BILL ANALYSIS                                                                                                                                                                                                    



                                                                SB 220
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        SENATE THIRD READING
        SB 220 (Yee)
        As Amended  July 16, 2009
        Majority vote 

         SENATE VOTE  :21-15  
         
         JUDICIARY           7-2         APPROPRIATIONS      11-5         
         
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        |Ayes:|Feuer, Brownley, Evans,   |Ayes:|De Leon, Ammiano, Charles   |
        |     |Jones, Krekorian, Lieu,   |     |Calderon, Coto, Davis,      |
        |     |Monning                   |     |Fuentes, Hall,              |
        |     |                          |     |John A. Perez, Skinner,     |
        |     |                          |     |Solorio, Torlakson          |
        |     |                          |     |                            |
        |-----+--------------------------+-----+----------------------------|
        |Nays:|Knight, Silva             |Nays:|Nielsen, Duvall, Harkey,    |
        |     |                          |     |Miller,                     |
        |     |                          |     |Audra Strickland            |
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        SUMMARY  :  Reforms the Whistleblower Protection Act (WPA).   
        Specifically,  this bill  :
         
         1)Permits the SPB to issue a right-to-sue notice, upon request of  
          the complainant, if timely requested within 10 days of submission  
          of the written complaint.  

        2)Specifies the contents of the notice, the courts with  
          jurisdiction, and the statute of limitations after an  
          administrative complaint is withdrawn. 

        3)Authorizes the SPB, after investigation and hearing, to order, in  
          addition to existing appropriate relief to a successful  
          complainant, the transfer to or placement of the complainant into  
          any vacant position for which the employee is qualified, and  
          reasonable attorney's fees and costs, and further authorizes the  
          administrative law judge presiding over the hearing to make any  
          order as may appear just in order to prevent any named party from  
          being embarrassed, delayed, or put to unnecessary expense, and any  
          other order as the interests of justice may require. 

        4)Clarifies that WPA covers former state employees who were covered  








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          by the Act during their employment.

        5)Clarifies that "protected disclosure" includes communications  
          based on, or when carrying out, job duties, that disclose  
          information evidencing improper governmental activity or that  
          threaten the health or safety of employees or the public.

        6)Provides that the SPB may receive and investigate any improper  
          acts alleged in a complaint asserting a violation of existing law.

         FISCAL EFFECT  :  According to the Assembly Appropriations analysis:

        1)Minor administrative cost savings to the SPB from avoided  
          investigatory workload as a result of WPA complainants instead  
          requesting right-to-sue notices.

        2)The net impact of authorizing the SPB to award attorney's fees  
          should be potentially moderate savings in state litigation costs.  
          This is because, according to SPB staff, if the SPB finds that a  
          plaintiff was a victim of retaliatory action under the Act, that  
          person typically will proceed to file an action in court, where  
          upon receiving a successful outcome (as is typical following the  
          board's finding), the plaintiff is awarded attorney's fees and may  
          receive punitive damages. With the board specifically authorized  
          to award attorney's fees under this bill, it is less likely that a  
          successful plaintiff will proceed to file an action with the  
          court.
         
        COMMENTS  :  In support of the bill the author states, "Whistleblowers  
        play a vital role in saving tax dollars and preventing waste, fraud,  
        and abuse.  Whistleblowers expose wrongdoing and inefficiency in our  
        state government.  It is our duty as the government of California to  
        encourage whistleblowing and to protect whistleblowers from  
        retaliation.  When a whistleblower alleges retaliation, it is  
        essential that we guarantee that their contentions receive prompt  
        and impartial investigations."

        The author explains the reason for the bill as follows:  "The  
        California Supreme Court ruled this year that state whistleblowers  
        who allege retaliation may take their case to Superior Court 60 days  
        after their complaint is filed with the State Personnel Board (SPB).  
         This is a great step forward for our government, but poses a  
        problem: with this new ability for all whistleblowers to go to  
        court, unnecessary expenses are imposed on the state and on the  








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        whistleblower by forcing people to go through the administrative  
        hearing process as well.  In cases in which the whistleblower knows  
        at the outset that they want to go to Superior Court, requiring them  
        to first go through the 60-day administrative remedy wastes their  
        time and money as well as the state's time and money.  SB 220 will  
        make the whistleblower retaliation hearing process more efficient  
        and effective by allowing whistleblowers to opt-out of the  
        administrative remedy.  Rather than wasting the state's and the  
        whistleblower's money on an unwanted 60 day administrative process,  
        this bill allows the SPB to issue a right-to-sue notice at the  
        outset"

        Current law requires an aggrieved individual to file a written  
        complaint with the SPB, and the SPB to initiate an investigation or  
        a hearing within 10 working days of the submission of the complaint.  
         The investigation and/or hearing must be completed by the end of 70  
        days (60 days after the initial 10 days in which to act).  This bill  
        would require the SPB to issue a right-to-sue notice if requested by  
        the complainant within the specified time period.  The bill would  
        specify the statute of limitations for the filing of a complaint in  
        superior court, which would start upon the receipt of the SPB  
        right-to-sue notice, consistently with comparable law.  

        In February, 2009, the California Supreme Court affirmed the right  
        of a state employee to sue in superior court, as a parallel action  
        to the administrative proceeding at the SPB.  (State Chiropractic  
        Examiners, et al. v. Superior Court of Sacramento County (Carole M.  
        Arbuckle, Real Party in Interest) (2009) 45 Cal.4th 963.)  While SB  
        220 is aimed at streamlining the administrative process for a  
        complaint of retaliation for whistleblowing activity, Arbuckle  
        leaves no doubt that an aggrieved employee does not have to exhaust  
        the administrative process (i.e., complete the SPB hearing process  
        and have an adverse SPB ruling set aside) before going to superior  
        court with a complaint for damages.  In other words, once a  
        complaint is filed with the SPB and accepted as being complete, the  
        employee is free to seek damages in superior court. Some  
        complainants wish to pursue the administrative process at the SPB  
        rather than filing a lawsuit.  In order to make this option more  
        viable, SB 220 would expand the available remedies that the SPB may  
        order for an employee found to have been wronged by a violation of  
        the SPB to include a transfer or placement in any vacant position  
        for which the employee is qualified (if requested and consented to  
        by the employee).  









                                                                SB 220
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         Analysis Prepared by  :    Kevin G. Baker / JUD. / (916) 319-2334 FN:  
        0001948