BILL ANALYSIS                                                                                                                                                                                                    Ó



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          Date of Hearing:  June 28, 2016 


                           ASSEMBLY COMMITTEE ON JUDICIARY


                                  Mark Stone, Chair


          SB  
          1065 (Monning) - As Amended March 28, 2016


                              As Proposed to be Amended

          SENATE VOTE:  26-9


          SUBJECT:  PETITIONS TO COMPEL ARBITRATION: APPEALS


          KEY ISSUE:  IN ORDER TO ALLOW VICTIMS OF ELDER ABUSE TO  
          VINDICATE THEIR RIGHTS IN COURT, SHOULD AN APPEAL OF AN  
          INTERLOCTUTORY ORDER DENYING A PETITION TO COMPEL ARBITRATION BE  
          EXPEDITED IN CASES WHERE THERE ARE CLAIMS OF ELDER ABUSE AND  
          WHERE THE ELDER HAS BEEN GRANTED A TRIAL PREFERENCE BECAUSE OF  
          FAILING HEALTH?


                                      SYNOPSIS


          According to the author, when there is an allegation of elder  
          abuse in a nursing home and the elder abuse victim is granted a  
          speedy trial preference, it is routine for a defendant nursing  
          home to file a motion to compel arbitration as a way to avoid  
          jury trial or to stall litigation proceedings.  Because appeals  
          take anywhere from one to two years, the victim of elder abuse  
          may very likely die while awaiting for the court of appeal to  








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          render a decision, which in most cases, will be to uphold the  
          trial court's decision and send the case back to trial.  When a  
          victim of elder abuse passes away, the defendant's damages are  
          reduced.  The elder's surviving family members do not have the  
          right to collect damages under the Elder and Dependent Adult  
          Civil Protection Act (EADACPA).  Nor, obviously, does the  
          victim.  Under existing law, the ability to appeal an  
          interlocutory order relating to arbitration is only available  
          for orders denying a petition to compel, but not available for  
          orders granting appeal - which seems particularly unfair if the  
          appeal right is being used by a defendant as a litigation tactic  
          to reduce a defendant's damages.


          As currently in print, this bill prohibits a party from  
          appealing an interlocutory court order that denies a petition to  
          compel arbitration if a party has filed a claim under the Elder  
          and Dependent Adult Civil Protection Act, and the party has been  
          granted a trial preference because of poor or failing health.   
          The bill in print is sponsored by California Advocates for  
          Nursing Home Reform, California Alliance for Retired Americans,  
          Congress of California Seniors, Consumer Attorneys of  
          California, and is supported by SEIU California.  The bill in  
          print is opposed by a coalition led by the California  
          Association of Health Facilities, and is opposed by doctors,  
          hospitals, and nursing homes.


          As proposed to be amended by the author, the bill will provide  
          an expedited appeal process for an order dismissing or denying a  
          petition to compel arbitration in matters where the plaintiff  
          has filed a claim under the Elder and Dependent Adult Civil  
          Protection Act, and the plaintiff has been granted a trial  
          preference because of poor or failing health.  Based on these  
          proposed amendments, the original opponents have removed their  
          opposition.  Although the proposed amendments now raises  
          concerns among Judicial Council staff, the author has signaled  
          to this Committee that it will continue to work with the  
          Judicial Council to address their concerns.








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          SUMMARY:  Creates an expedited appeal process for a plaintiff  
          for an order denying a motion to compel arbitration in matters  
          where the plaintiff has made a claim of elder abuse and where  
          the plaintiff has been granted an expedited trial preference.   
          Specifically, this bill:


          1)Provides that in a case where a plaintiff has filed a claim  
            pursuant to the Elder and Dependent Adult Civil Protection  
            Act, and the plaintiff has been granted a trial preference, an  
            appeal dismissing or denying a petition to compel arbitration  
            shall be scheduled according to the following timeline:  


             a)   The notice of appeal and designation of the record must  
               be filed within 15 days of the service of a notice of entry  
               of the order or judgment subject to appeal.
             b)   The clerk of the superior court shall prepare and file  
               the requested clerk's transcript within 10 days of the  
               filing of the notice of appeal and immediately give notice  
               to the parties of such filing by the most expedited means  
               available, including electronic mail.  Consistent with  
               California Rule of Court 8.124, a party may elect to  
               provide the clerk's transcript by way of an appendix filed  
               with the briefs. 


             c)   Upon the filing of the notice of appeal and designation  
               of the record, the clerk of the superior court shall  
               immediately give notice by the most expedited means  
               available (including electronic mail) to the designated  
               reporters, requiring preparation and filing of the  
               certified reporter's transcript with the appellate court  
               within 10 days of the filing of the notice of appeal upon  
               the filing of the transcript, the clerk shall immediately  
               give notice to the parties of such filing by the most  
               expedited means available, including electronic mail. 








