BILL ANALYSIS                                                                                                                                                                                                    Ó




                                                                  AB 2517
                                                                  Page A
          Date of Hearing:   April 18, 2012

                     ASSEMBLY COMMITTEE ON LABOR AND EMPLOYMENT
                                Sandre Swanson, Chair
                     AB 2517 (Eng) - As Amended:  April 16, 2012
           
          SUBJECT  :   Employment: payment of wages: liens.

           SUMMARY  :   Authorizes "wage liens" in the car wash industry 
          against the real and personal property of an employer for unpaid 
          wages, and makes changes to existing mechanics lien law, as 
          specified.  Specifically,  this bill  :

          1)Provides that the following provisions related to "wage liens" 
            apply only to employees and employers in the "car washing and 
            polishing" industry as that term is defined.

          2)Provides that an employee, employee representative, or the 
            Labor Commissioner (LC) may file a lien for the amount of 
            unpaid wages, other compensation and related penalties and 
            damages owed on all of the following:

             a)   Real or personal property owned by the employer that is 
               located within the state.

             b)   Real or personal property that is located within the 
               state upon which the employee performed work or for which 
               the employee furnished materials, as specified.

          3)Provides that a lien upon real property shall be recorded with 
            the county recorder where the property is located, as 
            specified.

          4)Provides that a lien upon personal property shall be recorded 
            with the Secretary of State, as specified.

          5)Specifies that the lien attaches to all personal property 
            owned by the employer or subsequently acquired by the 
            employer, whether tangible or intangible.

          6)Specifies that a lien may be filed at any time before the 
            expiration of the statute of limitations for the wage claim 
            the lien would enforce.

          7)Provides that an action to enforce a lien may be brought by 









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            the employee, employee representative, or the LC, who may 
            recover court costs and reasonable attorney's fees in a 
            successful action to enforce the lien.

          8)Requires an employee, in order to enforce a lien, to 
            demonstrate that he or she is owed wages or other compensation 
            and any related penalties damages.  This determination may be 
            made by a court or by the LC in an administrative hearing 
            (known as a "Berman" hearing).

          9)Specifies that if a lien is recorded and an action to recover 
            wages has already been filed, that action shall also be deemed 
            an action to enforce the lien upon any property subject to the 
            recorded lien.  If there is a judgment, the court may order 
            the sale at a public auction, or the transfer to the plaintiff 
            of title or possession, of any property subject to the lien.

          10)Specifies that if judgment is entered in favor of the 
            employer or if the case is dismissed with prejudice, any 
            applicable lien shall be extinguished upon expiration of the 
            appeals period if no appeal is filed.  If an appeal is filed, 
            the lien shall continue in force until all issues have been 
            decided.

          11)Specifies that if the lien is extinguished, upon demand and 
            15 days' notice by any affected party, the lienholder shall 
            file a release of the lien in the manner set forth under 
            current law.

          12)Provides that to enforce the lien, an action shall be brought 
            within one year of the recording of the lien.

          13)Provides that the lien established by this bill takes 
            precedence over all other debts, judgments, decrees, liens or 
            mortgages perfected on or after January 1, 2013 except a tax 
            lien.

          14)Provides that an employee's lien is effective against the 
            employer, the estate of the employer, or a subsequent bona 
            fide purchaser of the project subject to the employee's lien.

          15)Makes other related and conforming changes.

          16)Makes the following changes to existing law related to 
            mechanic lien law generally:









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             a)   Provides that a "laborer" (as that term is defined under 
               current law) may file a lien before the earlier of (1) one 
               year after completion of the work of improvement, or (2) 
               one hundred eighty days after the owner records a notice of 
               completion or cessation.

             b)   Provides that lien on behalf of a "laborer" shall be 
               preferred to any lien, mortgage, deed of trust, or other 
               encumbrance upon the work of improvement or the site, 
               regardless of whether it attached prior to or subsequent to 
               the laborer's lien.  However, the lien shall not take 
               precedent over a pre-existing lien, mortgage, deed of 
               trust, or other encumbrance that was recorded prior to 
               commencement of the labor or services if the laborer is 
               shown to have had actual knowledge of it prior to providing 
               labor or services.

             c)   Provides that a "laborer" shall be entitled to court 
               costs and attorneys' fees incurred as a result of recording 
               and foreclosing on a lien.  Upon award, these amounts shall 
               be considered part of the lien and shall relate back to the 
               date of recording of the lien.

