BILL ANALYSIS                                                                                                                                                                                                    �



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          CONCURRENCE IN SENATE AMENDMENTS
          AB 556 (Salas)
          As Amended September 5, 2013
          Majority vote 
           
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          |ASSEMBLY:  |70-0 |(May 16, 2013)  |SENATE: |37-0 |(September 9,  |
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           Original Committee Reference:    JUD.  

           SUMMARY  :  Prohibits employment discrimination against all active  
          duty military and veterans of the Armed Services.  Specifically,  
           this bill  :  

          1)Adds "military and veteran status," to the list of categories  
            protected from discrimination under the act by employers,  
            labor organizations and employment agencies with respect to  
            all aspects of employment and membership in a labor union. 

          2)Defines "military and veteran status" to mean a member or  
            veteran of the United States Armed Forces, United States Armed  
            Forces Reserve, the United States National Guard, and the  
            California National Guard.

          3)Provides that nothing in this bill shall be interpreted as  
            preventing the ability of employers to identify members of the  
            military or veterans for purposes of awarding a veteran's  
            preference as permitted by law.

           The Senate amendments  add chaptering out provisions regarding SB  
          292 (Corbett) of the current legislative session.
           
          EXISTING LAW  :  

           1)Protects, under the federal Uniformed Services Employment and  
            Reemployment Rights Act (USERRA), both active duty military  
            and veterans against discrimination by providing that a person  
            who is a member of, applies to be a member of, performs, has  
            performed, applies to perform, or has an obligation to perform  
            service in a uniformed service shall not be denied initial  
            employment, reemployment, retention in employment, promotion,  
            or any benefit of employment by an employer on the basis of  
            that membership, application for membership, performance of  








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            service, application for service, or obligation.  

          2)Provides, also pursuant to USERRA, that any person whose  
            absence from a position of employment is necessitated by  
            reason of service in the uniformed services shall be entitled  
            to specified reemployment rights and benefits and other  
            employment benefits of this chapter.  

          3)Protects, under state law, active duty military against  
            certain employment practices by providing that:  no person or  
            public entity or official shall discriminate against any  
            officer, warrant officer or enlisted member of the military or  
            naval forces of the state or of the United States because of  
            that membership, and that no member of the military forces  
            shall be prejudiced or injured by any person, employer, or  
            officer or agent of any corporation, company, or firm with  
            respect to that member's employment, position or status or be  
            denied or disqualified for employment by virtue of membership  
            or service in the military forces of this state or of the  
            United States.  

          4)Provides under state law that no employer or officer or agent  
            of any corporation, company, or firm, or other person, shall  
            discharge any person from employment because of the  
            performance of any ordered military duty or training or by  
            reason of being an officer, warrant officer, or enlisted  
            member of the military or naval forces of this state, or  
            hinder or prevent that person from performing any military  
            service or from attending any military encampment or place of  
            drill or instruction he or she may be called upon to perform  
            or attend by proper authority; prejudice or harm him or her in  
            any manner in his or her employment, position, or status by  
            reason of performance of military service or duty or  
            attendance at military encampments or places of drill or  
            instruction; or dissuade, prevent, or stop any person from  
            enlistment or accepting a warrant or commission in the  
            California National Guard or Naval Militia by threat or injury  
            to him or her in respect to his or her employment, position,  
            status, trade, or business because of enlistment or acceptance  
            of a warrant or commission.  

          5)Provides under state law that no private employer or officer  
            or agent of any corporation, company, or firm, or other  
            person, shall restrict or terminate any collateral benefit for  
            employees by reason of an employee's temporary incapacitation  








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            incident to duty in the National Guard or Naval Militia.  As  
            used in this subdivision, "temporary incapacitation" means any  
            period of incapacitation of 52 weeks or less.  

          6)Provides that a violation of the foregoing state laws is a  
            misdemeanor, and that any person violating any of the  
            provisions of this section shall be liable for actual damages  
            and reasonable attorney's fees incurred by the injured party.   


          7)Provides, under state law, that any employee of any  
            corporation, company, or firm, or other person, who is a  
            member of the reserve corps of the Armed Forces of the United  
            States or of the National Guard or the Naval Militia shall be  
            entitled to a temporary leave of absence without pay while  
            engaged in military duty ordered for purposes of military  
            training, drills, encampment, naval cruises, special exercises  
            or like activity as such member, providing that the period of  
            ordered duty does not exceed 17 calendar days annually  
            including time involved in going to and returning from such  
            duty.  

          8)Provides, also under state law that any public employee who is  
            a member of the reserve corps of the Armed Forces of the  
            United States or of the National Guard or the Naval Militia is  
            entitled to a temporary military leave of absence as provided  
            by federal law while engaged in military duty ordered for  
            purposes of active military training, inactive duty training,  
            encampment, naval cruises, special exercises or like activity,  
            providing that the period of ordered duty does not exceed 180  
            calendar days, including time involved in going to and  
            returning from that duty.  Specifies that a local public  
            agency may, but is not required to, provide paid military  
            leave of absence for periods of inactive duty training.  