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             d)   In lieu of a reporter's transcript filed by the reporter  
               as set forth in the notice of designation of the record,  
               the appellant may elect to file certified copies of  
               previously-prepared transcripts with the Opening Brief;  
               such election must be indicated in the notice of the  
               designation of the record.


             e)   The opening brief of an appellant must be filed and  
               served by the most expedited means available, including  
               electronic mail within 20 days of the filing of the  
               complete and accurate record of the superior court  
               proceedings in the court of appeal or within 40 days of the  
               filing of the notice of appeal if the provisions as  
               specified are invoked.  At the time of the filing of the  
               opening brief, an appellant must either expressly request  
               or waive oral argument.


             f)   The brief of a respondent must be filed and served by  
               the most expedited means available, including electronic  
               mail within 20 days of the filing of the opening brief.  At  
               the time of the filing of the brief of a respondent, a  
               respondent must either expressly request or waive oral  
               argument.


             g)   The reply brief of an appellant, if any, must be filed  
               and served by the most expedited means available, including  
               electronic mail within 20 days of the filing of the brief  
               of an respondent.


             h)   If requested by either party, oral argument must be set  
               within 30 days of the date of the filing of the reply brief  
               or the date the reply brief is otherwise due.









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             i)   The decision of the appellate court must be issued no  
               later than 15 days after the submission of the case for  
               decision, i.e., at the end of oral argument or after the  
               filing of the reply brief or the date the reply brief is  
               otherwise due if no oral argument is requested.


          2)Provides that the timelines established in the act, including  
            the time for filing a notice of appeal, may be extended by  
            stipulation of the parties filed with the appellate court or  
            may be waived, in whole or in part, by the plaintiff in  
            writing filed with the trial court, with respect to the timely  
            filing of the notice of appeal, or with the appellate court  
            with respect to all other matters.  


          3)Provides that any stipulated extension of time or written  
            waiver of the plaintiff to extend any of the time limitations  
            may not exceed the normal and usual maximum times otherwise  
            established for appeals under any statute or rule of court.


          4)Provides that the timelines established in the act may be  
            extended if there is a showing of extraordinary good cause.


          5)Establishes that the terms used in the act are defined as the  
            terms used in the appellate rules established in the Rules of  
            Court.


          6)Makes various legislative declarations and findings.


          EXISTING LAW:   


          1)Provides that an appeal may be taken from a judgment except an  








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            interlocutory judgment unless provided otherwise.  (Code of  
            Civil Procedure Section 904.1 (a)(1).  Unless otherwise  
            stated, all further statutory references are to the Code of  
            Civil Procedure.)


          2)Provides that when a court denies a petition to compel  
            arbitration, the aggrieved party has the right to immediately  
            appeal the order denying the petition.  (Section 1294.)


          3)Provides that when a court grants a petition to compel  
            arbitration, the aggrieved party does not have the right to  
            immediately appeal the order granting the petition.  (Ibid.)


          4)Provides that an aggrieved party may appeal from the  
            following:


             a)   An order dismissing or denying a petition to compel  
               arbitration.


             b)   An order dismissing a petition to confirm, correct or  
               vacate an award.


             c)   An order vacating an award unless a rehearing in  
               arbitration is ordered.


             d)   A judgment entered pursuant to this title.


             e)   A special order after final judgment.  (Ibid.)


          5)Provides that a party seeking review of an order either  








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            denying or granting a petition to compel arbitration may file  
            a writ of mandate with the court of appeal.  (Section 1085.)


          6)Establishes the California Arbitration Act which provides that  
            agreements to arbitrate shall be valid, irrevocable, and  
            enforceable, except such grounds as exist at law or in equity  
            for the revocation of any contract.  (Section 1280 et seq.)


          7)Similarly establishes the Federal Arbitration Act (FAA) which  
            provides that agreements to arbitrate shall be valid,  
            irrevocable, and enforceable, except such grounds as exist at  
            law or in equity for the revocation of any contract.  (9  
            U.S.C. Section 1 et seq.)


