BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 2889
                                                                  Page  1

          Date of Hearing:   April 21, 2004

                     ASSEMBLY COMMITTEE ON LABOR AND EMPLOYMENT
                                 Paul Koretz, Chair
                 AB 2889 (Laird) - As Introduced:  February 20, 2004
           
          SUBJECT  : Unlawful employment practices.

           SUMMARY  :  Makes employers responsible for the acts of  
          non-employees with respect to all forms of harassment in the  
          workplace where the employer or its agents or supervisors knew  
          or should have known of the conduct and failed to take immediate  
          and appropriate corrective action. 

           EXISTING LAW  

          1)Makes it an unlawful employment practice for an employer to  
            harass or discriminate against an employee because of the  
            employee's race, religious creed, color, national origin,  
            ancestry, physical or mental disability, medical condition,  
            marital status, sex, age, or sexual orientation. 

          2)Makes harassment of an employee by another employee, other  
            than an agent or supervisor, an unlawful employment practice  
            if the employer knew about the conduct and failed to take  
            immediate and appropriate corrective action.

          3)Provides that employers are responsible for the acts of  
            non-employees with respect to sexual harassment in the  
            workplace if the employer knew or should have known of the  
            conduct and failed to take immediate and appropriate  
            corrective action. 

          4)Requires employers in California to seek to prevent all  
            harassment in the workplace by taking "all reasonable steps to  
            prevent harassment from occurring." 

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   

          Last year, AB 76 (Corbett), Chapter 671, Statutes 2003, was  
          signed into law.  AB 76 clarified that employers in California  
          are required, consistent with federal law, to take reasonable  
          steps to protect their employees from sexual harassment  








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          perpetrated by an employer's customers, clients or other  
          non-employees.  When introduced the measure dealt with all forms  
          of harassment.  However, by the end of the legislative process  
          compromises were made and the measure was explicitly limited to  
          sexual harassment. 

          The author's argument for this bill states "Because AB 76 was  
          limited to sexual harassment, it has created a "hierarchy" of  
          harassment protection favoring sexual harassment over harassment  
          directed at employees because of their race, religion, color,  
          national origin, ancestry, disability, medical condition, age,  
          or sexual orientation.  This clean-up bill seeks to  
          appropriately "equalize" worker protections against harassment  
          so that regardless of the type of harassment being perpetrated  
          by a customer, client or other third party in the workplace, the  
          message will be clear: such harassment will not be tolerated,  
          and California employers must take reasonable steps to protect  
          their employees."

          Supporters and the author argue that this bill will put  
          California into conformity with federal law and regulations  
          regarding third-party, or non-employee harassment of any kind.   
          The primary federal law prohibiting sexual harassment is Title  
          VII of the Civil Rights Act of 1964 which makes it unlawful for  
          an employer to discriminate against an employee on the basis of  
          race, color, religion, sex, or national origin.  The United  
          States Supreme Court ruled, in Meritor Savings Bank V. Vinson  
          (1986 477 U.S. 57), that sexual harassment violates the  
          prohibition against sex discrimination in Title VII.  The Civil  
          Rights Act is enforced by the Equal Employment and Opportunity  
          Commission (EEOC).  

          EEOC enforcement guidelines, however, make clear that Title VII  
          protections apply to all forms of harassment, not only sexual  
          harassment.  Additionally, the guidelines note that "Title VII  
          law and agency principles will guide the determination of  
          whether an employer is liable for age [i.e., non-sexual]  
          harassment by its supervisors, employees, or non-employees".      


          Additionally, in Peries v. New York City Board of Education  
          (2001 U.S.Dist LEXIS 23393), 
          a federal district court cited the federal third party  
          harassment regulation in support of its conclusion that a  
          teacher's employer could be found liable for third-party  








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          harassment based not on sexual harassment, but on national  
          origin. 

          It should be noted that under state law, in Government Code   
          12940 (j)(1), only harassment against employees by non-employees  
          is limited to sexual harassment.  All forms of harassment, under  
          that section, apply to harassment of an employee by an employer  
          or of an employee by another employee, other than an agent or  
          supervisor.  

           Arguments in Support
           
          The author and supporters view the compromises to AB 76 as  
          having inadvertently created a "loop hole" with respect to state  
          law.  Supporters of the bill, made up of the Attorney General as  
          well as many statewide labor and civil rights groups, argue  
          that, by closing the loop hole, this bill merely brings  
          California law in line with the broader protections provided  
          under federal law so that California workers are not afforded  
          less protection against third party harassment than they receive  
          under federal law. 

          The California National Organization for Women writing in  
          support argues that this bill only holds an employer liable for  
          its own actions, and then only if the employer knew or should  
          have known if illegal harassment and failed to take corrective  
          action.

           Arguments in Opposition
           
          The Civil Justice Association of California (CJAC) opposes this  
          bill because "it will subject employers to liability for all  
          forms of third party harassment."  It also opposes the bill  
          because "Assembly Bill 76 ... expanded California law beyond  
          federal law that covers only employers with 15 or more  
          employees."  CJAC further argues that employers lack control,  
          legal or otherwise, over the behavior of non-employees such as  
          clients, customers, or others outside of their supervisory  
          scope.

          Similarly, the California Healthcare Association (CHA) argues in  
          opposition that the law must recognize the amount of control an  
          employer has over the conduct of non-employees currently  
          afforded under federal law.  CHA further states that "Health  
          care employers occasionally have to respond to employee  








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          complaints of harassment committed by patients in their  
          facilities.  Often times these patients suffer from diminished  
          mental capacity due to illness or medication and are unaware of  
          the impact their actions have on others."

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          American Civil Liberties Union
          American Federation of State, County and Municipal Employees
          Anti-Defamation League
          California Faculty Association
          California Labor Federation, AFL-CIO
          California National Organization for Women
          California School Employees Association
          California State Employees Association
          National Center for Lesbian Rights

           Opposition 
           
          California Bankers Association
          National Federation of Independent Business
          Associated Builders and Contractors of California
          California Healthcare Association
          Civil Justice Association of California
           
          Analysis Prepared by  :    Nick Louizos / L. & E. / (916) 319-2091