BILL ANALYSIS                                                                                                                                                                                                    �



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          Date of Hearing:   March 22, 2011

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                  Mike Feuer, Chair
                  AB 173 (Gatto) - As Introduced:  January 20, 2011

                             As Proposed to be Amended 
           
          SUBJECT  :  ARMENIAN GENOCIDE VICTIMS:  INSURANCE CLAIMS

           KEY ISSUE  :  SHOULD ARMENIAN GENOCIDE VICTIMS, and their heirs or 
          beneficiaries, BE PERMITTED TO FILE SUIT IN CALIFORNIA AGAINST 
          CERTAIN INSURERS UNTIL December 31, 2013, notwithstanding 
          failure to comply with any otherwise applicable statute of 
          limitation? 

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

          This bill seeks to revive and extend a statute, first enacted in 
          2000, that gave victims of Armenian Genocide, or their heirs or 
          beneficiaries, until December 31, 2010, to file insurance claims 
          arising out of policies that were purchased or in effect in 
          Europe or Asia between 1875 and 1923.  Under the existing 
          statute of limitation, any action based upon a contract, 
          obligation, or liability "founded upon an instrument in writing" 
          must be filed within four years of accrual of a cause of action. 
           Because of the absence of documents (including death 
          certificates) and dislocations caused by war, persecution, and 
          deportation between 1915 and 1923, many of the beneficiaries 
          under these policies could not possibly have brought actions 
          within the four year statute of limitation.  As such, in 2000 SB 
          1915 provided that no action brought by a victim, heir, or 
          beneficiary to recover proceeds would be barred by any statute 
          of limitation so long as the action was brought before December 
          31, 2010.  In 2009, Ninth Circuit Court of Appeal found that the 
          measure was preempted by federal law under the foreign policy 
          field preemption doctrine. Upon rehearing, however, the Ninth 
          Circuit reversed itself in an opinion issued on December 10, 
          2010.  Thus, the constitutional bar that might have precluded 
          renewal and extension of this particular statute has been 
          removed.  The bill as introduced extended the time to bring an 
          action another ten years, until December 31, 2020, but it is the 








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          assessment of the Committee that the intent of the 2000 
          legislation was not to create a renewable sunset, but rather to 
          give known claimants otherwise barred by the statute of 
          limitation until December 31, 2010, to bring their claims.  That 
          period would have already expired regardless of any action by 
          the Court.  Thus, the only persons who were affected by the 
          court's reversal are those who abandoned a claim in light of the 
          2009 ruling and did not have time to revive it given that only 
          three weeks separated the court's reversal and the deadline.  
          Therefore, the Committee is proposing a two-year extension until 
          December 31, 2013.  The following bill summary and analysis 
          reflects that proposed amendment.  In order to bring justice to 
          victims, the author wishes to take an amendment in Committee 
          adding an urgency clause so that the bill will take effect 
          immediately. 
           
          SUMMARY  :  Permits Armenian Genocide victims, as defined, or 
          their heirs or beneficiaries, who are residents of this state, 
          to file suit in a California court against certain insurers to 
          recover proceeds due under specified insurance policies until 
          December 31, 2013.  Specifically,  this bill  :

          1)Defines "Armenian Genocide victim" to include any person of 
            Armenian or other ancestry living in the Ottoman Empire during 
            the period of 1915 to 1923, inclusive, who died, was deported, 
            or escaped to avoid persecution during that period.

          2)Defines "insurer" to mean any insurance provider doing 
            business in California, or that is otherwise subject to 
            California jurisdiction, that sold insurance policies covering 
            persons or property in Europe or Asia at any time between 1875 
            and 1923. 

          3)Permits, notwithstanding any other provision of law, an 
            Armenian Genocide victim, or the heir or beneficiary of an 
            Armenian Genocide victim, who resides in this state and has a 
            claim arising out of an insurance policy or policies purchased 
            or in effect in Europe or Asian between 1875 and 1923, to 
            bring an action or continue a pending action in a California 
            court, which shall be deemed the proper forum for that action 
            until its completion or resolution. 

          4)Provides that any action described above shall not be 
            dismissed for failure to comply with the applicable statute of 
            limitation, provided the action is filed on or before December 








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            31, 2013. 