          8)Provides on petition of a party to an arbitration agreement  
            alleging the existence of a written agreement to arbitrate a  
            controversy and that a party thereto refuses to arbitrate such  
            controversy, the court shall order the petitioner and the  
            respondent to arbitrate the controversy if it determines that  
            an agreement to arbitrate the controversy exists, unless it  
            determines that:


             a)   The right to compel arbitration has been waived by the  
               petitioner;


             b)   Grounds exist for the revocation of the agreement; or


             c)   A party to the arbitration agreement is also a party to  
               a pending court action or special proceeding with a third  
               party, arising out of the same transaction or series of  
               related transactions and there is a possibility of  
               conflicting rulings on common issue of law or fact.   
               (Section 1281.2.)








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          9)Provides that specified civil parties may petition a court to  
            grant a trial preference, which upon granting, requires the  
            court to set the matter for trial not more than 120 days from  
            that date from the granting of the motion.  (Section 36 et  
            seq.)


          10)Provides that in a hearing and decision in the Court of  
            Appeal, a party seeking calendar preference must promptly  
            serve and file a motion for preference in the reviewing court.  
             "Calendar preference" means an expedited appeal schedule,  
            which may include expedited briefing and preference in setting  
            the date of oral argument.  (Rule of Court 8.240.)


          11)Establishes the Elder Abuse and Dependent Adult Civil  
            Protection Act (EADACPA), which provides civil protections and  
            remedies for victims of elder and dependent adult abuse and  
            neglect.  (Welfare and Institutions Code Section 15600 et  
            seq.)


          12)Provides that in any action for injury against a health care  
            provider based on professional negligence, the injured  
            plaintiff shall be entitled to recover noneconomic losses to  
            compensate for pain, suffering, inconvenience, physical  
            impairment, disfigurement and other nonpecuniary damage.   
            Provides that in no action shall the amount of damages for  
            noneconomic losses exceed two hundred fifty thousand dollars.   
            (Civil Code Section 3333.2.)


          13)Provides that a party seeking calendar preference must  
            promptly serve and file a motion for preference in the  
            reviewing court.  (California Rules of Court 8.240.) 










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


          COMMENTS:  Justice Brennan once said that, "courts are the  
          central dispute-setting institutions of our society.  They are  
          bound to do equal justice under the law, to rich and poor  
          alike."  It comes as no surprise then that the phrase, "Equal  
          Justice Under Law," is engraved above the entrance to our  
          nation's highest court. And so it seems, we put a great deal of  
          faith in our courts - but would we expect any less?  We  
          anticipate our courts to apply the law in a fair, neutral, and  
          open manner.  We hold judges to high standards, and ask that  
          they avoid even the appearance of impropriety.  We count on our  
          judiciary to advance the law, issue orders, and render written  
          opinions.  And yet, we acknowledge that our system isn't perfect  
          and that despite their best efforts, courts sometimes get it  
          wrong.  Acknowledging the imperfection of our justice system is  
          undoubtedly one reason why it has safeguards.  We remember that  
          decisions of courts are reviewed by appellate courts and indeed,  
          reviewed by our elected branches.  In order to facilitate the  
          right to appeal, we provide a record of the proceedings, in  
          criminal matters at least.  And so, when our families, friends,  
          and neighbors are injured, wronged, or have a dispute, we rely  
          upon that faith that our courts-the institution we trust upon to  
          promote fairness-will deliver equal justice under the law.


          As this Committee is well-aware, arbitration is a form of  
          alternative dispute resolution held outside of courts where a  
          third-party (rather than a judge) makes a binding (and rarely  
          appealable) award.  Because most arbitration is created by  
          entering into a contract (usually a contract that is adhesive or  
          take-it-or-leave-it), the arbitration agreement will lay-out the  
          procedures that will be followed during the arbitration hearing.  
           For example, the terms of the arbitration agreement may  
          stipulate that the award need not be written or justified  
          (unlike in court), and that the entire process be kept in secret  
          (rather than in public view).  Arbitrators do not need to be  








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          lawyers, nor do they need to be trained in the law.  Arbitrators  
          who issue favorable awards to a particular company can be  
          repeatedly-hired by that same company to serve as the  
          arbitration-neutral without ever notifying the public about that  
          award-history.  It's easy to predict the calls if you can hire  
          the umpire.  


