The policy a city council adopts under SB 580 by January 1 governs the public counter, the records room and the database. It does not govern the patrol car or the holding cell. Those are covered by three older statutes that bind the police department directly, carry their own reporting dates, and put one obligation on the council itself.
Last month we wrote about Senate Bill 580, which requires every state and local agency in California to implement the Attorney General's model policy on interactions with immigration authorities, or an equivalent, by January 1, 2027. That policy is written for agencies of every kind. A city with a police department has a second body of law to account for, and the Attorney General's SB 580 guidance says so in a sentence that is easy to read past: "The California Values Act applies directly to law enforcement agencies." It then points those agencies to the Division of Law Enforcement's information bulletins, which they "should review and follow."
This post covers that second body of law: the California Values Act (SB 54; Gov. Code, §§ 7284–7284.12), the TRUST Act (§§ 7282, 7282.5) and the TRUTH Act (§§ 7283–7283.2), as the Attorney General restated them in Information Bulletin 2025-DLE-03 on January 17, 2025. None of it is new. What is new is that a council adopting an SB 580 policy will be asked whether the police department is covered, and the answer is that it is covered twice.
Two regimes in one city
SB 580 works through policy. Government Code section 12532.5 tells each agency to implement the model or an equivalent, and it has no penalty clause. The Values Act works through prohibition. Section 7284.6 opens with the words "California law enforcement agencies shall not," and what follows binds a police department whether or not anyone has adopted a policy.
A police department is both kinds of agency. Its lobby, records counter and property room are public-agency facilities, and the SB 580 model policy applies to them as it does to the city clerk's office. Its officers, holding cells and investigative files are governed by the Values Act. The cleanest way to write the city's SB 580 policy is to say so: the citywide policy governs the department's public-facing functions, and the department's own immigration policy, incorporated by reference, governs enforcement.
Charter cities are not exempt. In City of Huntington Beach v. Becerra (2020) 44 Cal.App.5th 243, 279–280, the Court of Appeal reversed a trial court that had excused the city from compliance and held section 7284.6 valid as applied to charter cities, because it addresses matters of statewide concern and is narrowly tailored to them. The Supreme Court denied review. The Ninth Circuit had already rejected the federal government's preemption challenge in United States v. California (9th Cir. 2019) 921 F.3d 865, and Huntington Beach's later federal suit was dismissed in December 2025.
What the department may not do
Section 7284.6, subdivision (a), bars a California law enforcement agency from using its money or personnel "to investigate, interrogate, detain, detect, or arrest persons for immigration enforcement purposes." Among the particulars:
Asking about a person's immigration status.
Holding a person past release on an immigration hold request.
Giving out a release date, or a home or work address, unless the information is public or, for release dates, the TRUST Act allows it.
Making or intentionally participating in an arrest on a civil immigration warrant.
Performing the functions of an immigration officer, under a federal 287(g) agreement "or any other law, regulation, or policy, whether formal or informal."
Placing officers under federal supervision for immigration enforcement, or using immigration authorities as interpreters for people in custody.
Transferring a person to immigration authorities without a judicial warrant or judicial probable cause determination, except as the TRUST Act allows.
"Immigration enforcement" reaches federal civil immigration law and also any federal criminal immigration law "that penalizes a person's presence in, entry, or reentry to, or employment in, the United States" (§ 7284.4, subd. (f)).
What it may do, if the city lets it
Subdivision (b) lists what the Act does not prevent, and every item carries the same condition: the activity must be one "that does not violate any policy of the law enforcement agency or any local law or policy of the jurisdiction in which the agency is operating." Subject to that, a department may answer a request for a specific person's criminal history, take part in a joint task force whose primary purpose is not immigration enforcement, allow a custodial interview that complies with the TRUTH Act, and arrest for certain illegal reentry offenses detected during unrelated police work.
The TRUST Act supplies the rest. A department may answer a notification request or make a transfer only for a person in a listed category, chiefly prior convictions for serious, violent or state-prison felonies and recent convictions for listed offenses (§ 7282.5, subd. (a)). A conviction that Proposition 47 reduced to a misdemeanor never qualifies, and the bulletin tells agencies to read the rap sheet for exactly that.
