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Item # 24
City of Santa Ana
20 Civic Center Plaza, Santa Ana, CA 92701
Staff Report
March 19, 2024
TOPIC: Distance Requirements for Targeted Residential Picketing
AGENDA TITLE
Ordinance Establishing Distance Requirements for Targeted Residential Picketing
RECOMMENDED ACTION
1. Adopt an urgency ordinance establishing distance requirements for targeted
residential picketing.
ORDINANCE NO. NS-XXX entitled AN URGENCY ORDINANCE OF THE CITY
COUNCIL OF THE CITY OF SANTA ANA IN ACCORDANCE WITH SANTA
ANA CHARTER SECTIONS 415 AND 417 TO ESTABLISH DISTANCE
REQUIREMENTS FOR TARGETED RESIDENTIAL PICKETING (includes
determination that the ordinance is not subject to the California Environmental
Quality Act (CEQA) pursuant to Sections 15060(c)(2) and 15060(c)(3)); and
2. Approve first reading of an ordinance establishing distance requirements for
targeted residential picketing. If approved, Article 1 section 10-110 would be
amended and entitled “Targeted Residential Picketing” and sections 10-111 and
10-112 will be added to the Santa Ana Municipal Code.
ORDINANCE NO. NS-XXX entitled AN ORDINANCE OF THE CITY COUNCIL
OF THE CITY OF SANTA ANA AMENDING CHAPTER 10, ARTICLE 1,
SECTION 10-110 AND ADDING SECTIONS 10-111 AND 10-112 OF THE
SANTA ANA MUNICIPAL CODE TO ESTABLISH DISTANCE REQUIREMENTS
FOR TARGETED RESIDENTIAL PICKETING (includes determination that the
ordinance is not subject to the California Environmental Quality Act (CEQA)
pursuant to Sections 15060(c)(2) and 15060(c)(3)).
GOVERNMENT CODE §84308 APPLIES: No
DISCUSSION
Recently, an increasing number of picketers in the City of Santa Ana and surrounding
areas have targeted specific residences (and, at times, on private property of the
targeted residence), expressing their views at the targeted residence and captive
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March 19, 2024
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audience therein. City staff proposes that the City adopt an ordinance to address this
eminent re-occurring issue.
Targeted picketing not only harasses and intimidates occupants of a targeted home
(and other homes in close proximity to the targeted residence) but is intrusive upon
those individuals’ right to privacy in their home. Other municipalities have faced this
issue, and as a result, have enacted laws that afford protection against such actions at
private residences.
In an effort to manage targeted picketing in the City so as to protect an individual’s right
to privacy in their home, and to protect the safety of all involved, City staff recommends
that the City adopt this urgency ordinance and approve the first reading of the ordinance
prohibiting target picketing within 300 feet of the property line of a residence.
Establishing a distance which must be maintained between residential dwellings and
demonstrators targeting those dwellings will serve both these ends and the distance
restriction for targeted picketing proposed within this ordinance preserves ample
alternative channels of communication for protesters and demonstrators to disseminate
their message(s) and/or idea(s).This ordinance establishes a clear and precise buffer
zone between picketers and a targeted residence so as to preserve Santa Ana
residents’ right to privacy and prevent siege upon target residents while providing a
space for picketing. City staff proposes that the City adopt an ordinance to address this
imminent re-occurring issue.
The ordinance is attached for consideration as both an emergency (urgency) ordinance
(Exhibit 1) and a regular ordinance (Exhibit 2). Because these actions pose an
imminent threat to the public peace and safety, City staff recommend that this urgency
ordinance be adopted pursuant to Santa Ana Charter sections 415 and 417 which
provide that an urgency ordinance may be passed immediately upon introduction at a
regular meeting if made for the immediate preservation of the public peace, health, or
safety and passed by two-thirds (⅔) of the members of the City Council. If adopted, the
urgency ordinance will take effect on March 19, 2024.
The regular ordinance does not declare such express findings, and therefore, would be
considered for a first reading and second reading; if the majority of the members affirm
the passage of the first and second readings, the regular ordinance would become
effective 30 days after the second reading.
Staff recommends that the City Council:
1. Adopt an urgency ordinance establishing distance requirements for targeted
residential picketing.
2. Approve first reading of an ordinance establishing distance requirements for
targeted residential picketing.
Distance Requirements for Targeted Residential Picketing
March 19, 2024
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FISCAL IMPACT
There is no fiscal impact associated with this action.
