BILL ANALYSIS                                                                                                                                                                                                    




                                                                  AB 2187
                                                                  Page A

          ASSEMBLY THIRD READING
          AB 2187 (Arambula)
          As Amended  March 24, 2010
          Majority vote 

           LABOR AND EMPLOYMENT     4-2    APPROPRIATIONS      12-5        
           
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          |Ayes:|Swanson, Furutani,        |Ayes:|Fuentes, Ammiano,         |
          |     |Monning, Yamada           |     |Bradford,                 |
          |     |                          |     |Charles Calderon, Coto,   |
          |     |                          |     |Davis,                    |
          |     |                          |     |Nava, Hall, Skinner,      |
          |     |                          |     |Solorio, Torlakson,       |
          |     |                          |     |Torrico                   |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Bill Berryhill, Gaines    |Nays:|Conway, Harkey, Miller,   |
          |     |                          |     |Nielsen, Norby            |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :   Increases criminal penalties for willful failure to  
          pay wages.  Specifically,  this bill  :  

          1 Establishes a misdemeanor penalty for an employer or person  
            who willfully fails to pay all wages due to an employee who  
            has been discharged or who has quit within 90 days of the date  
            wages are due.

          2)Makes the aforementioned misdemeanor punishable by a fine of  
            not less than $1,000 and not more than $10,000, or by  
            imprisonment in a county jail for not more than six months, or  
            both.

          3)Requires an employer found guilty of the aforementioned  
            misdemeanor to pay, in addition to any criminal fines,  
            restitution to the aggrieved employee in an amount equal to  
            the total amount of unpaid wages.

          4)Requires an employer or person, upon conviction becoming  
            final, to pay all reasonable costs of prosecution to the  
            entity that prosecutes.  "Conviction" is defined as a verdict  
            of guilty or a plea of guilty or nolo contendere.










                                                                  AB 2187
                                                                  Page B

          5)Makes related legislative findings and declarations.

           EXISTING LAW  establishes misdemeanor criminal penalties for  
          various violations of the Labor Code, including the willful  
          failure to pay wages due.

           FISCAL EFFECT  :  According to the Assembly Appropriations  
          Committee, costs to the Division of Labor Standards Enforcement  
          (DLSE) are minor and absorbable.  In addition, this bill would  
          result in unknown, probably minor increase in penalty revenues  
          to the extent the provisions of the bill result in additional  
          prosecution, fines and penalties.

           COMMENTS  :  This measure is sponsored by the California Rural  
          Legal Assistance Foundation (CRLAF), who argues that it will  
          appropriately strengthen the hands of prosecutors who take on  
          theft of wages cases in the future, and will make certain that  
          restitution of all unpaid wages to aggrieved employees is  
          central to these prosecutions.

          CRLAF notes that various provisions of the Labor Code make it a  
          misdemeanor to fail to comply with wage payment laws.  However,  
          CRLAF argues that none of these statutes:  1) impose any  
          additional criminal sanctions if an unscrupulous employer fails  
          to pay wages that are due within a reasonable period of time; 2)  
          impose a significant minimum fine for such misconduct; (3)  
          require restitution to the employee of all unpaid wages; or, 4)  
          require a guilty party to pay the reasonable costs of a  
          successful prosecution.  In addition, CRLAF states that various  
          provisions of the California Constitution and the Penal Code  
          contain "victim's rights" restitutionary protections including a  
          mandatory "restitution fine" (for misdemeanor convictions,  
          ranging from not less than $100 to not more than $1,000) and  
          mandatory "full restitution" for an injured victim, but in both  
          instances a court has discretion not to assess any fine or not  
          to order full restitution if it finds that there are "compelling  
          and extraordinary" reasons to do so and states them on the  
          record.

          Therefore, CRLAF contends that this bill addresses each of the  
          four weaknesses identified in the Labor Code's provisions by:   
          1) making it a misdemeanor to fail to pay wages due, within 90  
          days, to an employee who quits or is discharged; 2) setting a  
          minimum fine of $1,000 and a maximum fine of $10,000 for this  









                                                                  AB 2187
                                                                  Page C

          violation; 3) requiring, in addition to the fine, full  
          restitution to each employee equal to the total amount of wages  
          not paid; and, 4) requiring payment of prosecution costs.

          Opponents, including the California Chamber of Commerce, argue  
          that this bill could make into criminals employers with  
          legitimate disputes over wage claims.  They contend that the  
          term "willfully fails" is vague and undefined, so it could be  
          construed to apply to wage disputes that are often not resolved  
          until long after 90 days.  For example, if an employer and  
          employee disagree over the amount of wages due, a Labor  
          Commissioner determination could take longer than 90 days.

          Opponents also argue that this bill could also be construed to  
          criminalize almost any wage-based lawsuit, such as overtime and  
          meal and rest period class actions, that might affect whether an  
          employee was paid "all wages due" at the end of employment.   
          These lawsuits have statutes of limitation from one to three or  
          more years and could also be pending in the courts for years in  
          appeals.  The threat of criminal prosecution under this bill  
          could unfairly force an employer to drop an otherwise reasonable  
          defense against a civil action.  Moreover, opponents express  
          concern that jail time and fines could be imposed against  
          individual employees who were following the directions of the  
          employer since the employer's "agents" and "employees" are  
          subject to liability under this bill.  This might include all  
          the employees in the payroll department and all the way up the  
          supervisorial chain.

          Finally, opponents question the necessity of this bill, since  
          existing law requires the employer to make the employee whole  
          and imposes stiff penalties of varying amounts, depending on the  
          wage dispute at issue, when the employer fails to pay wages due.  
           Moreover, current criminal laws outlaw theft, which permits  
          prosecution of ill-intentioned employers who steal money from  
          their employees.

           
          Analysis Prepared by  :    Ben Ebbink / L. & E. / (916) 319-2091 

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