          Last year, the New York Times issued a three-part series titled,  
          "Beware the Fine Print" - a special report examining how  
          arbitration clauses buried in contracts deprives Americans of  
          their fundamental constitutional rights:


            Over the last 10 years, thousands of businesses across the  
            country - from big corporations to storefront shops - have  
            used arbitration to create an alternate system of justice.   
            There, rules tend to favor businesses, and judges and juries  
            have been replaced by arbitrators who commonly consider the  
            companies their clients.  The change has been swift and  
            virtually unnoticed, even though it has meant that tens of  
            millions of Americans have lost a fundamental right: their day  
            in court.  (Silver-Greenberg & Corkery, In Arbitration, a  
            Privatization of the Justice System, N.Y. Times (Nov. 1,  
            2015).)


          In fact, some legal scholars have stated that, arbitration  
          "amounts to the whole-scale privatization of the justice  
          system."  (Ibid.)  In an effort to protect consumers and  
          workers, this Legislature has worked on legislation aimed at  
          leveling the playing field, a turf that has been used by  
          corporate interests to evade public scrutiny, and even, avoid  
          the law.  This is because arbitrators do not need to be trained  
          in the law, or even apply the law, or render a decision  
          consistent with the evidence presented to them.  What evidence  
          is presented may, in fact, be incomplete because parties in  
          arbitration have no legal right to obtain evidence in support of  
          their claims or defenses, or the claims or defenses of the other  








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          party, contrary to the longstanding discovery practice in public  
          courts.  Advocates continue to debate about the benefits and  
          harms of mandatory arbitration.  Proponents of arbitration say  
          that arbitration produces quicker results and reduces litigation  
          costs.  Opponents argue that arbitration harms consumers and  
          workers because arbitration proceedings render unfair awards. 


          A brief review of recent court decisions on arbitration.  Given  
          the preemptive issues surrounding the Federal Arbitration Act  
          (FAA) and the U.S. Supreme Court's interpretation of the FAA,  
          the ability to legislate around the issue of arbitration is  
          difficult. In 2005, the California Supreme Court held that in  
          certain adhesive take-it-or-leave-it consumer contracts, a  
          contractual provision requiring the consumer to waive  
          class-action is unconscionable and void.  This is known as the  
          Discovery Bank rule (herein the Rule).  (36 Cal. 4th 148, 159.)   
          In the well-known Concepcion decision, the U.S. Supreme Court  
          struck down the Rule.  (AT&T Mobility LLC v. Concepcion (2011)  
          563 U.S. 333, 344-47.)  In that case, Vincent and Liza  
          Concepcion entered into a cellphone contract that required  
          claims to be brought in an "individual capacity, and not as a  
          plaintiff or class member in any purported class or  
          representative proceeding."  (Id. at 336.)  Relying on Discovery  
          Bank, the Concepcions challenged the class-action waiver as an  
          unconscionable contract provision.  (Id. at 338.)  In abrogating  
          the Rule, the Court held that the Rule stood "as an obstacle to  
          the accomplishment and execution of the full purposes and  
          objectives of Congress" because it "interferes with fundamental  
          attributes of arbitration."  (Id. at 344-47.)  Although the  
          Supreme Court has not defined a "fundamental attribute of  
          arbitration," the Court did say that there were potential  
          advantages of arbitration: lower costs, greater efficiency and  
          speed, and the ability to choose expert adjudicators to resolve  
          specialized disputes.  (Id. at 348.)  Indeed, the Court  
          analogized to several examples on the kinds of rules or laws  
          that would amount to "interference" with the "fundamental  
          attribute of arbitration."  For example, a rule to require  
          arbitration agreements and proceedings to provide  








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          judicially-monitored discovery, or to follow the Federal Rules  
          of Evidence would clearly violate the FAA.  (Id. at 342.)  In  
          those instances, those additional protections and  
          procedures-admirable as they are-would increase costs, reduce  
          efficiency and speed, and prevent an arbitrator from applying  
          the rules he or she wants to apply; accordingly, states and  
          courts are limited in crafting certain rules.