           FISCAL EFFECT  :   Unknown

           COMMENTS  :  This bill attempts to address an issue that the 
          Legislature has struggled with for many years, if not decades - 
          how to ensure that workers (particularly low-wage workers) have 
          a meaningful opportunity collect on judgments issued in their 
          favor for unpaid wages.

          Over the years, the Legislature and state enforcement agencies 
          have enacted a number of tools and approaches intended to assist 
          workers in collecting on such judgments.  However, by their very 
          nature, such tools and approaches are generally limited to 
          post-judgment relief (once a final order has been issued and 
          there is no opportunity to appeal).  The unfortunate reality for 
          many workers is that unscrupulous employers are able to hide 
          their assets or declare bankruptcy well before any final 
          judgment is issued - denying the aggrieved worker any ability to 
          collect on their judgments for unpaid wages.  The situation has 
          been described by many advocates as a worker having a piece of 
          paper that represents a judgment in their favor that is in fact 
          not worth the paper upon which it is printed.









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           Brief Background on Wage Claims and Collections 

          Various recent studies have highlighted concerns about alleged 
          widespread "theft of wages" in the United States and in 
          California, particularly in the underground economy.

          For example, in 2009 the Ford Foundation sponsored a study<1> 
          that surveyed 4,387 workers in low-wage industries in the three 
          largest U.S. cities - Chicago, Los Angeles and New York City.  
          The study revealed that 26 percent of workers in the sample were 
          paid less than the legally required minimum wage, and 60 percent 
          of these workers were underpaid by more than $1 per hour.  In 
          addition, 76 percent of the respondents who worked overtime in 
          the previous week were not paid the legally required overtime 
          rate by their employers.

          Another study<2> focused on a survey of 1,815 workers in Los 
          Angeles County.  The survey found that low-wage workers in Los 
          Angeles regularly experience violations of basic laws that 
          mandate a minimum wage and overtime pay and are frequently 
          forced to work off the clock or during their breaks.  Other 
          violations documented in the survey include lack of required 
          payroll documentation, being paid late, tip stealing and 
          employer retaliation.
          The survey also revealed that the various forms of nonpayment 
          and underpayment of wages take a heavy monetary toll on workers 
          and their families.  Respondents who experienced a pay-based 
          violation in the previous work week lost an average of $39.81 
          out of average weekly earnings of $318.00 (or 12.5 percent).  
          Assuming a full-year work schedule, these workers lost an 
          average of $2,070.00 annually out of total earnings of 
          $16,536.00<3>.

          The survey estimated that, in a given week, 654,914 workers in 
          Los Angeles County suffer at least one pay-based violation.  
          ---------------------------
          <1> "Broken Laws, Unprotected Workers: Violations of Employment 
          and Labor Laws in America's Cities."  Center for Urban Economic 
          Development, National Employment Law Project, UCLA Institute for 
          Research on Labor and Employment (2009).
          <2> Milkman, Ruth, Ana Luz Gonzalez and Victor Narro.  "Wage 
          Theft and Workplace Violation in Los Angeles: The Failure of 
          Employment and Labor Law for Low-Wage Workers."  UCLA Institute 
          for Research on Labor and Employment (2010).
          <3>  Id  . at 4.








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          Extrapolating from this figure, front-line workers in low-wage 
          industries lose more than $26.2 million per week as a result of 
          employment and labor law violations<4>.
          The authors of the report underscored the economic impact of 
          these violations as follows:

               "Wage theft not only depresses the already meager earnings 
          of low-wage workers,
               it also adversely impacts their communities and the local 
          economies of which they
               are part.  Low-income families spend the bulk of their 
          earnings on basic necessities
               like food, clothing and housing.  Their expenditures 
          circulate through local economies,
               supporting businesses and jobs.  Wage theft robs local 
          communities of this spending
               and ultimately limits economic growth<5>."

          This problem is exacerbated by the fact that many workers, even 
          if they file a claim and obtain a judgment, are unable to 
          collect against their employer or former employer - particularly 
          if the employer is "savvy" enough to move or hide their assets 
          to avoid collection.

