BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 2773
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          Date of Hearing:  May 4, 2010

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                  Mike Feuer, Chair
                    AB 2773 (Swanson) - As Amended: April 8, 2010
                                           
          SUBJECT  :  EMPLOYMENT DISCRIMINATION: ATTORNEY'S FEES FOR  
          LOWER-WAGE WORKERS

           KEY ISSUE  :  WHEN LOWER-WAGE WORKERS PROVE THAT THEY WERE THE  
          VICTIMS OF UNLAWFUL EMPLOYMENT DISCRIMINATION, SHOULD THEY BE  
          ENTITLED TO RECOVER THEIR ATTORNEY'S FEES UNDER THE SAME RULES  
          AS MORE HIGHLY-PAID VICTIMS OF DISCRIMINATION, DESPITE  
          RECOVERING LOWER MONETARY DAMAGES THAN THE UNLIMITED CASE  
          THRESHOLD? 

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

                                      SYNOPSIS
          
          A recent California Supreme Court ruling upheld the denial of  
          attorney's fees to a victim of employment discrimination who  
          prevailed in the case but recovered less than the $25,000  
          jurisdictional limit for unlimited cases in state court.   
          Normally plaintiffs are presumptively entitled to attorney's  
          fees in such cases to ensure that employees are not deterred  
          from enforcing these important civil rights.  However, a  
          separate law rule allows judges to deny costs and attorney's  
          fees entirely when a plaintiff files the case under the  
          unlimited civil rules but fails to recover the jurisdictional  
          minimum.  When these two laws intersect, the Court held, the  
          rule allowing judges to deny fees for mis-denominated cases  
          trumps the rule that would otherwise make fees automatic.  

          Advocates for lower-wage workers believe the court's decision  
          will make it more difficult for the working poor to enforce  
          their rights when they are the victims of illegal  
          discrimination.  They argue that unlimited civil case procedures  
          are the only effective mechanism for prosecuting employment  
          discrimination disputes, and that lawyers should not be  
          penalized for not accurately predicting that the ultimate  
          outcome of the case would be above the $25,000 limit,  
          particularly because some aspects of damages recovery are  
          difficult to quantify.  The bill is opposed by the Civil Justice  








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          Association of California, which argues that an award of  
          attorney's fees to successful discrimination plaintiffs should  
          not be a routine event, and that it is appropriate for judges to  
          refuse to award attorney's fees in cases of nominal value.

           SUMMARY  :  Revises attorney's fees awards in small employment  
          discrimination cases.  Specifically,  this bill  exempts cases  
          brought under the Fair Employment and Housing Act (FEHA) from  
          the rule giving discretion to judges to deny fees in a case  
          other, than a limited civil case, if the prevailing party  
          recovers a judgment that could have been rendered in a limited  
          civil case.  

           EXISTING LAW  provides that a prevailing party is entitled as a  
          matter of right to recover costs in any action or proceeding,  
          and specifies those items allowable as costs, but provides that  
          costs, or any portion of claimed costs, shall be as determined  
          by the court, in its discretion, in a case, other than a limited  
          civil case, if the prevailing party recovers a judgment that  
          could have been rendered in a limited civil case.  (Code of  
          Civil Procedure section 1033.)

           COMMENTS  :  The author states that this bill will help ensure  
          that California workers have fair and equitable access to the  
          civil justice system for claims brought under the Fair  
          Employment and Housing Act (FEHA) by removing a significant  
          barrier to securing private counsel for lower wage workers. 

