Recycling the 3120s Instead of Repurposing Them Violates the Act, the SDEP, and CDCR’s Grant-Recipient Obligations

California’s Department of Corrections and Rehabilitation (CDCR) is upgrading laptops issued to incarcerated students in college programs from Dell Latitude 3120 units to Dell Latitude 3140 units. Students are hopeful that the new laptops will better support coursework and digital-literacy practice—and that the storage problems that effectively limited them to only a few dozen megabytes of the allocated 5 GB will be resolved. Administrators plan to complete the transition before the Fall 2025 semester. During planning, incarcerated people and staff proposed repurposing the outgoing 3120 laptops to fulfill CDCR’s digital-literacy obligations to incarcerated people who are not enrolled in college classes. CDCR, however, chose to recycle the older devices. That choice artificially constrains access to digital-literacy training and, as explained below, violates the federal Digital Equity Act of 2021 (“the Act”), California’s State Digital Equity Plan (SDEP), and CDCR’s obligations as a grant recipient or subrecipient.

What the law and the state plan actually require

The Act directs states to center “covered populations” with historically lower rates of computer and internet use—including incarcerated individuals—when investing digital-equity funds. California’s SDEP operationalizes that mandate by making device access and digital-literacy training core, measurable objectives for implementation grants (CalDEP). In plain terms: state agencies and their subgrantees must expand device access and provide digital-skills training to covered populations, not contract those opportunities. California’s CalDEP guidelines explicitly authorize and expect activities such as digital-literacy training and targeted device programs designed around the needs of covered populations. :contentReference[oaicite:0]{index=0}

What the hardware change really means for learners

Dell’s Latitude 3140 is a newer generation education laptop built around Intel’s N-series processors (e.g., N100/N200) and faster LPDDR5X memory. Those components deliver a real bump for multitasking, web apps, and modern security features. By contrast, the outgoing Latitude 3120 relies on Intel Celeron/Pentium “Jasper Lake” chips and LPDDR4/DDR4 memory. Both lines are 11.6-inch, classroom-tough designs with similar displays and education-ready durability; both support modest internal storage, and both can run the basic productivity and training software that digital-literacy programs use. In short, the 3140 will feel snappier and more future-proof, but a properly imaged 3120 remains perfectly adequate for foundational digital-skills work such as typing, file management, email, web navigation, and office apps. :contentReference[oaicite:1]{index=1}

Step-by-step: why recycling the 3120s violates the Act, the SDEP, and grant-recipient obligations

First, the Act names incarcerated individuals as a covered population and requires that state digital-equity investments measurably benefit them. California’s SDEP adopts that mandate and sets goals that hinge on increasing device access and expanding digital-skills training. Choosing to recycle an inventory of working 3120 laptops—rather than redeploying them as training devices for incarcerated people who are not in college—artificially limits the number of learners who can participate in basic digital-literacy programming. That restriction moves in the opposite direction of the Act and the SDEP, which call for more access, more training, and measurable gains for covered populations. :contentReference[oaicite:2]{index=2}

Second, CalDEP grant guidance makes “digital-literacy training” and “targeted device programs” allowable and prioritized activities for implementation. A department that receives or participates in such funding has an obligation to use available assets to expand, not shrink, the pool of learners served. Repurposing the 3120s would directly advance these allowable activities at minimal marginal cost because the devices already exist, are purpose-built for education, and can be securely reimaged. Opting to recycle instead of redeploy undermines those allowable activities and defeats the state plan’s measurable objectives for covered populations inside correctional facilities. :contentReference[oaicite:3]{index=3}

Third, the performance delta between the 3140 and the 3120 is not a barrier to digital-literacy use cases. The 3140’s newer CPU and memory will help enrolled college students run heavier, more modern workloads. But the 3120’s specifications are sufficient for entry-level skill building—from learning file systems and safe browsing to composing documents and practicing online forms—especially in secured, curated environments. Discarding adequate hardware that could support those outcomes is a policy choice that suppresses participation numbers and depresses learning hours, undermining the very metrics that the SDEP and the Act expect agencies and grantees to improve. :contentReference[oaicite:4]{index=4}

A practical, compliant path CDCR could take instead

Compliance does not require perfection; it requires good-faith, measurable expansion of access. CDCR could pause recycling, factory-reimage and sanitize the 3120s, standardize a lightweight, storage-error-free build, and dedicate the devices to supervised digital-literacy labs for people not in college programs. That approach would align with the SDEP’s emphasis on device access and training, elevate outcomes for a covered population, and better position CDCR to meet reporting and performance expectations that attach to digital-equity funds.

Conclusion

Because the Digital Equity Act and California’s SDEP require agencies and their subgrantees to expand device access and digital-literacy training for covered populations—including incarcerated individuals—CDCR’s decision to recycle the outgoing Latitude 3120 laptops rather than repurpose them for non-college learners violates the Act, the SDEP, and CDCR’s grant-recipient obligations. The 3140 is the right choice for enrolled college students, but that upgrade does not justify discarding a fleet of education-ready 3120s that could—and should—be powering basic digital-skills training today. Redeployment, not recycling, is the lawful and equitable path.