVA) funds and will employ computer technology that will create a paper ballot that will be the official ballot of record.
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  The $55 million still available is adequate to complete development and testing of the new BMD.
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  The purchase of new BMD will require additional funding. V. RECOMMENDATIONS 7.1 Los Angeles County should give full financial support to the Registrar Recorder/County Clerk’s efforts to bring the new voting system to fruition. 7.2 Los Angeles County and the Registrar Recorder/County Clerk should make all reasonable efforts to develop and test the new BMD so that the new machines are able to be used county wide no later than the 2020 election. 7.3 Los Angeles County and the Registrar Recorder/County Clerk should offer the new voting system, which is the most up-to-date technological method for secure voting, to other counties throughout the nation for a reasonable fee. 7.4 Los Angeles County and the Registrar Recorder/County Clerk should provide a minimum of five additional, secure Early Voting sites in the county for the 2016 Presidential General Election and also allow VBM ballot drop off at each site. 7.5 Los Angeles County and the Registrar Recorder/County Clerk should allocate funding to provide additional personnel to staff any additional, secure Early Voting or “will call” sites established for the 2016 Primary and Presidential General Elections. 7.6 The Registrar Recorder/County Clerk should institute a “will call” system of Early Voting for the next election after 2016, and determine optimal procedures and voter use. 7.7 Los Angeles County and the Registrar Recorder/County Clerk should take advantage of free publicity on individual city websites and city cable channels to 146 2015-2016 LOS ANGELES COUNTY CIVIL GRAND JURY FINAL REPORT promote the upcoming changes in the voting system as each one is implemented. 7.8 The Registrar Recorder/County Clerk should address the public meetings of the Los Angeles County Board of Supervisors and all of the cities in Los Angeles County to discuss opportunities for citizen involvement in voter outreach. 7.9 The Registrar Recorder/County Clerk should expand its use of social media for voter outreach in future elections, and should consider enlisting the public to help create and disseminate voter outreach messages. 7.10 A Registrar Recorder/County Clerk spokesperson should make appearances on morning and evening televised newscasts to discuss and promote the turn-out to vote campaign. 7.11 A Registrar Recorder/County Clerk spokesperson should schedule interviews on radio to promote the turn-out to vote campaign. 7.12 The Registrar Recorder/County Clerk should publicize the fact that VBM ballots can be postmarked on Election Day and still be counted. 7.13 Los Angeles County and the Registrar Recorder/County Clerk should initiate a study and complete it by January 1, 2017, to determine methods to increase the use of VBM ballots, including government payment of return postage and voter outreach regarding VBM procedures. 7.14 The Registrar Recorder/County Clerk should reconsider sending a ballot, using business reply envelopes, to each registered voter. 7.15 The Registrar Recorder/County Clerk should organize a committee, to meet at least once per year, to re-examine the implementation of on-line voting. VI. REQUEST FOR RESPONSE California Penal Code Sections 933 (c) and 933.05 require a written response to all recommendations contained in this report. Such responses shall be made no later than ninety (90) days after the Civil Grand Jury publishes its report (files it with the Clerk of the Court). Responses shall be made in accord with Penal Code Sections 933.05 (a) and (b). 2015-2016 LOS ANGELES COUNTY CIVIL GRAND JURY FINAL REPORT 147 All responses to the recommendations of the 2015-2016 Civil Grand Jury must be submitted on or before September 30, 2016, to: Presiding Judge Los Angeles County Superior Court Clara Shortridge Foltz Criminal Justice Center 210 West Temple Street Eleventh Floor-Room 11-506 Los Angeles, CA 90012 Responses are required from: Board of Supervisors: 7.1, 7.2, 7.3, 7.4, 7.5, 7.7, 7.13 Registrar-Recorder/County Clerk: 7.2, 7.3, 7.4, 7.5, 7.6, 7.7, 7.8, 7.9, 7.10, 7.11, 7.12, 7.13, 7.14, 7.15 VII. ACRONYMS BMD Ballot Marking Device BOS Board of Supervisors CGJ Civil Grand Jury ISB Interactive Sample Ballot PSA Public Service Announcement RR/CC Registrar-Recorder/County Clerk VBM Vote By Mail VIII. COMMITTEE MEMBERS Molly Milligan Chair Bruce A. Berke Francine DeChellis Victor H. Lesley Stephen Press Cynthia Vance George Zekan 148 2015-2016 LOS ANGELES COUNTY CIVIL GRAND JURY FINAL REPORT