BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 2517
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          Date of Hearing:   April 24, 2012

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                  Mike Feuer, Chair
                     AB 2517 (Eng) - As Amended:  April 16, 2012

                              As Proposed to be Amended
           
          SUBJECT  :  WAGE LIENS: CONSTRUCTION LABORERS AND CAR WASH WORKERS

           KEY ISSUES  :  

          1)SHOULD A NEW WAGE LIEN RIGHT BE CREATED FOR WORKERS IN THE CAR 
            WASH INDUSTRY IN ORDER TO ENSURE THAT THESE WORKERS ARE BETTER 
            ABLE TO ADDRESS THE LONGSTANDING PROBLEM OF UNPAID WAGES?

          2)SHOULD CONSTRUCTION LABORERS HAVE NEW RIGHTS UNDER THE 
            EXISTING MECHANICS LIEN LAW IN THE FORM OF EXPANDED TIME 
            PERIODS FOR ENFORCEMENT OF THEIR LIEN CLAIMS, PRIORITY OVER 
            OTHER LIENS, AND THE RIGHT TO RECOVER ATTORNEY'S FEES AND 
            COSTS OF RECORDING AND FORECLOSING ON THE LIEN?

           FISCAL EFFECT  :  As currently in print this bill is currently 
          keyed fiscal.

                                      SYNOPSIS

          In the continuing effort to prevent and remedy the problem of 
          wage theft, this bill would authorize a new wage lien against 
          the real and personal property of employers in the car wash 
          industry who unlawfully fail to pay wages due to their 
          employees.  In order to ensure that there are sufficient funds 
          available to satisfy these liens, the bill provides that these 
          liens would be entitled to higher priority than most other 
          liens.  As proposed to be amended, the bill would be limited to 
          a five-year pilot period.  Separately, the bill would also 
          revise the existing mechanics lien law to allow construction 
          laborers additional time to enforce their lien rights, 
          attorney's fees in legal actions, and higher priority over other 
          liens.  Supporters argue that these reforms are needed to 
          address longstanding problems of unpaid and uncollectable wages 
          for these workers in these industries.  Prior to recent 
          amendments, the wage lien provisions of the bill would have 
          applied to all employers.  A coalition of business interests 
          recorded strong opposition to the bill in that form, and 








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          presumably remain opposed despite the limited application of the 
          bill to the car wash industry.

           SUMMARY  :  Authorizes "wage liens" in the car wash industry 
          against the real and personal property of an employer for unpaid 
          wages for a five-year pilot period, and expands the rights of 
          construction laborers regarding mechanics lien under existing 
          law.  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 for a five-year 
            pilot period.

          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, except for real property used as 
               the employer's primary residence if the employer is a 
               natural person.

             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 
            the employee, employee representative, or the LC, who may 








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            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 the 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 and a purchase-money mortgage.

          14) Provides that the liens established by this bill shall have 
            equal priority to one another and that the funds resulting 
            from the sale of property that is subject to the lien shall be 
            divided proportionally among lien claimants if there are 
            insufficient funds to fully satisfy all perfected liens 
            arising under this chapter.

          15)Provides that an employee's lien is effective against the 
            employer, the estate of the employer, or a subsequent bona 








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            fide purchaser of the project subject to the employee's lien.

          16)Makes other related and conforming changes.

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

             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.

           EXISTING LAW  :  

          1)Grants laborers and materials suppliers a mechanic's lien on 
            any property improved by their labor or material.  (Cal. 
            Constit. Art. 14.)

          2)Generally specifies the obligations, rights, and remedies of 
            those involved in a construction project with regard to 
            mechanics liens and otherwise regulates the conditions under 
            which a mechanics lien may be enforced.  (Civil Code Sec. 8400 
            et seq.)

          3)Recognizes prejudgment wage liens against property as a remedy 
            in certain industries, including agriculture (on the crops 
            harvested) (Civ. Code § 3061.5-3061.6), logging (Civ. Code § 








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            3065), and mining (Cal. Civ. Code § 3060).

           COMMENTS  :  Employers are required by law to pay workers for 
          their labor.  Regrettably, there is a long history of 
          noncompliance toward lower-wage workers who are less able to 
          assert their rights, particularly in specific industries.  
          Moreover, even when these workers are able to overcome 
          substantial barriers and make their case in the legal system, 
          they are often left unable to enforce the court judgment because 
          of a variety of tactics by unscrupulous employers.  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 to 
          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 court judgments for unpaid wages.  
          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 dishonest employers 
          are able to hide their assets or declare bankruptcy well before 
          any final judgment is issued - effectively denying the aggrieved 
          workers any ability to collect on their judgments for unpaid 
          wages.  The situation has been described by many advocates as a 
          worker having a judgment that is not worth the paper upon which 
          it is printed.

          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.








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               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 
               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.

           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 that 








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          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.  (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).)

          Another study 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.  (Milkman, Gonzalez and 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).)

          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.

