BILL ANALYSIS                                                                                                                                                                                                    






                             SENATE JUDICIARY COMMITTEE
                           Senator Ellen M. Corbett, Chair
                              2009-2010 Regular Session


          AB 781 (Jeffries)
          As Amended January 21, 2010
          Hearing Date: June 22, 2010
          Fiscal: No
          Urgency: No
          KB:jd
                    

                                        SUBJECT
                                           
                                 Bilingual Services

                                      DESCRIPTION  

          This bill, sponsored by the California NAACP, would provide that  
          no state or local agency shall impose or implement an action or  
          decision pursuant to the Dymally-Alatorre Bilingual Services Act  
          as a pretext for discrimination on the basis of race, national  
          origin, or other unlawful discrimination in employment,  
          including specifically any requirement that an employee be  
          bilingual.  This bill would further provide that all information  
          and reports required by the Dymally-Alatorre Bilingual Services  
          Act shall be public information unless otherwise restricted by  
          law.

                                      BACKGROUND  

          The Dymally-Alatorre Bilingual Services Act (Act) was enacted in  
          1973 to provide for effective communication between the state's  
          residents and state, county, and municipal
          governments. (Chapter 1035, Section 8, Statutes of 1997.)  The  
          Act is intended to ensure that individuals who do not speak or  
          write English are not prevented from using
          public services because of language barriers.   In passing the  
          Act, the Legislature was responding to concerns that a  
          substantial portion of California's population could not  
          effectively communicate with government at the state and local  
          level because they spoke a different language.  Because public  
          agencies were frequently unable to communicate with individuals  
          requiring these services, non-English-speaking individuals were  
          effectively being denied rights and benefits to which they were  
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          entitled.  Accordingly, the Act required state and local  
          agencies to ensure that they provide information and services in  
          the various languages of their constituents. 

          This bill seeks to clarify that employment actions taken  
          pursuant to the Act may not be used as a pretext for unlawful  
          discrimination.  


                                CHANGES TO EXISTING LAW
           
           Existing law  , the Dymally-Alatorre Bilingual Services Act,  
          requires every state agency, except as specified, that is  
          directly involved in the furnishing of information or the  
          rendering of services to the public whereby contact is made with  
          a substantial number of non-English-speaking people to employ a  
          sufficient number of qualified bilingual persons in public  
          contact positions.  (Gov. Code Sec. 7292.)

           Existing law  requires every local public agency serving a  
          substantial number of non-English-speaking people to employ a  
          sufficient number of qualified bilingual persons in public  
          contact positions or as interpreters to assist those in such  
          positions, to ensure provision of information and services in  
          the language of the non-English-speaking person.  (Gov. Code  
          Sec. 7293.)

           Existing law  requires that any materials explaining services  
          available to the public be translated into any non-English  
          language spoken by a substantial number of the public served by  
          the agency.  (Gov. Code Sec. 7295.)

           Existing law  requires each state agency to conduct an assessment  
          and develop an implementation plan that complies with the  
          requirements of the Act.  (Gov. Code Sec. 7299.4.)

           Existing law  provides that it shall be an unlawful employment  
          practice, unless based upon a bona fide occupational  
          qualification for an employer, because of the race, color,  
          national origin (including language) or ancestry, of any person,  
          to refuse to hire or employ the person or to refuse to select  
          the person for a training program leading to employment, or to  
          bar or to discharge the person from employment or from a  
          training program leading to employment, or to discriminate  
          against the person in compensation or in terms, conditions, or  
          privileges of employment.  (Gov. Code Sec. 12940.)
                                                                      



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           This bill  would provide that no state or local agency shall  
          impose or implement an action or decision pursuant to this  
          chapter as a pretext for discrimination on the basis of race,  
          national origin, or other unlawful discrimination in employment,  
          including specifically any requirement that an employee be  
          bilingual.  

           This bill  would specify that all information and reports  
          required by the Act shall be public information unless otherwise  
          restricted by law.

                                        COMMENT
           
              1.   Stated need for the bill

           According to the author, while the Dymally-Alatorre Bilingual  
          Services Act appropriately provides for access to government  
          services to Limited English Proficiency residents, it fails to  
          ensure that local and state government hiring practices do not  
          have a disparate impact on equal employment opportunities, or  
          subject job applicants to discrimination based on race, color,  
          religion, sex, or national origin.  The author points to an  
          ordinance adopted by the City of Oakland which required the City  
          to hire "a sufficient number of bilingual employees in public  
          contact positions so as to adequately serve members of the  
          substantial number of limited-English-speaking persons group(s)  
          in the City."  (Equal Access Ordinance, O.M.C. 2.30.)  The  
          author and sponsor have expressed concerns that this ordinance,  
          as well as state law, does not sufficiently emphasize the  
          obligation to abide by longstanding equal employment opportunity  
          laws.