Two points follow for a council. First, nothing on these lists is required. On release dates the statute is explicit: "Responses are never required, but are permitted under this subdivision, provided that they do not violate any local law or policy." Second, the local-policy condition is a decision the city already owns. If the council and the department say nothing, the department's discretion runs to the statute's ceiling. If either adopts something narrower, the narrower rule binds; the bulletin confirms that local or agency policy "may be more restrictive than the Values Act." That choice should be made on the record, not by default.
At the scene of a federal operation
For a city department, the harder questions tend to come not from the jail but from the street, when a federal operation draws a crowd and the city's officers are called.
The statute's answer is one sentence: "Nothing in this section shall prohibit a California law enforcement agency from asserting its own jurisdiction over criminal law enforcement matters" (§ 7284.6, subd. (f)). The bulletin reads that to cover a call for service about a state-law crime, and an immigration enforcement action "where the safety of the public or a law enforcement officer, including an immigration enforcement officer, is in danger." It then adds the limit: "This narrow public safety exception should not be used to avoid the prohibitions in the Values Act on using state resources to conduct immigration enforcement."
The line runs between responding to a crime or a danger, which is permitted, and lending officers to the operation itself, which is not. Where traffic control and crowd management fall depends on the facts of the hour, and it is the question a watch commander will face with no time to call the city attorney. Decide it in advance and in writing.
Information: what may leave the building
Personal information. The bar on providing personal information applies "unless that information is available to the public." The bulletin reads that phrase to mean "information where a law enforcement agency has a practice or policy of making such information public, such as disclosing the information on its website." A department that posts booking logs has made a decision about more than transparency.
Status information. The Act leaves untouched the exchange of information about citizenship or immigration status under 8 U.S.C. §§ 1373 and 1644 (§ 7284.6, subd. (e)). The Ninth Circuit reads those statutes to reach a person's legal classification only, not release dates or addresses (United States v. California, 921 F.3d at p. 891).
License plate readers. A public agency "shall not sell, share, or transfer ALPR information, except to another public agency, and only as otherwise permitted by law" (Civ. Code, § 1798.90.55, subd. (b)). The Attorney General's position, in Information Bulletin 2023-DLE-06, is that "public agency" means a California agency, so sharing with federal or out-of-state agencies is barred, including through a vendor's shared network. He sued the City of El Cajon on that theory in October 2025, and we found no reported ruling as of this writing. Whatever the court decides, a department should know today which agencies can query its plate data. The sharing settings in a vendor's console are a policy choice whether or not anyone treated them as one.
The TRUTH Act: three duties for the department, one for the council
Section 7283.1 requires a department to do three things:
Give a written consent form before any ICE interview of a person in custody, explaining its purpose, that it is voluntary, and that the person may decline or have an attorney present.
Give the person a copy of every hold, notification or transfer request, and say whether the department intends to comply. If the department tells ICE a release date, it must give the same notice in writing to the person and to the person's attorney or designee.
Treat its records of ICE access as public records, "including all communication with ICE," subject to the Public Records Act's exemptions.
The fourth duty belongs to the council. Where a local law enforcement agency "has provided ICE access to an individual during the last year," the governing body of the city "shall hold at least one community forum during the following year, that is open to the public, in an accessible location, and with at least 30 days' notice" (§ 7283.1, subd. (d)). A regular council meeting can serve (§ 7283, subd. (a)), but only if it is noticed thirty days ahead. The Brown Act's seventy-two hours will not do.
"ICE access" is defined broadly. It includes responding to a hold, notification or transfer request, providing non-public release dates or addresses, allowing an interview, and providing probation or parole check-in times (§ 7283, subd. (d)). A department that follows the Values Act closely may provide none of these in a given year. But someone has to ask the question every January and write down the answer, because the forum obligation turns on it.
One open question matters to cities that contract with the sheriff. The forum duty falls on the governing body of a city "in which" a local law enforcement agency has provided ICE access, which reads as a question of where the access occurred, not whose officers provided it. We are not aware of a decision on the point. A contract city should ask its sheriff's station each year and keep the answer.