          In a 2005 case, former California Supreme Court Justice Moreno 
          perhaps accurately summarized the situation when he observed, 
          "Ŭe]mployers faced with large wage judgments often play the 
          'shell game'-that is, they close down one corporation and start 
          up another."<6> The new accounts then become unreachable under 
          the judgment "because of the legal fiction that the predecessor 
          and successor are separate legal entities."<7>

          For many years, the Franchise Tax Board (FTB) was charged with 
          pursuing wage claims that had been adjudicated against employers 
          by the Division of Labor Standards Enforcement (DLSE).  In 2004, 
          the Bureau of State Audits audited the FTB collection activities 
          and found that they resulted in full or partial payments on only 
          20 percent of wage judgments issued after a Labor Commissioner 
          hearing.  Moreover, the audit found that FTB took more than a 
          year to process claims on average.
          ---------------------------
          <4>  Id  . at 53.
          <5>  Id  . at 54.
          <6> Reynolds v. Bement, 36 Cal. 4th 1075, 1093-94 (2005) 
          (Moreno, J., concurring) (internal quotations omitted).
          <7> Id.








                                                                  AB 2517
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          Subsequently, the Department of Industrial Relations (DIR) 
          established its own internal collections unit to pursue 
          collections of unpaid wage judgments.  Worker advocates have 
          alleged that with limited resources, the DIR collections unit 
          has not significantly improved the prospects for workers to 
          collect unpaid wages.

           Solution Proposed by This Bill - The "Wage Lien"  

          Current California law provides a prejudgment "lien" as a tool 
          for certain classes of employees to recover unpaid wages in 
          certain limited circumstances.  However, the sponsors of this 
          bill contend that, under current California law, only 
          construction workers and farmer workers are entitled to 
          prejudgment liens for unpaid wages.  Moreover, the current liens 
          have unreasonably short time frames: 90 days after the work 
          stops to file the lien and 90 subsequent days to file an action 
          to enforce it.

          The sponsors contend that liens are a proven and longstanding 
          remedy.  Liens are commonly used by banks loaning money to 
          businesses to ensure the loans get paid back.  They are also 
          used by lawyers to secure their fees, doctors who treat patients 
          without upfront payment (e.g., for treatment that is to be paid 
          from workers' compensation insurance), hospitals, construction 
          contractors, architects, dry cleaners, hotels, landlords, 
          storage facilities, tax authorities and many others seeking to 
          ensure payment.

          The sponsors therefore argue that workers should have the same 
          access to liens.  Although wage earners lack the bargaining 
          power to demand voluntary liens as a condition of accepting a 
          job, the legal system can and should level the playing field by 
          giving wage earners the same protection as others who provide 
          services.

          Finally, the sponsors state that wage liens are 
          well-established.  Wage liens were a common remedy in the 
          nineteenth and early twentieth century, and many states in fact 
          have numerous wage liens on the books (these liens are typically 
          too out-of-date to be useful to modern workers). California is 
          an exception. It has very few wage liens on its books -- only 
          those for construction workers and agricultural workers.










                                                                  AB 2517
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           Recent Amendments Narrowing the Bill to the Car Wash Industry  

          As introduced, this bill would have afforded workers in any 
          industry in California the ability to pursue a "wage lien."  As 
          discussed below, that language generated widespread opposition 
          from employer groups - for a number of reasons.

          The author recently amended the bill to limit these wage lien 
          provisions to the "car washing and polishing" industry.  
          California leads the nation in both the number of car washes and 
          number of employees employed by car washes.  There are more than 
          1600 car washes and more than 22,000 employees respectively.  

          This industry is one that has been plagued by allegations of 
          worker exploitation in recent years.  In March 2008 the  Los 
          Angeles Times  reported the results of an investigation of the 
          carwash industry finding that many owners pay less than half of 
          the required minimum wage and that two-thirds of those inspected 
          by the state since 2003 were out of compliance with one or more 
          labor laws.  Some violations included underpaying workers, 
          hiring minors, operating without workers' compensation insurance 
          and denying workers their meal and rest breaks.

          As a result of these and earlier reports, the Legislature 
          responded with attempts to regulate the industry in an attempt 
          to protect workers.  In 1999, SB 1097 (Hayden) (which sought to 
          regulate the car wash industry) was vetoed by Governor Davis.  
          In his veto message the Governor said, in part: "I am vetoing 
          this bill I do not believe that the need to register car washes 
          with the Labor Commissioner has been demonstrated.  I am however 
          asking the Director of Industrial Relations (DIR) to review the 
          activities of the car washing industry and make any and all 
          appropriate recommendation to me by June 30, 2001."
           
          In response to the Governor's veto directive, DIR filed an 
          internal report about labor law violations in the industry and 
          possible remedies, considering limited resources and widespread 
          violations that affect other industries in the state.  
          Additionally, in early 2003, DIR conducted a coordinated 
          enforcement sweep of the car washing and polishing industry in 
          the Los Angeles area finding numerous labor law violations, 
          collecting back wages and penalties due, totaling over $250,000.
           