           EXISTING LAW  : 

          1)Generally provides a statute of limitation for commencing a 
            civil action.  For actions based "upon any contract, 
            obligation or liability founded upon an instrument in 
            writing," the accrual period is generally four years.  
            However, the Legislature may by statute prescribe other 
            limitations or no limitation at all.  (Code of Civil Procedure 
            Sections 312 and 337.)

          2)Permits an owner, or the heir or beneficiary of an owner, of 
            Holocaust-era artwork taken as a result of Nazi persecution 
            between 1929 and 1945, to bring an action in a California 
            court to recover the artwork from any gallery or museum that 
            displays, exhibits, or sells articles of historical, 
            interpretive, scientific, or artistic significance.  Provides 
            that such an action shall not be dismissed for failure to 
            comply with any applicable statute of limitation so long as 
            the action is commenced on or before December 31, 2010.  (Code 
            of Civil Procedure Section 354.3.  Held preempted in Von Saher 
            v. Norton Simon Museum of Art of Pasadena (2010) 592 F.3d 
            954.) 

          3)Permits an Armenian Genocide victim, as defined, or the heirs 
            or beneficiary of a victim, to bring an action in California 
            court to recover proceeds from an insurance policy that was 
            issued or in effect in Europe or Asia between 1875 and 1923.  
            Provides that such an action shall not be dismissed for 
            failure to comply with any applicable statute of limitation so 
            long as the action is commenced on or before December 31, 
            2010.  (Code of Civil Procedure Section 354.4.  Held preempted 
            in Movsesian v. Victoria Versicherung AG (2009) 578 F.3d 1052; 
            reversed upon rehearing, Movsesian v. Victoria Versicherung AG 
            (Dec. 10, 2010) 629 F.3d 901; 2010 US App LEXIS 24225.)

          4)Permits a Holocaust victim, as defined, or the heirs or 
            beneficiary of a victim, to bring an action in California 
            court to recover insurance proceeds from a policy issued in 
            Europe before 1945.  Provides that such an action shall not be 
            dismissed for failure to comply with any applicable statute of 
            limitation so long as the action is commenced on or before 
            December 31, 2010.  (Code of Civil Procedure Section 354.5.  
            Held preempted in Steinberg v. International Commission on 








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            Holocaust Insurance Claims (2005) 133 Cal. App. 4th 944.)

          5)Permits a Second World War slave or forced labor victim, as 
            defined, or the heirs or beneficiaries of the victim, to bring 
            an action to recover compensation for the slave or forced 
            labor performed against any entity, or successor in interest 
            thereof, for whom that labor was performed, either directly or 
            through a subsidiary or affiliate.  Provides that no such 
            action shall be barred on statute of limitation grounds so 
            long as the action is filed on or before December 31, 2010.  
            (Code of Civil Procedure Section 354.6.  Held preempted in 
            Deutsch v. Turner Corp. (2003) 317 F.3d 1105; and Steinberg v. 
            International Commission on Holocaust Insurance Claims (2005) 
            133 Cal. App. 4th 944.)

           COMMENTS  :  The author introduced this bill to ensure that 
          victims of the Armenian genocide, and their heirs or 
          beneficiaries, would be provided an opportunity to resolve their 
          insurance claims on the merits.  During the late nineteenth and 
          early twentieth centuries, insurance companies marketed 
          insurance policies to Armenians living in historic Armenia, then 
          part of the Ottoman Empire.  It is estimated that approximately 
          10,000 polices were sold at that time.  From 1915 until 1923, 
          most scholars agree, approximately 1.5 million Armenians were 
          subject to forced marches, torture, and murder.  Families were 
          separated and those who were not killed were either deported or 
          fled persecution.  

          Although the number of persons residing in California who 
          directly experienced the Armenian Genocide is of course 
          dwindling, many heirs and beneficiaries entitled to proceeds 
          under insurance policies purchased by the victims still reside 
          in the state.  Although many California families have sought to 
          resolve these claims, the dislocation caused by war and diaspora 
          has made it difficult for them to document that their family 
          members were insured.  Additionally, as the author of the 
          original legislation noted, there is evidence that insurers 
          demanded that the survivors produce death certificates, even 
          though neither the Ottoman or Turkish governments ever issued 
          death certificates for the hundreds of thousands of Armenian 
          victims.  Finally, even when families overcame these obstacles 
          and gathered the necessary evidence and documents, they found 
          that their claims were barred by a four-year statute of 
          limitation on bringing claims for liabilities based on a written 
          document.  In order to address this problem, SB 1915 








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          (Poochigian, Chapter 543, Stats. of 2000) gave victims, heirs, 
          and beneficiaries of the Armenian Genocide until December 31, 
          2010, to bring their causes of action, even if those actions 
          were otherwise barred by the applicable statute of limitation. 