          The survey estimated that, in a given week, 654,914 workers in 
          Los Angeles County suffer at least one pay-based violation.  
          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.

          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,








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               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.

          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 Reynolds v. Bement, 36 Cal. 4th 1075, 1093-94 (2005) 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."  The new 
          accounts then become unreachable under the judgment "because of 
          the legal fiction that the predecessor and successor are 
          separate legal entities."

          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.

          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.  This prejudgment wage lien rights operate in the 








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          construction industry as well as agriculture, timber, and 
          mining.  

          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.
           
           The prejudgment nature of the proposed wage lien has been the 
          subject of controversy and confusion.  Supporters note that 
          workers must prove in court or before the Labor Commissioner 
          that they are owed wages to enforce the wage lien under this 
          bill.  The wage lien is simply a security interest - a 
          placeholder - that protects workers during the time it takes to 
          decide if a wage claim is valid.  Supporters argue that such 
          prejudgment liens have long existed in California and other 
          states, and do not cause undue burdens on businesses.  They 
          contend that wage liens do not interfere with business or 
          commerce but simply maintain the status quo during the time it 
          takes a case to be decided by a court.  The lien is essentially 
          a piece of paper filed with a government agency that gives 
          notice that an employee may have a claim against certain 
          property if his/her claim is proven. As with other prejudgment 
          wage liens, supporters contend, workers would be required to 
          take action to enforce this lien.  If the worker does not go to 
          court or the Labor Commissioner within a year of filing the lien 
          to prove that he or she is actually owed wages, the lien is 
          automatically extinguished.  Likewise, supporters argue, if the 
          worker fails to prove that he or she is owed wages, the lien is 
          automatically extinguished.  Supporters note that many 
          businesses already operate with significant liens placed against 
          them by a variety of creditors without experiencing interference 
          with normal operations.  For example, creditor liens against 








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          business property may be recorded as UCC Financing statements or 
          deeds of trust. 

           Other States Reportedly Have Longstanding Wage Lien Laws Similar 
          To But Broader Than That Proposed By This Bill.   Supporters of 
          this bill report that a number of other states have wage lien 
          laws that date back more than 100 years.  Among the states with 
          liens that are substantially similar to AB 2517, in that they 
          are broadly-applicable to all employer property and all 
          employees, enjoy super-priority over other liens, and attach 
          prior to judgment are the following: Wisconsin Statutes § 
          109.09(2); Georgia Code § 44-14-380; and Ohio Revised Code § 
          1311.34.


          Other states with reportedly broad, prejudgment, super-priority 
          wage liens that are more targeted include Tennessee (Tenn. Code 
          § 66-13-101) (limited to corporate or partnership employers) and 
          Indiana (Indiana Code § 32-28-12-1 (limited to corporate 
          employers).  Additionally, some states have prejudgment wage 
          liens applying to a variety of industries, from construction 
          laborers and factory workers to hotel, restaurant and garment 
          workers. See, e.g., Alaska Stat. § 34.35.435 et. seq., 43 
          Pennsylvania Statutes and Consolidated Statutes § 221, Revised 
          Code of Washington 60.34.10, Florida Statutes § 713.56.  

           Recent Amendments Narrow This 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, 








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          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 
          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.

           Mechanics Lien Law Changes Proposed By This Bill.  Separately 
          from the wage lien provisions for the car wash industry, this 
          bill also proposes some changes related to California's general 
          mechanics lien law applicable to construction works of 
          improvement.

          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 








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          those involved in a construction project.  

          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).)

          Expanded Time For Laborers to Enforce Mechanics Liens.  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 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."

          Recovery of Attorney's Fees.  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 








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          laborer cannot afford an attorney when, on average, their claims 
          may amount to only several hundred dollars at the most.

          Preference Over Other Liens.  Finally, this bill provides that 
          the lien of a laborer will have higher priority than 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, 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).

           ARGUMENTS IN OPPOSITION  :  As originally introduced this bill 
          established the "wage lien" as a tool for employees in all 
          industries and occupations.  In that form, 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 
               almost all other liens or judgments, including mortgages?.
          
               Despite the undeniable complexity of wage and hour law in 








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               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 
               lien be recorded.  

               Article 1, Section 9 of California's Constitution states 








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               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.

           Author's Further Narrowing Amendments.  In response to 
          opposition concerns, the author offers further narrowing 
          amendments as follows:

          1)Allow purchase money mortgages to have priority over wage 
            liens.
          2)Exempt real property occupied as the employer's primary 
            residence where the employer is a natural person.
          3)Clarify that wage liens under this bill have equal priority as 
            against other such wage liens, and that funds are to be 
            divided proportionally among claimants if there are 
            insufficient proceeds to fully satisfy all lien claims.
          4)Five-year sunset on wage liens
           
          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








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          The Wage Justice Center
          Women's Employment Rights Clinic of Golden Gate University 
          School of Law
          Worksafe, Inc.

           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  :   Kevin G. Baker / JUD. / (916) 319-2334 










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