          9)Provides that a covered employee has an absolute right to be  
            restored to the former office or position and status formerly  
            had by him or her in the same locality and in the same office,  
            board, commission, agency, or institution of the public agency  
            upon the termination of temporary military duty.  If the  
            office or position has been abolished or otherwise has ceased  
            to exist during his or her absence, he or she shall be  
            reinstated to a position of like seniority, status, and pay if  
            a position exists, or if no position exists the employee shall  
            have the same rights and privileges that he or she would have  








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            had if he or she had occupied the position when it ceased to  
            exist and had not taken temporary military leave of absence.  
          10)Establishes that any public employee who has been in the  
            service of the public agency from which the leave is taken for  
            a period of not less than one year immediately prior to the  
            date upon which a temporary military leave of absence begins,  
            shall receive the same vacation, sick leave, and holiday  
            privileges and the same rights and privileges to promotion,  
            continuance in office, employment, reappointment to office, or  
            reemployment that the employee would have enjoyed had he or  
            she not been absent therefrom; excepting that an uncompleted  
            probationary period, if any, in the public agency, must be  
            completed upon reinstatement as provided by law or rule of the  
            agency.  For the purposes of this section, in determining the  
            one year of service in a public agency all service of the  
            employee in recognized military service shall be counted as  
            public agency service.  

           FISCAL EFFECT  :  According to the Senate Appropriations  
          Committee, pursuant to Senate Rule 28.8, negligible state costs.

           COMMENTS  :  In support of the bill the author states:

               The bill raises the issues of discrimination, and  
               unfair employment practices against veterans and  
               members of the uniformed services (US military, US and  
               California National Guard). Current law provides  
               protections for several groups which have  
               traditionally been targeted and discriminated against.  
                These groups have traditionally been discriminated  
               against in many aspects of life, including employment.  
                In the spirit of equality and civil rights, fair  
               hiring practices are essential to ensuring everyone  
               has an opportunity to better their condition by  
               attaining a higher standard of living through  
               employment.  Current law doesn't provide sufficient  
               protections for Veterans, which comprise approximately  
               1.8 million of California's estimated 22.3 million  
               residents (according to CalVet).  Military members,  
               both active and reserve, and Veterans fall outside the  
               scope of comprehensive protections that exist within  
               the Fair Employment and Housing Act (FEHA).

          The author notes a number of recent media stories describing the  
          significant unemployment problems many veterans encounter.  For  








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          example, a recent Los Angeles Times article stated:

               Veterans' advocacy groups, and many unemployed  
               veterans, say civilian employers don't always  
               appreciate veterans' skills and maturity. They point  
               out that this is the first generation of employers who  
               have no widespread military experience and thus no  
               inherent appreciation for what the institution can  
               provide.

               Further, the increased military and media attention  
               given to post-traumatic stress disorder and traumatic  
               brain injury has had the effect of stigmatizing  
               veterans, advocates say. Some employers fear that  
               soldiers diagnosed with these conditions are prone to  
               violence or instability.

               The unemployment rate for veterans of Afghanistan and  
               Iraq is 10.3%, according to the Bureau of Labor  
               Statistics. For veterans age 24 and under, the rate is  
               29.1%, or 12 points higher than for civilians the same  
               age. That compares with 8.2% unemployment nationally,  
               and 7.5% for all veterans.

               A survey this year by the advocacy group Iraq and  
               Afghanistan Veterans of America found that a quarter  
               of its members could not find a job to match their  
               skill level, and half said they did not believe  
               employers were open to hiring veterans.

               "These veterans have skills and maturity a decade  
               beyond their civilian peers," said Tom Tarantino, the  
               group's deputy policy director, who couldn't find work  
               for 10 months after he left the Army in 2007. "It's  
               very frustrating for them to be told they have to  
               retrain for jobs they've already been trained for in  
               the military."  (Unemployment is a Special Challenge  
               for Veterans, Los Angeles Times, April 25, 2013.)

          This bill does not write on a blank slate.  Existing state and  
          federal law afford certain rights against employment  
          discrimination to both active duty military and veterans,  
          although not as broadly as this bill would provide.  For  
          example, veterans are protected against job discrimination under  
          the federal USERRA, but not under state law, which protects only  








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          active duty service members.  

          This bill is also broader in that it covers non-employers (labor  
          organizations and employment agencies) who may not be covered by  
          existing law.  (But see Haligowski v. Superior Court
          200 Cal.App.4th 983 (2011)(interpreting Military and Veterans  
          Code (MVC) Section 394 to be consistent with the FEHA in its  
          coverage of potential defendants by excluding liability of  
          individual supervisors ).)