          Despite what some may say, California may regulate issues that  
          affect arbitration.  Relying on these principles in Concepcion,  
          some argue that anything that interferes with arbitration is  
          preempted by the FAA, as interpreted under Concepcion; however,  
          this argument is mistaken.  Federal law does not preempt states  
          from enacting basic protections around the principles of  
          contract law.  While federal preemption is broad, states are  
          permitted to set rules that are consistent with certain contract  
          law principles.  Additionally, states may establish specific  
          arbitration rules in their states.  As the Supreme Court has  
          stated, "parties are generally free to structure their  
          arbitration agreements as they see fit?[Where] parties have  
          agreed to abide by state rules of arbitration, enforcing those  
          rules according to the terms of the agreement is fully  
          consistent with the goals of the FAA."  (Volt Information  
          Sciences, Inc. v. Board of Trustees of Leland Stanford Junior  
          Univ. (1989) 489 U.S. 468, 479.)  Accordingly, states can enact  
          legislation that affects arbitration without offending the FAA.  


           How do courts settle a dispute over whether there is a valid  
          arbitration clause?  When there is a disagreement between  
          parties about whether the parties agreed to arbitration, a court  
          resolves the dispute by examining whether there was an agreement  
          by applying contract law principles.  Because the resolution of  
          that question does not resolve the merits of the case-in-chief,  
          the court's decision is issued through an interlocutory order.   
          This is significant because there is generally no right to  
          appeal interlocutory orders, which are often issued throughout a  
          case.  Generally, the right to appeal attaches upon a final  








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          judgment.  According to one California court, there are sound  
                                                                             reasons for the final judgment rule:


            Interlocutory appeals burden the courts and impede the  
            judicial process in a number of ways: (1) They tend to clog  
            the appellate courts with a multiplicity of appeals; (2) Early  
            resort to the appellate courts tends to produce uncertainty  
            and delay in the trial court; (3) Until a final judgment is  
            rendered the trial court may completely obviate an appeal by  
            altering the rulings from which an appeal would otherwise have  
            been taken;  (4) Later actions by the trial court may provide  
            a more complete record which dispels the appearance of error  
            or establishes that it was harmless; (5) Having the benefit of  
            a complete adjudication will assist the reviewing court to  
            remedy error (if any) by giving specific directions rather  
            than remanding for another round of open-ended proceedings.   
            (Vivid Video, Inc. v. Playboy Entertainment Group, Inc. (2007)  
            147 Cal.App.4th 434, 442-444 [citations omitted].)


          Current statute creates a one-sided interlocutory appellate  
          right.  Despite the general rule requiring finality prior to  
          appeal, current law creates a one-sided interlocutory appeal in  
          the arbitration context.  Currently, parties can appeal an  
          interlocutory order denying (a petition to compel) arbitration,  
          but parties may not appeal an interlocutory order compelling  
          arbitration.  In other words, if a court orders the parties to  
          go to arbitration, the parties cannot appeal that decision; if a  
          court denies arbitration and orders the parties go to trial, the  
          injured parties can appeal.  Indeed, in an attempt to equalize  
          the appellate rights for all parties contesting the validity of  
          an arbitration clause, this Committee previous considered AB  
          1062 (Dickinson, 2001), which would have eliminated the  
          interlocutory appeal for arbitration orders altogether.   
          Although this Committee passed AB 1062 (Dickinson) out of the  
          Committee, the bill was held on the Assembly Floor.  










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          Author's statement:  In explaining the need for this bill, as  
          proposed to be amended, the author writes:


            When there is an allegation of elder abuse in a nursing home  
            and the elder abuse victim is granted a speedy trial  
            preference, it is routine for the defendant nursing home to  
            file a motion to enforce arbitration as a way to avoid jury  
            trial or to stall litigation proceedings.  This is because the  
            nursing facility drafts the arbitration provisions and coerces  
            the victim into signing the arbitration clause during  
            enrollment.


            If the trial court finds that the agreement's terms are  
            unconscionable and unreasonably one-sided, it may deny the  
            defendant's motion to compel arbitration, allowing the elder  
            to proceed to a jury trial in regular court.  Under current  
            law, a nursing care facility - who has lost in court - will  
            delay an elder's speedy trial by filing an unnecessary appeal.


            This appeal causes a delay in the matter for another 1-3  
            years.  The delay caused by the appeal is done in the hope  
            that the elder will not survive long enough for the appeal to  
            be decided, thereby reducing the defendant's liability if the  
            victim dies before trial.  


            SB 1065 helps seniors get a more timely trial in Elder Abuse  
            Act claims by maintaining current appellate rights, but  
            expediting the time frame that the appeal must be heard.  This  
            bill will help victims of elder abuse who are old and dying  
            and who need a speedy resolution of the elder abuse case.   
            Victims should be able to proceed to the speedy hearing that  
            was originally ordered by the court, but under current law,  
            they cannot.  SB 1065 fixes that injustice by establishing an  
            expedited appeal process for this narrow yet very deserving  
            class of elder abuse victims.








