BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 76
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           REPLACE
           
          ASSEMBLY THIRD READING
          AB 76 (Corbett)
          As Amended March 11, 2003
          Majority vote 

           JUDICIARY           11-3        LABOR & EMPLOYMENT              
          6-2                 
           
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          |Ayes:|Corbett, Dutra, Hancock,  |Ayes:|Koretz, Mullin, Chu,      |
          |     |Jackson, Laird,           |     |Hancock, Laird, Negrete   |
          |     |Longville, Lieber,        |     |McLeod                    |
          |     |Spitzer, Steinberg,       |     |                          |
          |     |Vargas, Nunez             |     |                          |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Harman, Bates, Pacheco    |Nays:|Shirley Horton, Houston   |
          |     |                          |     |                          |
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           APPROPRIATIONS      19-6                                        
           
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          |Ayes:|Steinberg, Berg,          |     |                          |
          |     |Calderon, Cohn, Corbett,  |     |                          |
          |     |Correa, Diaz, Firebaugh,  |     |                          |
          |     |Goldberg, Leno,           |     |                          |
          |     |Maldonado, Nation,        |     |                          |
          |     |Negrete McLeod, Nunez,    |     |                          |
          |     |Pavley, Ridley-Thomas,    |     |                          |
          |     |Laird, Wiggins, Yee       |     |                          |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Bates, Daucher, Haynes,   |     |                          |
          |     |Pacheco, Runner,          |     |                          |
          |     |Samuelian                 |     |                          |
          |     |                          |     |                          |
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           SUMMARY :  Invalidates a 2002 court of appeal decision which held  
          workers in California are not protected against workplace  
          harassment perpetrated by customers, vendors, and other third  
          parties.  Specifically,  this bill  : 

          1)Clarifies language in the Fair Employment and Housing Act  








                                                                 AB 76
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            (FEHA) to ensure that under state law employers may  
            potentially be liable for harassment committed against their  
            workers by clients, customers and other third parties if they  
            knew or should have known of the harassment, and failed to  
            take immediate and appropriate corrective action to stop the  
            harassment.

          2)Effectively invalidates the court of appeal decision last year  
            of  Salazar v. Diversified Paratransit, Inc  ., 103 Cal. App. 4th  
            131 (2002).

          3)Ensures that California's discrimination law is not weaker  
            than federal regarding workplace protections for employees  
            facing harassment by customers and other third parties.
           
          FISCAL EFFECT  :  According to the Assembly Appropriations  
          analysis, minor, absorbable costs to the Department of Fair  
          Employment and Housing (DFEH).

           COMMENTS  :  This bill is sponsored by the California Labor  
          Federation and the California chapter of the National  
          Organization for Women.  This bill addresses a critical question  
          surrounding workplace protections against sexual and other forms  
          of harassment:  whether or not the state's principal  
          anti-harassment law imposes a duty on an employer to take  
          reasonable steps to prevent its employees from being harassed in  
          the workplace by clients, customers, or other non-employees.  In  
          so doing, this bill seeks to invalidate the recent court  
          decision in  Salazar  , a case that shocked many employment law  
          experts when it held that the Legislature did not intend the  
          state's FEHA to hold employers potentially responsible for  
          protecting their workers from sexual or other forms of  
          harassment if such harassment was committed by outside parties  
          in the workplace.

          In the majority opinion, a sharply divided court of appeal  
          concluded that regardless of how egregious the harassment, or  
          the employer's actual knowledge of it, the employer's duty to  
          prevent harassment did not extend to harassment by the  
          employer's customers or clients.  This recent court decision was  
          a dramatic departure from the view shared by legal experts in  
          California.
            
          In the 2-1 decision in  Salazar  , Presiding Justice Joan Dempsey  
          Klein vociferously dissented, stating that the majority's  








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          opinion makes no sense as a matter of statutory construction,  
          and does serious damage to the fundamental policies which  
          California's key anti-harassment law was intended to further.   
          Indeed, Justice Klein noted that the employer forced the victim  
          in that case, Ms. Salazar, over her protests and as a condition  
          of her continued employment, to interact with the client in  
          circumstances where Ms. Salazar was ultimately forced to be  
          sexually exposed to a client of the business for whom she  
          worked.  "Thus," wrote Justice Klein, "the very powerlessness  
          that underlies so much of our anti-harassment law was directly  
          implicated by the circumstances of her case.  It obviously made  
          no difference to Ms. Salazar whether the threat to her safety  
          came from a fellow employee, or from a client or anyone else  
          with whom she was required to interact." 
           
           The uncodified preamble to FEHA has for almost 20 years stated  
          legislative intent that  "employers be required to establish  
          affirmative programs . . . so that work sites will be maintained  
          free from prohibited harassment and discrimination by . . .  
          [employers'] . . . agents, administrators, and supervisors as  
          well as by their non-supervisors and clientele."  (Statutes of  
          1984, Chapter 1754,  1, emphasis added.)  Supporters of this  
          bill, in addition to Presiding Justice Klein in her dissent in  
           Salazar  , suggest this language should put a quick end to the  
          question whether the Legislature intended to cover third party  
          harassment under FEHA.  DFEH does now and has long considered  
          such cases against third parties covered under the umbrella of  
          FEHA. 

          There appears to be little dispute that enactment of this bill  
          will ensure that state anti-harassment law in this area is  
          consistent with the federal approach to third party harassment.   
          The converse is of course also true:  if the  Salazar  case is  
          permitted to stand, California law in this area will be less  
          worker-protective than federal law.  The federal cases are  
          virtually unanimous in their conclusion that an employer may be  
          held liable for a non-employee's sexual harassment of an  
          employee, if the employer fails to remedy or prevent a hostile  
          or offensive work environment which management-level employees  
          knew, or in the exercise of reasonable care should have known,  
          existed.  Leading California practice guides on employment law  
          also state that an employer may be held liable for harassment of  
          its employees by non-employees, when the employer fails to take  
          reasonable steps to prevent the harassment.  









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          Although the  Salazar  case was recently accepted by the  
          California Supreme Court for consideration later this fall, and  
          therefore is not presently viable law, enactment of this  
          legislation would put to rest any question of legislative intent  
          raised in the case.

          The enactment of this bill will not change existing law that  
          holds employers strictly liable for the sexual harassment of  
          employees (or applicants) by supervisors or agents.  [  Doe v.  
          Capital Cities  (1996);  Murillo v. Rite Stuff Foods, Inc.  (1998)]  
           It is immaterial whether the employer knew or should have known  
          of the supervisor or agent's harassment and failed to intervene.  
           [  Weeks v. Baker & McKenzie (1998);  Kelly-Zurian v. Wohl Shoe  
          Co., Inc.  (1994)]


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


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