ICE IN L.A. ICE IN L.A. I. EXECUTIVE SUMMARY The Los Angeles County Civil Grand Jury (CGJ) conducted a study to determine the effectiveness of a new program in the screening of undocumented immigrants in Los Angeles County jails. The primary concern of the CGJ was to ensure that agents of Immigration and Customs Enforcement (ICE) interview, for possible deportation, those undocumented inmates deemed to be a serious public safety threat. The new procedure from the Los Angeles County Sheriff’s Department (LASD) outlined a shift away from the previous policies and procedures. Under the new policy, federal immigration officials are allowed access to inmates who are being released from jail. ICE agents will only be allowed to interview those inmates who have been convicted of serious crimes and are not protected by the California Trust Act. The Trust Act shields immigrant inmates from ICE agents unless they have been convicted of a serious crime. Inmates are advised of their right to consult counsel before they are turned over to ICE agents. Public posting of information is instituted to promote transparency and accountability. Monthly audits make sure only Trust Act qualified inmates are transferred to ICE, and only during the standard time period it would normally take to release an inmate.1 The new procedures in Los Angeles County stand in contrast to those in San Francisco. The Sheriff in San Francisco and other sanctuary cities have banned all collaboration with federal immigration officials except when federal authorities have a court order or a warrant. II. BACKGROUND Seven days prior to any inmate’s release, LASD provides his or her name to ICE agents. The ICE screening process of inmates to be released at the Inmate Reception Center (IRC) consists of computerized database screening such as fingerprints and is not race-based. The LASD personnel verify that the inmate’s conviction is listed in the California Trust Act. Only after all of the relevant steps are completed can an ICE interview occur, 1 Letter from Sheriff Jim McDonnell to Board of Supervisors. September 22, 2015 (hereafter “McDonnell letter”). 2015-2016 LOS ANGELES COUNTY CIVIL GRAND JURY FINAL REPORT 149 followed by the possibility of an ICE immigration detainer and advice of their right to consult with legal counsel. Figure 1 illustrates the screening process. Some programs identified in it are described in detail later in this report. Figure 1 – Screening Process Diagram No Is there an ICE Yes detainer issued through PERC? No Does inmate meet PEP and Notify inmate of an ICE Trust Act? detainer. Advise inmate of right to consult counsel Inmate will not be Yes available for transfer to ICE Yes No Potential for ICE Does inmate interview meet PEP and Trust Act? Inmate will not be Notify ICE up to seven Notify ICE up to seven available for transfer (7) days prior to release (7) days prior to release to ICE P otential for ICE transfer Potential for ICE transfer 2 CGJ devised this chart based on information received from LASD. The information contained in this simplified diagram is merely for reference use only and not intended as legal advice or direction. No reliance should be placed upon it for making important decisions. 150 2015-2016 LOS ANGELES COUNTY CIVIL GRAND JURY FINAL REPORT A. History In 2005 and again in October 2014 the Los Angeles County Board of Supervisors (BOS) authorized LASD to participate in ICE’s 287(g) program. This section of the Immigration and Nationality Act allows local law enforcement officials to perform some of the duties of immigration officers. Five specially trained custody assistants worked with a dozen federal agents within the Los Angeles County jails, interviewing and investigating inmates to determine their immigration status.3 This kind of in-depth screening helped detect deportable inmates whose fingerprints did not show up in the federal database. On May 12, 2015, BOS voted 3-2 to end the program. The Los Angeles Times reported that this vote was the result of years of pressure from advocates who claimed that it led to racial profiling.4 The same day BOS ended the prior agreement, it voted 4-1 to instruct LASD to continue to cooperate with ICE in identifying deportable immigrants being held in the jails which included a new federal initiative called the Priority Enforcement Program (PEP). BOS directed LASD to report back in 90 days on a strategy for implementation while safeguarding the rights of all. Following this action LASD sought input from a variety of community groups, including “ICE out of L.A.,” the Public Defender’s Office, the American Civil Liberties Union, the National Immigration Law Center and other immigration groups. These policies were finalized on