          In one respect however this bill appears to be narrower than  
          existing law in that all employers are covered by existing law,  
          while only employers with five or more employees would be  
          covered by this bill.

          Existing federal and state law appear to cover the same types of  
          adverse employment actions, including harassment, as under this  
          bill, although this bill expressly covers job training programs  
          that do not appear to be expressly addressed by existing law,  
          although that coverage may be implicit.  This bill may be  
          broader however in that non-intentional "disparate impact"  
          discrimination is prohibited under the FEHA, but it does not  
          appear to be expressly outlawed currently.

          The bill also broadens existing law by making available the  
          services of the Department of Fair Employment and Housing (DFEH)  
          to the parties in disputes concerning alleged unlawful  
          discrimination.  The DFEH is charged with investigating and  
          making a determination regarding complaints of discrimination on  
          the basis of characteristics protected by the FEHA, and with  
          attempting to resolve those complaints where it can, and  
          prosecuting complaints where the DFEH determines that a  
          violation may have occurred.  

          Both state and federal law likewise provide for a private right  
          of action to enforce existing anti-discrimination protections,  
          as this bill would, although this bill requires filing with the  
          DFEH prior to suit, within one year of the discriminatory act,  
          and exhausting administrative procedures.  Existing state law  
          does not appear to provide an explicit statute of limitations  
          for unlawful discrimination against members of the military, nor  
          does it offer or require an administrative procedure.  Existing  
          federal and state law also authorizes recovery of attorney's  
          fees when a complaining party prevails, although not when the  
          complaining party loses.  This bill by contrast would subject  








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          complaining parties to potential exposure to attorney's fees  
          liability when they lose under the general rule of the FEHA.

          This bill would not displace these existing non-FEHA statutory  
          protections against military and veterans discrimination; it  
          would simply add military and veterans status as new protected  
          classes to the FEHA.  

          The author addresses the relationship with existing law as  
          follows:

               Although there are state and federal laws in place to  
               discourage employment discrimination, such  
               discrimination still persists. Active members of the  
               Military and National Guard, and those who are to be  
               activated, are protected from employment termination  
               based on their obligations. However, there are still  
               many instances where the burden of obligations is not  
               the direct cause of the express act of discrimination  
               or wrongful termination based on discrimination.  
               Current law has loopholes that need to be closed.  
               Additionally, there many of the situations outlined in  
               the Fair Employment and Housing Act that are not  
               covered under state and federal anti-military  
               discrimination laws. For example Non-Job related  
               inquiry can be used to circumvent the restrictions in  
               place against asking about disabilities, including  
               Post-Traumatic Stress Disorders and Traumatic Brain  
               Injuries. Other examples are the right to be free from  
               harassment and the right to be free from a hostile  
               anti-military work environment.    
                   
               Veterans of the United States Armed Forces are  
               currently not protected from discriminatory hiring  
               practices that may come as a result of incorrect  
               assumptions regarding the prevalence of Post-Traumatic  
               Stress Disorder, personality issues, insensitivity to  
               military culture, and because military applicants are  
               non-traditional applicants. Employers express concern  
               over military members stating that they are too  
               non-traditional, too old and will not take orders from  
               younger civilians, and that they have fallen behind  
               their civilian counterparts.    

               This Bill would remedy these injustices and would  








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               allow Veterans to attain or not attain employment  
               based solely on their merit instead of prejudice and  
               discrimination. 
                
               Veterans already have a difficult time readjusting to  
               civilian life from which they have been temporarily  
               displaced. In October of 2012, the unemployment rate  
               for young veterans in California Peaked at 43%. Many  
               Veterans returning from foreign conflicts of the past  
               decade are at risk of homelessness as a result of not  
               being able to secure steady employment. 
                       
               This bill would allow veterans to secure and maintain  
               employment without discrimination from employers, and  
               agents, or any other person. Rather than amending a  
               carbon copy of the Fair Employment and Housing Act  
               language into the Military and Veterans code,  
               including "military and veteran status" as a protected  
               group in FEHA would provide a more clear and  
               substantive framework for protecting Military and  
               Veterans from discrimination and harassment. Current  
               law regulating anti-military and veteran  
               discrimination is silent on discrimination by labor  
               organizations, employment agencies, apprenticeship  
               programs and any person or entity who aids, abets,  
               incites, compels, or coerces the doing of a  
               discriminatory act, as well as retaliation against  
               those who report.

          Both state and federal law entitle veterans to preferential  
          treatment in hiring for government jobs and promotions.  The  
          bill recognizes that this preference might otherwise be at odds  
          with a prohibition against discrimination, which would normally  
          tend to discourage employers from inquiring about a status or  
          characteristic which the employer is prohibited from  
          considering.  The bill addresses this issue by stating:   
          "Nothing in this section shall be interpreted as preventing the  
          ability of employers to identify members of the military or  
          veterans for purposes of awarding a veteran's preference as  
          permitted by law."

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










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