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          Summary of the bill as proposed to be amended:  The bill, as  
          proposed to be amended, will provide an expedited appeal process  
          for reviewing an order dismissing or denying a petition to  
          compel arbitration in matters where the plaintiff has filed a  
          claim under the Elder and Dependent Adult Civil Protection Act,  
          and the plaintiff has been granted a trial preference because of  
          poor or failing health.


          Examples of violations under the Elder and Dependent Adult Civil  
          Protection Act.  The Elder and Dependent Adult Civil Protection  
          Act (EADACPA) was enacted to protect elder and dependent adults  
          from abuse and exploitation.  EADACPA recognizes that elders and  
          dependent adults may have disabilities and cognitive  
          impairments, such as Alzheimer's disease and other dementia  
          disorders, which often leave elders incapable of seeking help  
          and protection from others.  These elders and dependent adults  
          suffer from physical impairments and poor health, which places  
          them in a dependent and vulnerable position.  In enacting  
          EADACPA, the Legislature found that criminal cases of elder and  
          dependent adult abuse are seldom prosecuted, and that civil  
          cases brought in connection with this abuse face problems of  
          proof, court delays, and the lack of incentives to litigate  
          these suits.  EADACPA was enacted to expand and enhance the  
          remedies available to elders, their families, and their  
          advocates to encourage the civil prosecution of elder abuse  
          cases.  For example, under EADACPA, a defendant who is found  
          liable for physical elder abuse may also be liable for damages  
          for pain, suffering, and disfigurement.  If a defendant is found  
          liable for elder abuse and engaged in recklessness, oppression,  
          fraud, or malice in the commission of the abuse, EADACPA  
          mandates attorney's fees and costs.  But if the elder passes  
          away before the claim is resolved, the elder obviously cannot  
          obtain any of these EADACPA damages.  Nor can the deceased  
          elder's surviving family members.










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          Certain parties may obtain a trial preference.  In civil  
          litigation, shortly after the parties have filed their  
          pleadings, the court holds an initial case management conference  
          to schedule the timeline for the litigation, which includes  
          setting a trial date.  Because the trial date largely controls  
          the pace of the litigation proceedings, some parties seek to  
          have expedited proceedings by obtaining a trial preference.   
          Generally, a court will grant a trial preference if the trial  
          preference serves the interests of justice.  Existing law also  
          specifically authorizes a court to grant a trial preference in  
          certain instances and requires trial preference in other  
          instances.  The purpose behind trial preference for elders is to  
          acknowledge that older litigants should have the right to go to  
          trial, and obtain a full measure of damages during the  
          litigant's lifetime.  (Rice v. Superior Court (1982) 136  
          Cal.App.3d 81.)  For parties over seventy, the court must grant  
          a trial preference if the court finds that the health of the  
          party makes it necessary for the court to grant a trial  
          preference.  Another instance of when the court may grant a  
          trial preference is when there is clear and convincing medical  
          documentation that one of the parties suffers from an illness or  
          condition that raises substantial medical doubt about the  
          survival of that party beyond six months.  If a party obtains a  
          trial preference, the court must set that matter for trial  
          within six months, which may be postponed (or continued) for a  
          date no later than six months.  Essentially, a party granted a  
          trial preference is expected to have their dispute resolved in  
          six months to one year.


          It is not unprecedented to provide parties before the Courts of  
          Appeal with an expedited appeal.  Under California Rules of  
          Court, a party seeking an expedited appeal schedule may serve  
          and file a motion for preference in a reviewing court.  (Rules  
          of Court 8.240.)  Generally, an expedited appeal includes  
          expedited briefing and preference in setting the date of oral  
          argument.  Parties who are granted a trial preference - such as  
          parties over the age of seventy and who are in poor health - may  
          obtain an expedited appeal.  Additionally, in 2011, the  








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          Legislature enacted AB 900 (Buchanan, Chap. 354, Stats. of  
          2011), which requires Courts of Appeal to issue a decision in  
          specified cases under the California Environmental Quality Act  
          (CEQA) within 175 days of the filing of the petition.  