          The sponsor, California Employment Lawyers Association, argues  
          that this bill will ensure that plaintiffs are not punished for  
          being unable to predict damage awards, and are allowed more  
          extensive discovery procedures to address the complex nature of  
          claims brought under the FEHA.  Supporters note that this  
          proposal would still leave the trial court with broad authority  
          under Government Code Section 12965 to determine the amount of  
          reasonable attorney's fees, and the court may, if appropriate,  
          reduce a fee award if a plaintiff obtains only limited success,  
          so long as the claims on which the plaintiff prevails are  
          distinct from and unrelated to the unsuccessful claims.  (Harman  
          v. City and County of San Francisco (2006) 136 Cal. App.4th  
          1279, 1307, 39 Cal.Rptr.3d 589; Greene v. Dillingham  
          Construction N.A., Inc., supra, 101 Cal.App.4th at p. 423, 124  
          Cal.Rptr.2d 250.)

           Prevailing Plaintiffs In Employment Discrimination Cases Are  








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          Normally Entitled To Recover Attorney's Fees.   In any action  
          brought under the California Fair Employment and Housing Act  
          (FEHA) (Gov. Code,  12900 et seq.), Government Code section  
          12965(b) grants the trial court discretion to award attorney's  
          fees to a prevailing party.  This statute has been interpreted  
          to mean that in a FEHA action a trial court should ordinarily  
          award attorney's fees to a prevailing plaintiff unless special  
          circumstances would render a fee award unjust.  (Young v. Exxon  
          Mobil Corp. (2008) 168 Cal.App.4th 1467, 1474; Steele v. Jensen  
          Instrument Co. (1997) 59 Cal.App.4th 326, 331.)

           Recovery of Attorney's Fees For Lower-Wage Workers Is At Risk  
          Under A Recent Court Ruling.   Under existing law, a prevailing  
          party is generally entitled as a matter of right to recover  
          costs in any action or proceeding.  (Code Civ. Proc.,  1032,  
          subd. (b).)  The litigation costs that the prevailing party may  
          recover include attorney's fees when recovery of such fees is  
          authorized by statute.  (Id.,  1033.5, subd. (a)(10)(B).)  But  
          when "the prevailing party recovers a judgment that could have  
          been rendered in a limited civil case," and the action was not  
          brought as a limited civil case, Code of Civil Procedure section  
          1033(a) states that "costs or any portion of claimed costs shall  
          be as determined by the court in its discretion . . . ."  A  
          limited civil case is one in which the plaintiff believes the  
          amount in controversy does not exceed twenty-five thousand  
          dollars ($25,000) or one defined by statute as a limited civil  
          case (Code of Civil Procedure 86.)

          On January 14, 2010, the California Supreme Court held in Chavez  
          v. City of Los Angeles (2010) 47 Cal.4th 970, that a trial court  
          has discretion in a FEHA case to deny a successful plaintiff his  
          attorney's fees when the plaintiff chooses to proceed in an  
          unlimited civil jurisdiction, but recovers less than the $25,000  
          jurisdictional minimum. 

          This decision reversed the Court of Appeal's ruling, which  
          reasoned that the rationale for denying attorney's fees under  
          section 1033(a) of the California Code of Civil Procedure, which  
          was designed to encourage pursuit of minor grievances in courts  
          of limited jurisdiction, is inapposite to statutory  
          discrimination or civil rights actions because "even a modest  
          financial recovery can serve to vindicate a substantial legal  
          right."  The Court of Appeal also opined that denying attorney's  
          fees under section 1033(a) would discourage attorneys from  
          taking meritorious cases.  








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          The decision unfairly penalizes lower-wage workers and deters  
          enforcement actions, supporters state, because damages amounts  
          in FEHA claims, which often involve non-pecuniary damages, are  
          difficult to quantify and hard to predict.  They contend that  
          the legislature must step in to help ensure that plaintiffs'  
          attorneys are not discouraged from taking FEHA cases because  
          these cases are integral to protect and vindicate important  
          civil rights. 