          As a result of proven violations in this industry AB 1688 
          (Goldberg) "The Car Wash Worker Bill" was signed into law and 









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          took effect on January 1, 2004.  AB 1688 contained a sunset date 
          of January 1, 2007.  The final car wash regulations were 
          promulgated by DIR and finally adopted by The Office of 
          Administrative Law December 2005.

          SB 1468 (Alarcon) of 2006 extended the sunset date relating to 
          the regulation of the car washing and polishing industry to 
          January 1, 2010.  AB 236 (Swanson) of 2010 extended the sunset 
          date to January 1, 2014.

          As stated above, the recent amendments to this bill limit the 
          "wage lien" provisions to the car washing and polishing 
          industry. 


           Mechanics Lien Law and Changes Proposed By This Bill

           This bill also proposes some changes related to California's 
          general mechanics lien law.

          The California Constitution grants laborers and materials 
          suppliers a mechanics lien on any property improved by their 
          labor or material.  The mechanics lien law in the Civil Code 
          generally specifies the obligations, rights, and remedies of 
          those involved in a construction project.  Mechanics liens are 
          not available on public works of improvement.  However, the 
          mechanics lien law in the Civil Code provides claimants on 
          public works projects with other statutory remedies, including 
          stop notices and claims against payment bonds.

          This bill proposes three changes that would apply to mechanics 
          liens filed by "laborers" as that term is defined under current 
          law.  Civil Code Section 8024(a) defines a "laborer" as a person 
          who, acting as an employee, performs labor upon, or bestows 
          skill or other necessary services on, a work of improvement.  
          "Laborer" also includes a person or entity to which a portion of 
          compensation is paid by agreement with the laborer or the 
          collective bargaining agreement of that laborer.  Civil Code 
          Section 8024(b).

          First, current law generally requires a mechanic lien to be 
          recorded before the earlier of either (1) 90 days after 
          completion of the work of improvement, or (2) 30 days after the 
          owner records a notice of completion or cessation.  This bill 
          would provide that a "laborer" may file a lien before the 









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          earlier of (1) one year after completion of the work of 
          improvement, or (2) one hundred eighty days after the owner 
          records a notice of completion or cessation.  Supporters contend 
          that, unlike contractors, "laborers are typically unaware of 
          their right to file a mechanics lien and are taken advantage of 
          by subcontractors who purposely string them along until it is 
          too late to do anything.  Day laborers often wait several months 
          to seek legal help because they hope that the subcontractor that 
          hired them will eventually pay.  The subcontractor makes 
          promises to pay the back wages, plus more, if the laborer will 
          just wait one more week, month, etc. The subcontractor claims 
          that he is about to get a big job and will hire the laborers on 
          the new job, it they just wait.   Ninety days is an extremely 
          short time period for someone who is unsophisticated about the 
          legal system and the business world."

          Second, this bill provides that a "laborer" shall be entitled to 
          the court costs and attorney's fees incurred as a result of 
          recording and foreclosing on the lien.  Upon award of these 
          amounts, they shall be deemed part of the lien and shall relate 
          back to the date of the recording of the lien.  Again, the 
          supporters of this bill contend that, unlike contractors, 
          laborers claims are often relatively small, and thus, it is 
          impossible for them to find legal assistance to enforce the 
          lien.  A contractor can and will hire an attorney to collect on 
          a significant job.  However, they contend that a laborer cannot 
          afford an attorney when, on average, their claims may amount to 
          only several hundred dollars at the most.

          Finally, this bill provides that the lien of a "laborer," 
          preferred to any lien, mortgage, deed of trust, or other 
          encumbrance upon the work of improvement or the site, regardless 
          of whether it attached prior to or subsequent to the laborer's 
          lien.  However, the lien shall not take precedent over a 
          pre-existing lien, mortgage, deed of trust, or other encumbrance 
          that was recorded prior to commencement of the labor or services 
          if the laborer is shown to have had actual knowledge of it prior 
          to providing labor or services.  Supporters argue that this 
          final provision is needed because laborers, unlike contractors, 
          are not in a position to assess the financial viability of a 
          construction project or the encumbrances on the property prior 
          to accepting a job.  Moreover, the amount of wages claimed is 
          typically quite small relative to other encumbrances and claims, 
          so other creditors will not be completely denied their rights to 
          payment by giving laborers priority.  If, on the other hand, 









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          banks take priority, there is often nothing left to pay laborers 
          after the bank recoups hundreds of thousands of dollars pursuant 
          to its lien.  As a result, workers end up with nothing.  
          Supporters contend that California law already recognizes this 
          and allows for super-priority for liens for agriculture workers 
          (Civil Code Section 3061.5(b)) and loggers (Civil Code Section 
          3065).

