BILL ANALYSIS                                                                                                                                                                                                    �






                             SENATE JUDICIARY COMMITTEE
                             Senator Noreen Evans, Chair
                              2011-2012 Regular Session


          AB 360 (Brownley)
          As Amended June 27, 2011
          Hearing Date: July 5, 2011
          Fiscal: No
          Urgency: No
          TW
                    

                                        SUBJECT
                                           
              Charter Schools: Governing Boards: Conflicts of Interest

                                      DESCRIPTION  

          Existing law requires a public school district to comply with 
          the open meeting and public disclosure requirements under the 
          Ralph M. Brown Act (Brown Act), Bagley-Keene Open Meeting Act 
          (Bagley-Keene Act), and the California Public Records Act 
          (CPRA), and the conflict of interest disclosure requirements 
          under the Political Reform Act (PRA).  This bill would extend 
          these requirements to a charter school.  This bill also would 
          exempt from criminal liability certain financial transactions, 
          as specified, between a board member and the charter school.  
          This bill would become operative on July 1, 2012.

                                      BACKGROUND  

          In 1992, the Legislature enacted the California Charter Schools 
          Act in order to provide communities with the opportunity to 
          establish schools that could operate freely from the structural 
          programs of public school districts.  (SB 1448 (Hart, Ch. 781, 
          Stats. 1992).) Charter schools are intended to provide a unique 
          learning environment, giving students a different approach to 
          scholastic achievement.  In the 2007-2008 State of California 
          Education report, 675 charter schools were in operation, serving 
          almost 250,000 students.  (Education Data Partnership, May 22, 
          2009.)  In the 18 years of charter school existence in 
          California, many reports of widespread financial mismanagement 
          of charter schools' public funds have led to the belief that 
          public disclosure and conflict of interest laws need to be 
          established for charter schools.  
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          As reported by the Los Angeles Times, in 2005, the 
          Superintendent of Public Instruction and various California 
          County Offices of Education commissioned an outside audit of 
          Options for Youth, Inc. (OFY) and Opportunities for Learning, 
          Inc. (OFL) Charter Schools.  The audit revealed OFL and OFY had 
          contracts with many companies which were owned by overlapping 
          family members, had several of the same corporate officers, 
          directors, and staff of OFL and OFY, and all sold and purchased 
          goods and services from each other.  Although financial 
          interests in transactions between the companies were disclosed, 
          some of the related party arrangements were questionable.  The 
          audit concluded that both OFY and OFL schools had inadequate 
          conflict of interest policies and therefore could not be 
          protected against improper transactions.  (Cleeland, Audit 
          Faults Chain of Charter Schools (Aug. 10, 2006) Los Angeles 
          Times  (as of June 24, 
          2011).)

          In 2007, the Los Angeles Times reported that the Los Angeles 
          County Office of Education hired an outside auditor to examine 
          the Gorman Learning Center Charter School.  The audit showed 
          that for the three years audited, the Gorman Learning Center 
          Charter School provided false information on State Schools Funds 
          applications and received $7.7 million more than the school 
          should have received.  The audit further revealed that the 
          school spent thousands of dollars on questionable items, such as 
          a $14,000 board retreat that included helicopter and yacht 
          rentals, and horseback riding and diving lessons for board 
          members and their families.  As reported, the school's chief 
          executive officer inappropriately hired family members and the 
          director of human resources received $18,000 in school funds to 
          pay for her rent.  (Rubin, School misused funds, audit finds 
          (Mar. 17, 2007) Los Angeles Times < 
          http://articles.latimes.com/2007/ mar/17/local/me-school17> (as 
          of June 24, 2011).)

          Another Los Angeles Times article reported that Charles Cox, 
          head and founder of California Charter Academy, was indicted and 
          charged with the misuse of over $5 million in school funds, 
          using the money as compensation in the form of wages to himself, 
          friends, and family members, and to make extravagant purchases 
          unrelated to the chartered school.  Cox was also charged with 
          inappropriately entering into school service contracts with a 
          company he owned.  (Reston and Landsberg, Charter schools' 
                                                                      



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          founder indicted (Sept. 5, 2007) Los Angeles Times 
           (as 
          of June 24, 2011).)