EXHIBIT(S)
1. Urgency Ordinance
2. Regular Ordinance
Submitted By: Tom Hatch, Interim City Manager
Approved By: Tom Hatch, Interim City Manager
ORDINANCE NO. NS-XXXX
AN URGENCY ORDINANCE OF THE CITY COUNCIL OF
THE CITY OF SANTA ANA IN ACCORDANCE WITH
SANTA ANA CHARTER SECTIONS 415 AND 417 TO
ESTABLISH DISTANCE REQUIREMENTS FOR
TARGETED RESIDENTIAL PICKETING
WHEREAS, the City of Santa Ana, California (“City”) is a municipal corporation, duly
organized under the constitution and laws of the State of California; and
WHEREAS, Section VII of Article XI of the California Constitution provides that a city may
make and enforce within its limits all local, police, sanitary, and other ordinances and regulations
not in conflict with general laws; and
WHEREAS, demonstrators and protestors have a right, protected by the First Amendment of the
United States Constitution to express their views and to convey their message to both a general
audience and a particularly targeted audience; and
WHEREAS, persons and/or groups have a right to engage in picketing on public streets and
sidewalks within residential areas; and
WHEREAS, recently, an increasing number of picketers in the City of Santa Ana and
surrounding areas have targeted specific residences (and, at times, on private property of the
targeted residence), expressing their views at the targeted residence and captive audience therein;
and
WHEREAS, the City acknowledges that the act of picketing at, near, on or about a particular
residence whose occupants do not welcome such activity is an invasion of residential privacy for
its occupants and if picketers are positioned at, near, on or about a targeted residence, it becomes
impossible for the occupants to access or leave their homes without having to confront picketers;
and
WHEREAS, the City acknowledges that the act of picketing at, near, on or about a particular
residence whose occupants do not welcome such activity instills feelings of captivity, fear and
intimidation to the target occupants; and
WHEREAS, in developing this ordinance, the City has been mindful of legal principles relating
to the regulations of targeted residential picketing and considered decisions in Carey v. Brown
(1980) 447 US 455, the United States Supreme Court confirmed that the government’s protection
of the “well-being, tranquility, and privacy of the home is certainly of the highest order in a free
and civilized society” and that preserving “the sanctity of the home, the one retreat to which men
and women can repair to escape from the tribulations of their daily pursuits, is surely an
important value.”; and Frisby v. Schultz (1988) 487 US 474, the United States Supreme Court
concluded that “There simply is no right to force speech into the home of an unwilling listener”
and that the “devastating effect of targeted picketing on the quiet enjoyment of the home is
beyond doubt”.; and City of San Jose v. Superior Court of Santa Clara County (1995) 21
Cal.App.4th 330, the Court of Appeal for the 6th District, upheld an ordinance of the City of San
Jose prohibited targeted residential picketing within three hundred feet (300’) of the targeted
residential dwelling; and
WHEREAS, establishing a distance which must be maintained between residential dwellings
and demonstrators targeting those dwellings will serve both these ends and the distance
restriction for targeted picketing proposed within this Ordinance preserves ample alternative
channels of communication for protestors and demonstrators to disseminate their message(s)
and/or idea(s); and
WHEREAS, this Ordinance establishes a clear and precise buffer zone between picketers and a
targeted residences so as to preserve Santa Ana residents’ right to privacy and prevent siege upon
target residents while providing a space for picketing; and
WHEREAS, on February 22, 2024, a large group of protestors targeted a public official’s
private event at or near a private banquet hall in the City and with the use of a bullhorn, began
screaming vulgar and obscene statements about the public official creating fright, terror and
intimidation to those attending the event, blocked traffic, and followed guests to vehicles
resulting in a 911 call; and
WHEREAS, on February 24, 2024, protestors targeted and congregated on or in close proximity
to Congressman Lou Correa’s private residence at approximately 6:00 a.m. resulting in an
unwarranted invasion of residential privacy for the occupants and instilling feelings of captivity,
fear and intimidation to the target occupants; and
WHEREAS, because these actions pose an imminent threat to the public peace and safety, the
immediate preservation of the public peace, health or safety is warranted; and
WHEREAS, pursuant to Santa Ana City Charter sections 415 and 417, based on the above findings,
this Ordinance is declared by the City Council to be necessary as an emergency measure to protect
and preserve the health, safety and welfare of the citizens of the City of Santa Ana and will become
effective immediately if passed by the affirmative votes of at least two -thirds (2/3) of the members of
the City Council. The City Council hereby finds that there is an urgent need to adopt these
regulations in order to address the current and immediate threats set forth above.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA ANA DOES
ORDAIN AS FOLLOWS:
SECTION 1. Recitals. The recitals above are true, correct and each incorporated herein by
reference and adopted as findings by the Santa Ana City Council (“City Council”).