           Background: Federal Preemption and State Causes of Action.    
          Section 354.4 of the Code of Civil Procedure (CCP), the original 
          statute extending the time for bringing actions to victims of 
          the Armenian Genocide and their heirs, was one of a series of 
          measures enacted between 1998 and 2002 that extended the statute 
          of limitation for victims of wartime atrocities.  All of these 
          statutes permitted claimants to bring their actions until 
          December 31, 2010.  CCP Section 354.3 permits persons to bring 
          claims to recover "Holocaust-era artworks" taken by the Nazis 
          during World War II.  CCP Section 354.5 permits victims of the 
          Holocaust, or their heirs or beneficiaries, to bring claims 
          based on insurance policies issued in Europe before 1945.  CCP 
          Section 354.6 permits victims of Nazi slave and forced labor 
          programs to recover compensation for labor from any entity, or 
          its successor in interest, who benefitted from that labor. 

          All of these statutes have been successfully challenged on 
          preemption grounds, although the ruling originally striking down 
          the Armenian Genocide statute was subsequently reversed upon 
          rehearing.  �See Von Saher v. Norton Simon Museum of Art of 
          Pasadena (2010) 592 F.3d 954 (holding that CCP Section 354.3, on 
          recovery of art, was preempted under the foreign policy field 
          preemption doctrine); Steinberg v. International Commission on 
          Holocaust Insurance Claims (2005) 133 Cal. App. 4th 944 (holding 
          that CCP 354.5, on Holocaust-era insurance claims, was preempted 
          by a federal policy favoring settlement of such claims through 
          the International Commission on Holocaust Era Insurance Claims); 
          Deutsch v. Turner Corp. (2003) 317 F.3d 1105 (holding that CCP 
          354.6, on slave labor, was preempted under foreign policy field 
          preemption doctrine); Movsesian v. Victoria Versicherung AG 
          (2009) 578 F.3d 1052 (holding that CCP 354.4, on Armenian 
          Genocide insurance claims, was preempted by federal law; 
          reversed upon rehearing, Movsesian v. Victoria Versicherung AG 
          (Dec. 10, 2010) 629 F.3d 901; 2010 US App LEXIS 24225.]

          In its recent reversal on the Armenian Genocide statute, the 9th 
          Circuit Court of Appeal distinguished its ruling from its prior 
          holding in Deutsch v. Turner, the 2003 opinion that voided the 
          slave labor compensation statute.  In Deutsch, the 9th Circuit 
          held that any state effort to create a private right of action 








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          for "war related injuries" intruded upon the federal 
          government's "exclusive powers of matters related to war."  The 
          court distinguished the Armenian genocide insurance cases, on 
          the other hand, holding that these were private claims against 
          private insurance companies, and therefore were not matters 
          relating to war.  Moreover, the post-World War I agreements 
          created a commission to settle claims of "American citizens" 
          against "the German government or German nationals."  It did not 
          cover claims by Armenian citizens of the Ottoman Empire, or 
          their heirs, against private insurance companies.  In addition, 
          the court noted that the Legislature defined the period of the 
          Armenian Genocide as extending from 1915 to 1923, revealing the 
          Legislature's understanding that the genocide continued after 
          the end of the War by five years, and even after the relevant 
          post-war agreement by one year, and therefore claims arising as 
          a result of the genocide could not have been included in 
          agreements ending the war. 

          Although the court did not expressly distinguish the latest case 
          from Von Saher - the 9th Circuit ruling invalidated CCP 354.3 on 
          recovery of Holocaust art - it did note that the Nazi art case 
          also involved "field preemption" and a "matter of war," whereas 
          the Armenian insurance actions were private claims in an area of 
          traditional state concern. 

          While one can distinguish rulings voiding the slave labor and 
          Nazi art theft statutes, the Court's reversal of the Armenian 
          Genocide insurance claims might, at first glance, suggest that 
          CCP 354.5, relating to Holocaust insurance claims, could be also 
          salvaged - since it too deals with "private" insurance claims 
          and not strictly speaking "matters of war."  However, in 
          Steinberg v. Int'l Comm. on Holocaust Era Insurance Claims 
          (2005), the 9th circuit found an express federal policy in a 
          United States executive agreement with several European nations 
          to the effect that all insurance- related claims should be 
          processed through the International Commission on Holocaust Era 
          Insurance Claims (ICHEIC).  So even though the Nazi era 
          insurance claims could also be seen as private matters and not 
          "matters of war," the United States has nonetheless entered into 
          an international agreement dealing expressly with Nazi-era 
          insurance claims.  There was no such international agreement 
          that the United States signed pertaining to the Armenian 
          genocide insurance claims.  

