BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 156
                                                                  Page  1

          CONCURRENCE IN SENATE AMENDMENTS
          AB 156 (Lara)
          As Amended  June 29, 2011
          Majority vote
           
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          |ASSEMBLY:  |74-0 |(May 23, 2011)  |SENATE: |36-0 |(August 31,    |
          |           |     |                |        |     |2011)          |
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           Original Committee Reference:    G.O.  

           SUMMARY  :  Provides that a gambling establishment that conducts 
          play of a controlled game that has been approved by the 
          Department of Justice (DOJ), but is later found to be unlawful, 
          has an absolute defense to any criminal, administrative, or 
          civil action provided the game was being played in the manner 
          approved and, during the time for which it was approved, and 
          play ceases upon notice that the game has been found unlawful. 

           The Senate amendments  :  

           1)Delete language that permitted a contract for the sale or 
            lease of real or personal property to specify a closing date 
            earlier than 90 days after the submission of the contract to 
            the California Gambling Control Commission (CGCC) if the 
            commission had approved the contract and the parties had 
            requested it.

          2)Provide that a contract for the sale or lease of real or 
            personal property that requires the approval or licensing of 
            the purchaser by the Commission shall not specify a 
            transaction closing date that is prior to the approval or 
            licensing by the CGCC.

          3)Require a contract for the sale of a gambling enterprise to 
            state whether any outstanding gaming chips from the seller 
            will be honored by the purchaser, and provides for redemption 
            of gaming chips by either the seller or the purchaser in the 
            event the purchaser does not intend to sue the same gaming 
            chips in use by the seller. 

          4)Provide that in any enforcement action, the gambling 
            enterprise shall have the burden of proving that the 
            department approved the controlled game and that the game was 








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            played in the manner approved. 

           EXISTING LAW  :

          1)Provides pursuant to the Act, the licensure of certain 
            individuals and gambling establishments involved in various 
            gambling activities, and for the regulation of those 
            activities, by the CGCC.

          2)Provides for the enforcement of those activities by the Bureau 
            of Gambling Control (Bureau) within DOJ.

          3)Limits the transfer of property if the transferee has to be 
            approved or licensed by the commission, and specifically 
            prohibits a contract for sale or lease of real or personal 
            property that requires approval of the commission, as 
            specified, from specifying a closing date earlier than 90 days 
            after the submission of the contract to the commission, as 
            specified.

          4)Requires CGCC to approve the play of any controlled game, 
            including, but not limited to, placing restrictions and 
            limitations on how a controlled game is played.  

          5)Provides that a banking game does not include a controlled 
            game if the published rules of the game feature a 
            player-dealer position and provide that this position must be 
            continuously and systematically rotated amongst each of the 
            participants during the play of the game, and if other 
            specified conditions are met.

          6)Defines "house" to mean the gambling enterprise, and any 
            owner, shareholder, partner, key          employee, or 
            landlord thereof.

          7)Defines "gambling enterprise" to mean a natural person or an 
            entity, whether individual, corporate, or otherwise, that 
            conducts a gambling operation and that by virtue thereof is 
            required to hold a state gambling license under the Act..

           FISCAL EFFECT  :  Unknown

           COMMENTS  :  According to the bill's sponsor, Commerce Club 
          Casino, this bill will provide that if a card club is playing a 
          controlled game approved by the Bureau of Gambling Control 








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          (Bureau) within DOJ in the manner in which it was approved, the 
          approval by Bureau shall be an absolute defense to any action 
          that is brought through the criminal courts, administrative 
          courts, or civil courts if the game being played is later ruled 
          to be deemed unlawful. 

          In at least one situation, a game approved by Bureau was 
          subsequently found to be unlawful by the Court of Appeal. The 
          Attorney General then brought administrative action against 
          numerous card clubs for playing a game which they had approved.  
          This bill seeks to insulate a club from criminal, civil and 
          administrative action if a game that has been approved by the 
          Bureau and is played in the manner in which it was approved.

           Similar language vetoed last year  .  SB 1125 (Florez) of 2010, 
          was vetoed by Governor Schwarzenegger.  The bill contained two 
          provisions, one of which is in this bill.  SB 1125 contained the 
          same "absolute defense" language which stated that a gambling 
          establishment that conducts play of an approved controlled game 
          that is subsequently found to be            unlawful shall be 
          protected from any criminal, administrative, or civil action, 
          provided that the game was played in an approved manner and was 
          not played after it was found to be illegal.
           
          The veto message stated in part  :  

              This past legislative session, my Administration 
              sponsored several bills to address the issue of 
              tort reform.  Similar to this measure, one of these 
              measures provided for limited immunity for 
              businesses that engaged in conduct that was 
              approved by a federal or state agency.  However, 
              even this modest reform contained a provision that 
              prevented an absolute defense if the business in 
              question intentionally misrepresented material 
              information or defrauded the public entity that 
              gave its approval. 

              I am unable to sign this bill because, unlike the 
              measure previously mentioned, this bill does not 
              take into account possible misconduct by a gambling 
              establishment that may have induced the Bureau to 
              erroneously approve a controlled game.  In 
              addition, there may be other instances where a 
              gambling establishment may be playing a controlled 








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              game in bad faith and in violation of other 
              provisions of existing law.  Notwithstanding the 
              fact that the Bureau may have approved such 
              conduct, that approval alone should not constitute 
              an absolute defense to all civil, criminal, or 
              administration actions.


           Analysis Prepared by  :    Felipe Lopez / G. O. / (916) 319-2531 


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