SECTION 2. Chapter 10, Article 1, Section 10-110 of the Santa Ana Municipal Code shall be
hereby amended and restated to read as follows: (new language is underlined and deleted
language is stricken):
Sec. 10-110. - Picketing of private residences.
(a)It is unlawful for any person to engage in picketing before of about the residence or dwelling
of any individual, where such picketing is focused on that particular residence or dwelling.(b)In
enacting this section, the city council finds and determines as follows:(1)The protection of the
well-being, tranquility and privacy of the home is a significant government interest.(2)Picketers
who focus upon a particular residence or dwelling generally do not seek to disseminate a
message to the general public but to intrude upon the targeted resident and to do so in an
especially offensive way.(3)Such picketers inherently and offensively intrude on residential
privacy.(4)The purpose of this section is to protect and preserve the home through assurance that
members of the community enjoy in their homes and dwellings a feeling of well-being,
tranquility and privacy.
Sec. 10-110- Targeted Residential Picketing.
(a) Definitions
For purposes of this Chapter, the following definitions shall apply.
(1) The term “residential dwelling” means any permanent building situated in the
City of Santa Ana that is being used by its occupants solely for non-transient
residential purposes.
(2) The term “targeted picketing” means picketing activity that is directed at a
particular residential dwelling or one or more occupants of a particular residential
dwelling, and that occurs at a particular location and/or which proceeds on a
definite course or route in front of or around that particular residential dwelling.
Section 3. Chapter 10, Article 1, Sections 10-111 and 10-112 of the Santa Ana Municipal Code
shall be hereby added as follows:
Section 10-111. Distance restrictions for Targeted Residential Picketing.
(a) No person shall engage in picketing activity that is targeted at and is within three
hundred feet (300’) of the residential dwelling that is the subject of the targeted
picketing.
(b) For purposes of this Section, the distance shall be measured from the outer walls of
the residential structure. An attached garage shall be considered part of the residential
structure.
(c) This section shall not be interpreted to preclude picketing or general marching in or
through a residential area that is not targeted at a particular residential dwelling.
Section 10-112 Penalties.
A. Any person violating the provisions of this section shall be guilty of a
misdemeanor, punishable by a fine not to exceed $1,000 and/or shall be sentenced
to imprisonment in the county jail for a period not to exceed six months. Each and
every day such a violation exists shall constitute a separate and distinct violation
of those sections
B. The remedies provided by this section are in addition to any other legal or
equitable remedies.
SECTION 3. Urgency Clause. The City Council finds and declares that this Ordinance is
required for the immediate protection of the public peace, health and safety of the residents of
the City of Santa Ana. More recently, demonstrators have picketed the homes of residents, and in
some instances, threatened intimidation. More recently, the threat of intimidation and violence
directed at resident occupants has become more concrete and imminent. For this reason, this
Ordinance shall become effective upon publication.
SECTION 4. California Environmental Quality Act. The City Council finds that this
Ordinance is not subject to the California Environmental Quality Act (CEQA) pursuant to
Sections 15060(c)(2) because the activity will not result in a direct or reasonably foreseeable
indirect physical change in the environment and 15060(c)(3) because the activity is not a project
as defined in Section 15378 of the CEQA Guidelines, California Code of Regulations, Title 14,
Chapter 3, because it has no potential for resulting in physical change to the environment,
directly or indirectly and so is not a project.
SECTION 5. Severability. Should any provision of this Ordinance, or its application to any
person or circumstance, be determined by a court of competent jurisdiction to be unlawful,
unenforceable or otherwise void, that determination shall have no effect on any other provision
of this Ordinance or the application of this Ordinance to any other person or circumstance and, to
that end, the provisions hereof are severable.
SECTION 6. Effective Date. This Ordinance shall become effective thirty (30) days following
its adoption.
SECTION 7. Publication. The City Clerk shall attest to the passage and adoption of this
Ordinance, causing it to be published as required by law, and it shall become effective thirty (30)
days after its adoption.