Two reports, due January 15
The Values Act requires two annual reports to the Department of Justice (§ 7284.6, subd. (c)), and Information Bulletin 25-02-CJIS sets January 15 as the date. The first covers any joint task force with a federal agency to which the department has "agreed to dedicate personnel or resources on an ongoing basis": its purpose, the agencies involved, total arrests, and arrests for immigration enforcement purposes. The Department of Justice reads "ongoing basis" to mean more than one interaction to discuss task force operations, which is a low threshold. The second covers transfers: how many people were transferred to immigration authorities in the calendar year, and the offense that permitted each.
Both reports are public records, and the 2027 filing falls two weeks after the SB 580 deadline.
What changes on January 1 on the police side
The 2026 session left the Values, TRUST and TRUTH Acts alone, but changed neighboring statutes that a department's manual has to reflect.
Facial coverings. Government Code section 7289, as rewritten by SB 1004 (Stats. 2026, ch. 757), now reads: "By January 1, 2027, a law enforcement agency operating in California shall maintain and publicly post a written policy regarding the use of facial coverings." The date had been July 1, 2026. An officer's exemption from the criminal penalty in Penal Code section 185.5 depends on the agency having posted that policy. A department that posted one last summer should compare it against the amended text, which changed the required exemptions. The companion policy on visible identification of sworn personnel (Gov. Code, § 7288) has been due since January 1, 2026.
Flash-bang grenades and breaching charges. SB 937 (Stats. 2026, ch. 754) adds flash-bang grenades to the crowd-control limits in Penal Code section 13652, and to the public summary a department must post within sixty days of each use. It also ties directly to the Values Act: flash-bang grenades may not be used "for the purposes of immigration enforcement" except as part of a joint task force or in compliance with section 7284.6, and new section 13652.2 sets the same rule for explosive breaching charges.
Vehicles and hiring. AB 1650 (Stats. 2026, ch. 741) requires, with exceptions, an agency decal on a rented vehicle used to detain, arrest or transport people, under rental contracts made on or after January 1, 2027 (Civ. Code, § 1939.36). AB 1627 (Stats. 2026, ch. 739) extends the peace-officer disqualification for serious misconduct in Government Code section 1029 to a former officer employed "by the federal government who engages in immigration enforcement."
The federal litigation over the mask and identification statutes concerns their application to federal officers. In United States v. California, the district court preliminarily enjoined the mask prohibition as to federal officers in February 2026, and no party appealed that ruling. The Ninth Circuit then directed a preliminary injunction against enforcing the identification requirement against federal agencies and officers (9th Cir. Oct. 14, 2026, No. 26-926). Neither ruling disturbs the sections that require agencies to post policies, and nothing in the case relieves a city department of its duty to post both.
What to do before January 1
Write the SB 580 policy so that it names the department, applies to its lobby, counters and records functions, and incorporates the department's immigration policy by reference. Do not restate the Values Act in the citywide policy; two texts drift.
Check the department's policy against the 2025 bulletin. It supersedes the 2018 bulletin that many manuals were written from.
Decide the local-policy questions on the record. Will the department answer notification requests? Allow custodial interviews? Which task forces does it sit on, and has anyone confirmed their primary purpose in writing?
Give the watch commander a written rule for federal operations in the city, and a number for the SB 580 designee that works at night.
Ask the TRUTH Act question now. Did the department provide ICE access to anyone in 2026? If so, calendar the 2027 forum and its thirty-day notice. If not, record the answer. Contract cities should ask the sheriff.
Calendar January 15 for the task force and transfer reports.
Audit the plate-reader sharing list against the department's written policy. Print it and date it.
Post the facial-covering policy by January 1 under amended section 7289, confirm the identification policy is posted, and update the crowd-control policy for SB 937.
For businesses and individuals
These statutes are written to public agencies, but they give the public something to hold. A person in local custody is entitled to a copy of any immigration request that names them, to be told whether the department will honor it, and to refuse an interview. A department's communications with ICE, its task force reports and its transfer counts are public records. A resident may put a verified written challenge to a department's facial-covering or identification policy, which starts a ninety-day period to cure. And in any year after the department has given ICE access to anyone, the council must hold a forum, on thirty days' notice, where the public may ask what happened.