           COMMITTEE STAFF COMMENT  :  Mechanics lien law is a complex area 
          of the law that has been subject to significant legislative 
          activity in recent years.  This area of the law is traditionally 
          under the jurisdiction of the Assembly Judiciary Committee.  
          This bill has been double-referred to the Assembly Judiciary 
          Committee, so a more thorough discussion of the changes related 
          to mechanics lien law (and any potential ramifications 
          therefrom) may be more appropriate to discuss before that 
          committee. 

           ARGUMENTS IN SUPPORT  :

          According to the author:

               "California has one of the highest rates of wage theft in 
               the country. For example, 30 percent of low wage workers in 
               Los Angeles are paid less than minimum wage; nearly 80 
               percent are not paid proper overtime. A worker filing a 
               claim for unpaid wages at the Labor Commissioner's office 
               typically must wait more than a year for a decision. 
               Likewise, workers filing claims in the state civil court 
               must typically wait at least a year to get a trial. This 
                                                 time lag means that unscrupulous employers can dissolve the 
               old business entity and create new corporate forms under a 
               different name, often while still operating the same type 
               of business at the same address. Further, under current 
               law, if a business files for bankruptcy while a wage claim 
               is pending, the workers' claim will typically be lost.

               Even after winning a judgment, California workers cannot 
               collect their wages, because the state lacks an effective 
               mechanism for enforcing wage judgments. California's Bureau 
               of State Auditors found in 2004 that collections by the 
               state's primary collections agency (the Franchise Tax 
               Board), result in payments on only 20 percent of wage 
               judgments issued after a Labor Commissioner hearing.  These 
               are cases that the workers won, proving he or she was owed 









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               wages. Nonetheless, 80% of the claims went uncollected. 
               Uncollected wage judgments hurt the state budget, because 
               they constitute lost opportunities to collect fines and 
               penalties that would go into the state's General Fund.

               Liens are a proven and longstanding remedy to address wage 
               theft.  For example, California's longstanding mechanics' 
               lien, which is currently available only to construction 
               workers and contractors, is a proven, cost-effective, and 
               widely used remedy for building contractors. Similar liens 
               are also commonly used by banks loaning money to 
               businesses, lawyers seeking to secure payment of their 
               fees, architects, storage facilities, tax authorities and 
               many others seeking to ensure payment."

          Similarly, other supporters argue that the wage lien is a 
          proven, simple legal tool that costs the state nothing.  It 
          creates no new bureaucracies and no new agencies with 
          complicated enforcement procedures. Instead, workers simply file 
          with the County Recorder or Secretary of State and pay a $10 to 
          $30 filing fee.  The worker can foreclose (through a legal 
          process that provides protections for the accused employer) on a 
          delinquent employer, just as a bank does on a mortgage, a 
          creditor on an outstanding debt, a lawyer on unpaid retainer 
          fees, a hospital on unpaid medical costs, a construction 
          contractor, an agricultural worker, an architect, a dry cleaner, 
          a hotel, a landlord, storage facilities, and many more.  
          Supporters argue that such a streamlined, cost-effective, common 
          tool to enforce wages is long overdue in California.

           ARGUMENTS IN OPPOSITION  :

          As mentioned above, as originally introduced, this bill 
          established the "wage lien" as a tool for employees in all 
          industries and occupations.  A large coalition of employer 
          groups submitted a lengthy opposition letter which, among other 
          things, stated the following:

               "ŬThis bill] would cripple California businesses by 
               allowing any employee, employee representative, or the LC 
               to file super priority liens on an employer's real property 
               or any property where an employee has performed work for an 
               alleged, yet unproven wage claim.  This bill would 
               essentially destroy commercial and personal real estate as 
               Ŭthis bill] would allow a wage lien to take precedent over 









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               almost all other liens or judgments, including mortgages?
          
               ?Despite the undeniable complexity of wage and hour law in 
               this state, Ŭthis bill] would allow any employee, employee 
               representative, or the LC to file a lien against the 
               employer's real property simply on the basis that the 
               employee believes he or she has a valid wage claim against 
               the employer.  At the time of filing the lien, the employee 
               would have no burden to provide any actual evidence that 
               the employer violated any wage and hour law?