PASSED AND ADOPTED by the City Council of the City of Santa Ana, State of California, on
_______________, 2024 by the following vote:
ADOPTED this ______ day of ______________, 2024.
AYES: Councilmembers __________________________________
NOES: Councilmembers __________________________________
ABSTAIN: Councilmembers __________________________________
NOT PRESENT: Councilmembers __________________________________
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, JENNIFER HALL, City Clerk, do hereby attest to and certify that the attached Urgency
Ordinance No. NS-XXX to be the original ordinance adopted by the City Council of the City of
Santa Ana on March 19, 2024 and that said ordinance was published in accordance with the
Charter of the City of Santa Ana.
Dated:______________ __________________________________
City Clerk
City of Santa Ana
_______________________
Valerie Amezcua
Mayor
APPROVED AS TO FORM:
Sonia R. Carvalho
City Attorney
By:________________________
Tamara Bogosian
Senior Assistant City Attorney
ORDINANCE NO. NS-XXXX
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY
OF SANTA ANA AMENDING CHAPTER 10, ARTICLE 1,
SECTION 10-110 AND ADDING SECTIONS 10-111 AND 10-
112 OF THE SANTA ANA MUNICIPAL CODE TO
ESTABLISH DISTANCE REQUIREMENTS FOR
TARGETED RESIDENTIAL PICKETING
WHEREAS, the City of Santa Ana, California (“City”) is a municipal corporation, duly
organized under the constitution and laws of the State of California; and
WHEREAS, Section VII of Article XI of the California Constitution provides that a city may
make and enforce within its limits all local, police, sanitary, and other ordinances and regulations
not in conflict with general laws; and
WHEREAS, demonstrators and protestors have a right, protected by the First Amendment of the
United States Constitution to express their views and to convey their message to both a general
audience and a particularly targeted audience; and
WHEREAS, persons and/or groups have a right to engage in picketing on public streets and
sidewalks within residential areas; and
WHEREAS, recently, an increasing number of picketers in the City of Santa Ana and
surrounding areas have targeted specific residences (and, at times, on private property of the
targeted residence), expressing their views at the targeted residence and captive audience therein;
and
WHEREAS, the City acknowledges that the act of picketing at, near, on or about a particular
residence whose occupants do not welcome such activity is an invasion of residential privacy for
its occupants and if picketers are positioned at, near, on or about a targeted residence, it becomes
impossible for the occupants to access or leave their homes without having to confront picketers;
and
WHEREAS, the City acknowledges that the act of picketing at, near, on or about a particular
residence whose occupants do not welcome such activity instills feelings of captivity, fear and
intimidation to the target occupants; and
WHEREAS, in developing this ordinance, the City has been mindful of legal principles relating
to the regulations of targeted residential picketing and considered decisions in Carey v. Brown
(1980) 447 US 455, the United States Supreme Court confirmed that the government’s protection
of the “well-being, tranquility, and privacy of the home is certainly of the highest order in a free
and civilized society” and that preserving “the sanctity of the home, the one retreat to which men
and women can repair to escape from the tribulations of their daily pursuits, is surely an
important value.”; and Frisby v. Schultz (1988) 487 US 474, the United States Supreme Court
concluded that “There simply is no right to force speech into the home of an unwilling listener”
and that the “devastating effect of targeted picketing on the quiet enjoyment of the home is
beyond doubt”.; and City of San Jose v. Superior Court of Santa Clara County (1995) 21
Cal.App.4th 330, the Court of Appeal for the 6th District, upheld an ordinance of the City of San
Jose prohibited targeted residential picketing within three hundred feet (300’) of the targeted
residential dwelling; and
WHEREAS, establishing a distance which must be maintained between residential dwellings
and demonstrators targeting those dwellings will serve both these ends and the distance
restriction for targeted picketing proposed within this Ordinance preserves ample alternative
channels of communication for protestors and demonstrators to disseminate their message(s)
and/or idea(s); and
WHEREAS, this Ordinance establishes a clear and precise buffer zone between picketers and a
targeted residences so as to preserve Santa Ana residents’ right to privacy and prevent siege upon
target residents while providing a space for picketing.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA ANA DOES
ORDAIN AS FOLLOWS:
SECTION 1. Recitals. The recitals above are true, correct and each incorporated herein by
reference and adopted as findings by the Santa Ana City Council (“City Council”).