           Is The Interest In Protecting Lower-Wage Workers From Illegal  
          Discrimination Sufficiently Important To Prevent Courts From  
          Denying Attorney's Fees When Illegal Discrimination Has Been  
          Proved?   As the California Supreme Court noted in its decision,  
          attorney's fee awards in FEHA actions make it easier for  
          plaintiffs of limited means to pursue meritorious claims  
          (Cummings v. Benco Building Services (1992) 11 Cal.App.4th 1383,  
          1387), are intended to provide fair compensation to the  
          attorneys involved in the litigation at hand, and encourage  
          litigation of claims that are of public interest (Flannery v.  
          Prentice (2001) 26 Cal.4th 572, 584).  
           
          Supporters of this measure contend that that limited  
          jurisdiction case procedure makes it generally inappropriate for  
          employment discrimination cases.  Most importantly, supporters  
          argue, limited jurisdiction cases are permitted very limited  
          discovery; in particular, only one deposition is allowed per  
          party.  Employment lawyers on both sides will acknowledge that  
          virtually no employment discrimination case can be proved with  
          these restrictions.  Discrimination generally requires proof of  
          intent - that is, state of mind - which typically depends on  
          showing a larger pattern of treatment.  Amassing that evidence  
          requires significant discovery by the plaintiff.  Unlike a  
          normal breach of contract or tort action, such as an auto  
          accident, for example, all of the relevant evidence regarding  
          motive is in the exclusive possession of the employer.   
          Therefore, plaintiffs must engage in substantial discovery to  
          prove their cases.

           If Lower-Wage Workers Are Deterred From Bringing Private  
          Enforcement Actions, They May Be Effectively Precluded From  
          Seeking Relief Because The Department Of Fair Employment And  
          Housing Reportedly Does Not Well Serve Those Who Cannot Obtain A  
          Lawyer.   The need for plaintiffs of limited means to access  
          private counsel to pursue their FEHA claims was highlighted in a  








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          recent UCLA-RAND study on the FEHA and its enforcement  
          procedures, supporters note.  As this Committee heard in its  
          recent oversight hearing regarding the Department of Fair  
          Employment and Housing (DFEH), this study found that lower-wage  
          workers are much less able to secure private counsel because the  
          amount of damages they are allowed to recover under the FEHA  
          compared to the amount of legal work needed to prosecute the  
          case and the risks involved makes it economically difficult for  
          attorneys, most of whom are small business owners operating as  
          sole practitioners, to take on this representation.  

          This is unfortunate, because the UCLA-RAND study found,  
          employees who are represented by lawyers prevail far more  
          frequently and obtain much better relief than those who must  
          rely on the DFEH.  According to this study, employees who take  
          their case to trial win about half the time with jury awards  
          averaging $205,000.  Those who stay in the state's  
          administrative system recover anything at all in 1 case out of  
          7, and even then receive an average of only $3,000.



          The study found:

               At present, we have two anti discrimination systems -  
               separate and unequal.  Those with lawyers operating on  
               contingency fees have access to a civil justice system.   
               Others depend on the alternative provided by the DFEH and  
               the FEHC.  Access to those two systems appears to vary  
               systematically by race, by occupation, and by sex.  The  
               barrier to private counsel has been raised even higher very  
               recently.  The California Supreme Court held in Chavez v.  
               City of Los Angeles (2010 WL 114941, January 14, 2010) that  
               in FEHA cases that might have been brought in a limited  
               jurisdiction Superior Court but were litigated to a verdict  
               of less than the $25,000 in a general jurisdiction Superior  
               Court, the court may deny attorneys' fees to the prevailing  
               plaintiff.  Thus any attorney who considers accepting a  
               case that may result in a verdict under the jurisdictional  
               amount risks being paid nothing at all, even if he or she  
               prevails at trial, based on his or her inability to predict  
               a jury verdict.  Although most plainti ff s' lawyers were  
               already reluctant to accept smaller cases, their  
               disincentive to do so is now increased.









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          (G. Blasi & J. Doherty, California Employment and Discrimination  
          Law and Its Enforcement: The Fair Employment and Housing Act at  
          50, p. 65 (2010).)  