           Rationale for Extending the Deadline for Armenian Genocide 








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          Insurance Claims  .  While the 9th Circuit's recent reversal 
          removes any constitutional bar to renewing CCP Section 354.3, it 
          is not clear to the Committee how the court rulings justify an 
          additional ten year extension of the statute.  The author's 
          desire to "renew" the statute for another ten years implies that 
          the original deadline of December 31, 2010, was intended as a 
          sunset provision subject to renewal.  However, nothing in the 
          legislative history or the express language of SB 1915 suggests 
          that possibility.  Rather, it appears that the measure was 
          intended to give more time to known claimants whose efforts to 
          recover had been frustrated by lack of documentation and/or an 
          expired statute of limitation.  That deadline has now passed, 
          and there is no suggestion in the legislative history to suggest 
          that this was intended to be an ever-moving deadline.  If that 
          were the intent of the Legislature, it could have eliminated a 
          statute of limitation for such causes of action entirely, but it 
          chose not to do so.  However, it is possible that some claimants 
          who intended to file an action before 2010, but who had still 
          not done so by the time of the 2009 ruling striking down the 
          statute, abandoned those actions after the first ruling.  When 
          the Court reversed itself on December 10, 2010, those claimants 
          would have had only three weeks, assuming they were even aware 
          of the ruling, to revive their abandoned causes of actions.  
          Because many claimants may have abandoned their claims in 
          reliance on the first ruling, it seems fair to give those 
          persons additional time to re-file those claims.  Two years 
          seems a reasonable period of time to revive those claims. 

          Finally, the author proposes to amend the bill in Committee to 
          add an urgency clause, so that the measure will take effect 
          immediately and allow affected claimants to proceed immediately. 
           This change is reflected in the amendments proposed below.

           Proposed Committee Amendment:  

             -    On page 2 line 31 delete "2020" to and insert 2013. 

           Proposed Author Amendments  :

             -    In line 2 of the title, after "Genocide" insert:

            , and declaring the emergency thereof, to take effect 
            immediately

             -    On page 2, below line 35, insert:








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            SEC. 2. This act is an urgency statute necessary for the 
            immediate preservation of the public peace, health, or safety 
            within the meaning of Article IV of the Constitution and shall 
            go into immediate effect.  The facts constituting the 
            necessity are:
                 In order that the insurance policy claims of Armenian 
            Genocide victims will not be dismissed for failure to comply 
            with the statute of limitations, it is necessary that this 
            bill take effect immediately. 

           ARGUMENTS IN SUPPORT  :  According to the Consumer Attorneys of 
          California, extending the deadline for filing a cause of action 
          "will assist �Armenian Genocide] victims in their efforts to 
          seek justice through our legal system."  AFSCME writes in 
          support of this bill: "Given the scope of an atrocity like the 
          Armenian Genocide, the equitability of a statute of limitation 
          on legal actions is difficult to determine."  Extending the 
          deadline, AFSCME believes, will allow "more time for Armenian 
          Genocide victims in the state, and their heirs or beneficiaries, 
          to build cases, find materials, and take legal action."

           ARGUMENTS IN OPPOSITION  :  The Turkish Peace and Justice 
          Committee of California (TP&J) opposes this bill for two 
          reasons.  First, TP&J claims that Armenian victims and their 
          families already received a $20 million settlement with New York 
          Life Insurance and a $17 million settlement with the French 
          insurer AXA in 2005.  Second, TP&J claims that "the federal 
          government has made a conscious decision not to apply the 
          politically charged label of 'genocide' to the deaths of these 
          Armenians during World War I," and therefore it is "shocking to 
          see CA lawmakers disregarding U.S. interests at a most vital 
          time for our economic recovery and national security." 

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          AFSCME
          Consumer Attorneys of California

           Opposition 
           
          Turkish Peace and Justice Commission of California 
           








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          Analysis Prepared by  :    Thomas Clark / JUD. / (916) 319-2334