September 22, 2015. B. Key LASD practices and principles 6 • LASD will provide ICE with notification up to seven (7) days prior to an inmate’s release. Full access into the County’s jails and databases will also be authorized in order for ICE to conduct thorough investigations, ensuring timeframes and procedures are met. During this period of time, ICE will have the opportunity to interview inmates who have ICE immigration detainers and certain other inmates who meet PEP and Trust Act criteria. • LASD will implement a system for notifying inmates when an ICE detainer is issued. In addition to the notification, inmates will be advised of their opportunity to consult legal counsel. • ICE agents will be allowed to review the status of all inmates who are being released. This effort helps to identify any and all individuals who may pose a danger and who are within the criteria of both PEP and the Trust Act. • LASD will validate an inmate’s qualification under the Trust Act, prior to in- custody transfer to ICE. All crimes allowable by the Trust Act will be eligible for in-custody transfer. The Times Editorial Board. “No Ice in L.A. County jails.” Los Angeles Times 19 May 2015 http://www.lstimes.com/nation/la-ed-ice- agents-in-county-jailos-20150519-story.html 4 Linthicum, Kate. “Immigration agents allowed back in L.A. County jails, with limits.” Los Angeles Times 23 Sept. 2015. http://www.latimes.com/local/lanow/la-me-ln-ice-los-angeles-jails-20150922-story.html 5 Linthicum, Kate. “Immigration agents allowed back in L.A. County jails, with limits.” Los Angeles Times 23 Sept. 2015. http://www.latimes.com/local/lanow/la-me-ln-ice-los-angeles-jails-20150922-story.html 6 McDonnell letter. 2015-2016 LOS ANGELES COUNTY CIVIL GRAND JURY FINAL REPORT 151 • ICE agents will be authorized to interview specific inmates who do not have ICE immigration detainers issued through Pacific Enforcement Response Center (PERC). • Trust Act/PEP qualified inmates will be transferred to the custody of ICE only during the standard amount of time it would normally take to release an inmate. No inmate will be held beyond the release date based solely on an ICE request. • To promote transparency and accountability, monitoring and public posting of information will be instituted. C. Pacific Enforcement Response Center The Pacific Enforcement Response Center (PERC) is the agency through which ICE issues immigration detainers for immigrants arrested by local law enforcement who are suspected of being in the country illegally.7 The center is a key part of the federal government’s efforts to identify and deport immigrants convicted of serious crimes. Immigration authorities issue immigration detainers based on electronic data after gaining access to fingerprints from jail bookings. This is a result of enhanced law enforcement information-sharing after the 2001 terrorist attacks. D. Priority Enforcement Program 8 On November 20, 2014, the Obama Administration announced the new PEP program regarding immigration enforcement. The new policies took effect on January 5, 2015. The Department of Homeland Security (DHS) PEP enables ICE to work with state and local law enforcement to take custody of inmates who pose a danger to public safety before they are released into our communities. PEP was established at the direction of the DHS Secretary and focuses on convicted criminals and others who pose a danger to public safety. PEP begins at the state and local level when an individual is arrested and booked by a law enforcement officer for a criminal violation and his or her fingerprints are submitted to the FBI for criminal history and warrant checks. This same biometric data is also sent to ICE so that ICE can determine whether the individual is a priority for removal, consistent with DHS enforcement priorities. Under PEP, ICE will seek the transfer of a removable individual who has (1) been convicted of an offense listed under DHS civil immigration enforcement priorities, (2) intentionally participated in an organized gang to further the illegal activity of the gang, or (3) poses a danger to national security. The policy is primarily about reforms to immigration detainers which will now generally be notification requests, not hold requests for extra detention. Taxin, Amy. “Immigration detainers often issued by California Center.” The Associated Press 19 Sept. 2015. http://home.cableone.net/news/read/category/AP%20Top%20News%20-%20US%20Headlines/article/the_associated_press- immigration_detainers_often_issued_by_california_c-ap 8 Department of Homeland Security Website. https://www.ice.gov/pep 152 2015-2016 LOS ANGELES COUNTY CIVIL GRAND JURY FINAL REPORT The three civil enforcement PEP priority levels are described below.