          According to the author, existing Rules of Court relating to  
          expedite appellate review are inadequate to ensure that victims  
          of elder abuse have their day in court.  According to the author  
          and sponsors, an expedited appeal under current Rules of Court  
          can still take up to over a year.  Given the concern that many  
          victims of elder abuse who have been granted a trial preference  
          because of poor health may not survive longer than 6 months, the  
          current Rules of Court does not provide adequate relief to those  
          victims.  Thus, it would seem that legislation is necessary and  
          appropriate to shorten the timelines for resolving an appeal in  
          limited elder abuse cases.


          Given that most cases are pending in a court of appeal for more  
          than 800 days - a little over two years--Judicial Council staff  
          has raised several legitimate concerns about a requirement to  
          resolve appeals in a fraction of that time.  According to the  
          Judicial Council, the statewide average to process a civil  
          appeal is 498 days - nearly one year and a half - while the  
          statewide average to process a civil appeal of 90% of cases is  
          807 days - a little over two years.  As proposed to be amended,  
          this bill would require an appellate case-reviewing an  
          interlocutory order denying a petition to compel arbitration in  
          EADACPA claims where the elder has been granted a trial  
          preference-to be completed in as few as 100 days, unless parties  
          stipulate to specified extensions.  Given the short timeframe  
          under this bill, Judicial Council staff has raised significant  
          concerns about whether the requirements of this bill would be  
          workable - especially considering the court's existing  
          resources.  Judicial Council staff point out that when the  
          Legislature has previously considered measures to expedite  
          judicial review, some of those bills included a 175 day timeline  
          (e.g., AB 900 (Buchanan, Chap. 354, Stats. of 2011)), which has  








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          been difficult for the court to implement.  Additionally,  
          Judicial Council staff asserts that even if the timeline under  
          this bill were workable, statutory timelines are disfavored and  
          that a better approach would be to address this issue through a  
          Rule of Court.


          In response to the arguments raised by the Judicial Council, the  
          author asserts the following: 


            This proposal is not intended to add extra burdens to the  
            appellate courts as very few people will qualify for the  
            expedited appeal.  First, most elder abuse victims die and the  
            bill covers only live victims.  Second, for those live  
            victims, in order to qualify for the expedited process, the  
            victim must prove to the court she qualifies for a trial court  
            preference, meaning she is over 70 and in ill health.   
            Although there are no state statistics on the number of elder  
            abuse plaintiffs, we believe a very small number (under 20)  
            would qualify and therefore the impact on the appellate courts  
            should be very small.  Third, it is within the purview of the  
            legislature to set timeframes and deadlines for the court.   
            Fourth, it is important that when the Legislature has enacted  
            specific laws to assist a vulnerable population (in this case  
            elder abuse victims) that it also ensures that the laws are  
            adjudicated in a timely manner.


          Although the Judicial Council raises legitimate concerns, this  
          bill would significantly help a very small number of very  
          vulnerable plaintiffs.  The Committee staff acknowledges that  
          the role of our appellate courts is to render decisions  
          thoughtfully and methodically, and to serve as a backstop for  
          trial error.  It would seem that forcing a Court of Appeal to  
          issue a decision quickly would potentially jeopardize these  
          principles by rushing judgment and potentially harming all  
          parties involved.  However, given the limited number of  
          plaintiffs who would benefit from this procedure and the  








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          desperation of their circumstances, it seems that the burden on  
          the court and the risk of harm would be limited and justified.   
          Additionally, the Legislature has enacted a number of measures  
          aimed at ensuring that victims of elder abuse have their day in  
          court - a policy that is promoted by this bill.  With that said,  
          the author is encouraged to continue working with the Judicial  
          Council to resolve the Council's concerns about this bill should  
          the bill move forward.  Given that the ultimate goal is to allow  
          elder abuse victim plaintiffs to have their day in court by  
          reducing the appellate timeframe in limited cases without  
          disrupting the calendars of Courts of Appeal, the author may  
          wish to consider amendments that require the Judicial Council to  
          promulgate a Rule of Court consistent with the timeframe  
          provided under this bill, rather than specifying an exact timing  
          schedule.


          REGISTERED SUPPORT / OPPOSITION:




          Support (of the bill in print)


          California Advocates for Nursing Home Reform (co-sponsor)


          California Alliance for Retired Americans (co-sponsor)


          Congress of California Seniors (co-sponsor)


          Consumer Attorneys of California (co-sponsor)


          SEIU California









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          Opposition


          None on file




          Analysis Prepared by:Eric Dang / JUD. / (916)  
          319-2334