           2.Balancing public policies providing for public services and  
            prohibiting discrimination 

           As previously noted, the author has indicated that the Equal  
          Access Ordinance adopted by the City of Oakland ordinance is  
          problematic in that it potentially undermines equal employment  
          opportunities for monolingual English speakers.  Committee staff  
          notes that the author has not provided any published studies or  
          reports demonstrating that hiring practices pursuant to the  
          Bilingual Services Act have had a disparate impact on any  
          specific groups of the population.  In contrast, the City of  
          Oakland adopted the Equal Access Ordinance after a report was  
          released by the State Auditor concluding that state and local  
                                                                      



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          governments could be doing more to address the need for  
          bilingual services.  (Dymally-Alatorre Bilingual Services Act:  
          State and Local Governments Could Do More to Address Their  
          Clients' Needs for Bilingual Services, California State Auditor,  
          November 1999.)  Despite its ordinance, Oakland has still been  
          sued by community groups for allegedly failing to fulfill its  
          obligations under its Equal Access Ordinance.  In filing the  
          lawsuit, the community groups cited examples of residents who  
          were unable to access services because of language barriers,  
          such as a non-English speaking Cantonese couple who were robbed  
          at gunpoint and unable to get assistance from 9-1-1.  Thus, it  
          appears that, despite the requirements of state law, the  
          provision of bilingual services has not always kept up with the  
          state's increasingly diverse population.  

          Nonetheless, the provision of bilingual services should never be  
          used as a pretext for employment practices that have expressly  
          been declared to be unlawful by both state and federal law.   
          Accordingly, this bill would provide that no state or local  
          agency shall impose or implement an action pursuant to the  
          Dymally-Alatorre Bilingual Services Act as a pretext for  
          unlawful discrimination in employment, including any requirement  
          that an employee be bilingual.  In order to ensure that state or  
          local efforts to comply with the Act are not hindered, this bill  
          would further provide that an action or decision taken for the  
          purpose of fulfilling the requirements of the Act shall not be  
          considered a pretext for discrimination.  

          It should be noted that this bill does not equate the hiring of  
          a bilingual employee to be unlawful discrimination.  Rather, it  
          specifically provides that a bilingual requirement for a job  
          position may not be used to hide otherwise unlawful  
          discrimination, such as, racial animus. 
              3.   Required reports shall be public information
             
          Under current law, state agencies must conduct an assessment and  
          develop and update an implementation plan for the provision of  
          bilingual services pursuant to the Act.  This includes the  
          requirement that state agencies conduct a survey of their local  
          offices every two years to determine all specified information,  
          including: (1) the number of public contact positions in each  
          field office; (2) the number of bilingual employees in public  
          contact positions and the other languages they speak; (3) the  
          number of people served by each office who do not speak English,  
          identified by the specific language they speak, and each  
          language's percentage of the total; (4) the number of  
                                                                      



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          anticipated vacancies in public contact positions for the coming  
          year; and (5) whether contracted telephone-based interpreters  
          are used to serve any language needs of the agency's clients.   
          (Gov. Code Sec. 7299.4.)  

          State agencies are required to submit implementation plans to  
          the State Personnel Board, which must review each plan, and, if  
          it determines that the plan fails to address the identified  
          deficiencies, order the agency to supplement or make changes to  
          its plan.  (Id.)  A state agency that has been determined to be  
          deficient shall report to the State Personnel Board every six  
          months on its progress in addressing the identified  
          deficiencies.  (Id.)  The State Personnel Board is also required  
          to review the results of the surveys and implementation plans  
          required by the Act, compile data, and provide a report to the  
          Legislature every two years, identifying significant problems or  
          deficiencies and proposing solutions where warranted.  (Gov.  
          Code Sec. 7299.6.)

          This bill would clarify that the information and reports  
          required under the Act are public information, unless otherwise  
          restricted by law.  This provision underscores the need for  
          accountability in the actions taken by state or local agencies  
          in complying with the Act, while at the same time ensuring that  
          otherwise confidential information, such as personnel records,  
          are not disclosed.  

              4.   Suggested amendment
           
          In order to better clarify the intent of this bill, committee  
          staff recommends the following technical amendment:

             Suggested amendment
           
            On page 2, lines 6-7, strike "including any requirement that  
            an employee be bilingual"

            On page 2, line 4, after "chapter," insert "including any  
            requirement that an employee be bilingual"



              5.   Opposition
           
          In opposition, the City of Oakland writes:

                                                                      



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            The City of Oakland has made it a priority to establish a form  
            of government that is truly inclusive of all its residents and  
            is committed to the delivery of effective, courteous and  
            responsive services.  A substantial number of persons who live  
            and work in Oakland are unable to communicate effectively in  
            English because their primary language is not English; in  
            fact, there are over 125 languages and dialects spoken in  
            Oakland.  It is of paramount importance that all residents  
            regardless of their ability or proficiencies in English have  
            access to City programs, support, and services.  

            On May 8, 2001, the City of Oakland became the first city in  
            the nation to pass an Equal Access to Service ordinance with  
            the purpose of removing language barriers for limited English  
            speakers attempting to access City services.  City of Oakland  
            departments are required to provide language access for  
            residents who are limited English speaking through  
            availability of bilingual staff and translated written  
            outreach materials. ?

            While we agree that local agencies should not engage in any  
            form of discrimination in employment, our concern is that your  
            bill, if passed, could potentially deter local governments  
            from requiring bilingual skills and would negatively impact  
            our residents by preventing them from accessing essential city  
            services. 


           Support  :  None Known

           Opposition  : City of Oakland

                                        HISTORY
           
          Source  :  California NAACP

           Related Pending Legislation  :  None Known

           Prior Legislation  :  See Background. 

           Prior Vote  :

          Assembly Judiciary Committee  (Ayes 9, Noes 0)
          Assembly Floor (Ayes 68, Noes 0)

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