               ?ŬThis bill] will also basically destroy commercial 
               investments or lending in California as well as personal 
               home loans.  Specifically, Ŭthis bill] would give a wage 
               lien priority over any other lien, except a tax lien.  This 
               means that first mortgages on real property would be 
               secondary to an alleged wage claim.  The direct result of 
               such a requirement would basically end commercial 
               investment and real estate in California.  It is impossible 
               to imagine that a financial lender would provide a mortgage 
               on real property if its interest in that property could be 
               surpassed at any time by a wage lien.  Moreover, given that 
               Ŭthis bill] allows an employee to file a lien on any real 
               property where work was performed, this could directly 
               impact personal homeowners as well.  For example, a 
               technician that does electrical installation, such as cable 
               or internet in a home, could file a wage lien under Ŭthis 
               bill] on that home because that is the site where work was 
               performed.  The real estate market in California is still 
               struggling from the recession.  If Ŭthis bill] is enacted, 
               it will basically eliminate any opportunity for recovery, 
               thereby destroying jobs in California?.
          
               ?This bill will negatively impair an employer's opportunity 
               to seek future financing that is secured against the 
               residential real property?This will preclude an employer 
               from being able to refinance their mortgage or secure a 
               home equity line of credit, even in the event of an 
               emergency.  The employer will not be able to expand or hire 
               new employees due to the inability to secure financing to 
               do so.  In short, no lender is going to extend a loan to 
               someone with a super-lien placed on their real or person 
               property.  Finally, under Ŭthis bill], it is unclear 
               whether there will be sufficient disclosure by the LC 
               informing employers of the ramifications should a super 









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               lien be recorded.  

               Article 1, Section 9 of California's Constitution states 
               the following: "A bill of attainder, ex post facto law, or 
               law impairing the obligation of contracts may not be 
               passed."  The Constitution of the United States declares in 
               Article I, Section 10, that "No state shall enter into any 
               treaty, alliance, or confederation; grant letters of marque 
               and reprisal; coin money; emit bills of credit; make 
               anything but gold and silver coin a tender in payment of 
               debts; pass any bill of attainder, ex post facto law, or 
               law impairing the obligation of contracts, or grant any 
               Title of Nobility."

               With respect to Ŭthis bill's] creation and recordation of a 
               super lien for the payment of unpaid wages, the measure 
               creates a violation of the terms of the mortgage or deed of 
               trust for any prospective mortgage contract after the 
               bill's enactment.  The measure impairs the obligation of 
               the mortgage contract in violation of the state and federal 
               constitutions."

          Again, this opposition was submitted regarding the introduced 
          version of the bill.  It is not clear whether opponents continue 
          to have the same concerns to the bill in its recently-amended 
          form (limited to the car washing and polishing industry).  
          However, out of an abundance of caution, the original opposition 
          arguments are included here. 

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Employment Lawyers Association
          California Immigrant Policy Center
          California Labor Federation, AFL-CIO
          California Rural Legal Assistance Foundation
          CLEAN Car Wash Campaign
          Jewish Labor Committee, Western Region
          Maintenance Cooperation Trust Fund
          National Day Laborer Organizing Network
          The Wage Justice Center
          Women's Employment Rights Clinic of Golden Gate University 
          School of Law
          Worksafe, Inc.









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           Oppose unless amended

           California Land Title Association
           
          Opposition 
           
          American Council of Engineering Companies California
          Associated Builders and Contractors of California
          Associated General Contractors
          Building Owners and Managers Association of California
          California Association for Health Services at Home
          California Association of Bed & Breakfast Inns
          California Association of Health Facilities
          California Attractions and Parks Association
          California Bankers Association
          California Building Industry Association
          California Business Properties Association
          California Chamber of Commerce
          California Chapter of the American Fence Association
          California Farm Bureau Federation
          California Fence Contractors' Association
          California Grocers Association
          California Hotel & Lodging Association
          California Independent Grocers Association
          California League of Food processors
          California Manufacturers and Technology Association
          California Mortgage Bankers Association
          California Restaurant Association
          California Retailers Association
          Engineering Contractors' Association
          Flasher Barricade Association
          International Council of Shopping Centers
          Marin Builders Association
          NAIOP of California, the Commercial Real Estate Development 
          Association
          Western Growers Association

           
          Analysis Prepared by  :    Ben Ebbink / L. & E. / (916) 319-2091