SECTION 2. Chapter 10, Article 1, Section 10-110 of the Santa Ana Municipal Code shall be
hereby amended and restated to read as follows: (new language is underlined and deleted
language is stricken):
Sec. 10-110. - Picketing of private residences.
(a)It is unlawful for any person to engage in picketing before of about the residence or dwelling
of any individual, where such picketing is focused on that particular residence or dwelling.(b)In
enacting this section, the city council finds and determines as follows:(1)The protection of the
well-being, tranquility and privacy of the home is a significant government interest.(2)Picketers
who focus upon a particular residence or dwelling generally do not seek to disseminate a
message to the general public but to intrude upon the targeted resident and to do so in an
especially offensive way.(3)Such picketers inherently and offensively intrude on residential
privacy.(4)The purpose of this section is to protect and preserve the home through assurance that
members of the community enjoy in their homes and dwellings a feeling of well-being,
tranquility and privacy.
Sec. 10-110. - Targeted Residential Picketing.
(a) Definitions
For purposes of this Chapter, the following definitions shall apply.
(1) The term “residential dwelling” means any permanent building situated in the
City of Santa Ana that is being used by its occupants solely for non-transient
residential purposes.
(2) The term “targeted picketing” means picketing activity that is directed at a
particular residential dwelling or one or more occupants of a particular residential
dwelling, and that occurs at a particular location and/or which proceeds on a
definite course or route in front of or around that particular residential dwelling.
Section 3. Chapter 10, Article 1, Sections 10-111 and 10-112 of the Santa Ana Municipal Code
shall be hereby added as follows:
Sec. 10-111.- Distance Restrictions for Targeted Residential Picketing
(a) No person shall engage in picketing activity that is targeted at and is within three
hundred feet (300’) of the residential dwelling that is the subject of the targeted
picketing.
(b) For purposes of this Section, the distance shall be measured from the outer walls
of the residential structure. An attached garage shall be considered part of the
residential structure.
(c) This section shall not be interpreted to preclude picketing or general marching in
or through a residential area that is not targeted at a particular residential dwelling.
Sec. 10-112.- Penalties.
A. Any person violating the provisions of this section shall be guilty of a
misdemeanor, punishable by a fine not to exceed $1,000 and/or shall be sentenced
to imprisonment in the county jail for a period not to exceed six months. Each and
every day such a violation exists shall constitute a separate and distinct violation
of those sections.
B. The remedies provided by this section are in addition to any other legal or
equitable remedies.
SECTION 4. California Environmental Quality Act. The City Council finds that this
Ordinance is not subject to the California Environmental Quality Act (CEQA) pursuant to
Sections 15060(c)(2) because the activity will not result in a direct or reasonably foreseeable
indirect physical change in the environment and 15060(c)(3) because the activity is not a project
as defined in Section 15378 of the CEQA Guidelines, California Code of Regulations, Title 14,
Chapter 3, because it has no potential for resulting in physical change to the environment,
directly or indirectly and so is not a project.
SECTION 5. Severability. Should any provision of this Ordinance, or its application to any
person or circumstance, be determined by a court of competent jurisdiction to be unlawful,
unenforceable or otherwise void, that determination shall have no effect on any other provision
of this Ordinance or the application of this Ordinance to any other person or circumstance and, to
that end, the provisions hereof are severable.
SECTION 6. Effective Date. This Ordinance shall become effective thirty (30) days following
its adoption.
SECTION 7. Publication. The City Clerk shall attest to the passage and adoption of this
Ordinance, causing it to be published as required by law, and it shall become effective thirty (30)
days after its adoption.
PASSED AND ADOPTED by the City Council of the City of Santa Ana, State of California, on
_______________, 2024 by the following vote:
ADOPTED this ______ day of ______________, 2024.
_______________________
Valerie Amezcua
Mayor
APPROVED AS TO FORM:
Sonia R. Carvalho
City Attorney
By:________________________
Tamara Bogosian
Senior Assistant City Attorney
AYES: Councilmembers __________________________________
NOES: Councilmembers __________________________________
ABSTAIN: Councilmembers __________________________________
NOT PRESENT: Councilmembers __________________________________
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, JENNIFER HALL, City Clerk, do hereby attest to and certify that the attached
Ordinance No. NS-XXXX to be the original ordinance adopted by the City Council of the City
of Santa Ana on _______________, 2024 and that said ordinance was published in accordance
with the Charter of the City of Santa Ana.
Dated:______________ __________________________________
City Clerk
City of Santa Ana