           This Bill Would Appear To Address Concerns By Non-Profit Public  
          Interest Law Organizations.  
          The Asian Pacific American Legal Center, Bet Tzedek Legal  
          Services, The Impact Fund, Public Counsel, and The Western  
          Center On Law And Poverty filed an amicus brief on the side of  
          the plaintiff in the Chavez case, arguing that the case  
          presented an issue of critical importance to California's  
          working poor.  According to their brief, these organizations  
          represent low-wage workers "who, when they are the victims of  
          illegal discrimination or retaliation in the workplace, often  
          cannot show calculable economic damages in amounts that would  
          automatically meet the requirement for filing suit in a court of  
          unlimited jurisdiction.  This is, in part, because these workers  
          earn extremely low wages.  Also, in order to survive, these  
          workers must immediately mitigate any damages they suffer from  
          termination or other adverse employment actions by seeking new  
          employment, as the loss of wages for even one day or one week  
          can itself render a
          low-wage employee unable to feed, clothe, and house herself and  
          her family.  Finally, low-wage workers do not have the luxury of  
          seeking professional treatment for the emotional distress that  
          often accompanies discriminatory and retaliatory employment  
          practices."

          These organizations noted that FEHA advances the constitutional  
          and legislative mandate to eradicate discrimination in the  
          workplace.  "Given limited governmental resources available to  
          combat discrimination, FEHA's effectiveness depends on the  
          initiation of private lawsuits to combat discrimination.  A  
          private lawsuit remedy, however, is illusory if a victim of  
          discrimination is unable to afford an attorney to prosecute his  
          or her case.  FEHA solves that problem by providing attorney  
          fees to the prevailing party."  [Giving] a court discretion to  
          deny "costs" to a prevailing party if the damage award is an  
          amount that could have been obtained in a court of limited  
          jurisdiction, overrides FEHA's attorney fee standard and permits  
          a trial court discretion to deny fees simply because the damage  
          award is low."  According to these amici, denying attorney's  
          fees in these cases would "disproportionately affect those the  
          FEHA's attorney fees provision was designed to protect: the  
          indigent victims of discrimination and retaliation, who are  








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          wholly dependent on attorney fees to entice competent counsel to  
          take their cases. Without the same prospect for obtaining fees  
          as any other attorney prevailing in a FEHA matter, an attorney  
          presented with a clear case of discrimination against a  
          low-income employee would face an untenable choice: file the  
          claim in a court of limited jurisdiction, thereby guaranteeing  
          attorney fees but limiting the client's potential recovery of  
          noneconomic and punitive damages; or file the claim in superior  
          court and risk obtaining no fees if the client's award is  
          limited to low economic damages. An attorney faced with such a  
          dilemma may simply decline to take the case."

           ARGUMENTS IN OPPOSITION:   The Civil Justice Association of  
          California opposes the bill, arguing that it "will undo a  
          judicial deterrent to filing frivolous lawsuits." 

          CJAC "believes it is appropriate for judges to use their  
          discretion to refuse to award attorney's fees in case of nominal  
          value and therefore opposes the bill.  Allowing the award of  
          attorney's fees to successful plaintiffs should not be a routine  
          event.  While our Legislature and our courts have allowed the  
          award of attorney's fees, the rationale behind such awards is to  
          compensate the attorneys for involvement in litigation that  
          somehow benefits the public.  Such awards are discretionary and  
          should remain so." 

          CJAC concludes, "If we allowed all cases involving $5,000 in  
          controversy to be filed and litigated as unlimited civil cases,  
          our courts would be even more clogged and backlogged than they  
          are." 

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Employment Lawyers Association (sponsor)
          California Labor Federation
          California Rural Legal Assistance Foundation
          Consumer Attorneys of California
          Employment Law Center, Legal Aid Society of San Francisco
          Equal Rights Advocates
          Western Center on Law and Poverty

           Opposition 
           








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          Civil Justice Association of California
           
          Analysis Prepared by  :  Kevin G. Baker / JUD. / (916) 319-2334