          Over the years, the Legislature has made clear that public 
          agency actions should be open to the scrutiny of the public.   
          In 1961, the Legislature enacted the Brown Act, which provided 
          public access to local public agency information.  In 1967, the 
          Legislature enacted the Bagley-Keene Act, which provided public 
          access to state public agency information.  In 1975, the Brown 
          Act was amended to provide for disclosure of public agency acts 
          taken during closed meetings.  In 1986, the Brown Act, among 
          other things, was amended to provide for the posting of public 
          agency agendas.  In 2004, Proposition 59 added to the California 
          Constitution the people's right of access to public body 
          information.  (Cal. Const., art. I, sec. 3(b)(1).)

          This bill is substantially similar to AB 2115 (Mullin, 2008) and 
          AB 572 (Brownley, 2010), which were both vetoed by Governor 
          Schwarzenegger.  

          This bill, sponsored by California School Boards Association, 
          would address the reports of fiscal mismanagement by subjecting 
          a governing board of a charter school to the same open meetings, 
          public records disclosure, and conflict of interest laws that 
          govern public schools and school districts.  This bill would 
          become operative on July 1, 2012.

          This bill was heard by the Senate Education Committee on June 
          22, 2011 and approved by a vote of 7-2.

                                CHANGES TO EXISTING LAW
           
          1.    Existing law  provides that the people have the right of 
            access to information concerning the people's business and 
            requires meetings of public bodies and the writings of public 
            officials and agencies to be open to public scrutiny.  (Cal. 
            Const., art. I, sec. 3(b)(1).)

             Existing law  , the Brown Act, provides statutory requirements 
            of local school districts to keep the public informed.  (Gov. 
            Code Sec. 54950 et seq.)  Existing law requires a school 
            district board to post notices and agendas of school district 
            board meetings.  (Gov. Code Secs. 54953, 54954.2, 54954.6, and 
            54956.)  Existing law requires a school district board to 
            publicly report any action taken in closed sessions.  (Gov. 
                                                                      



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            Code Secs. 54957.1 and 54957.7.)  Existing law requires a 
            school district board to disclose in an open meeting the items 
            to be discussed in closed sessions.  (Gov. Code Sec. 54957.7.)

             Existing law  , the Bagley-Keene Act, provides statutory 
            requirements of state school districts to keep the public 
            informed.  (Gov. Code Sec. 11120 et seq.)  Existing law 
            requires state school district boards to post notices and 
            agendas of state public body meetings.  (Gov. Code Secs. 
            11123, 11125, 11125.4, 11125.5, 11125.9, and 11126.)  Existing 
            law requires state school district boards to publicly report 
            any action taken in closed sessions.  (Gov. Code Secs. 
            11125.2, 11126, and 11126.3.)

             Existing law  provides that all meetings of the governing board 
            of the school district and the county board of education at 
            which the granting, revocation, appeal, or renewal of a 
            charter petition is discussed shall comply with the Brown Act. 
             (Gov. Code Sec. 47608.)

             Existing law  provides that a charter school is deemed to be a 
            "school district" for purposes of appropriations, 
            disbursements, and apportionment from state school and lottery 
            funding.  (Ed. Code Secs. 47612, 47638, 47650.)

             Existing law  provides that a charter school is provided with 
            local operational funding that is equal to the total funding 
            that would be available to a similar school district serving a 
            similar pupil population.  (Ed. Code Sec. 47630.)

             Existing law  requires a local school district board to hold 
            open meetings, unless otherwise exempt, as specified.  (Ed. 
            Code Sec. 35147.)

             This bill  would require a charter school and its board to 
            comply with the open meeting requirements under the Brown Act 
            or Bagley-Keene Act, as appropriate according to whether the 
            charter school is operated by a local or state entity, and 
            Education Code Section 35147.

          2.  Existing law  , the CPRA, governs the disclosure of information 
            collected and maintained by public agencies, including school 
            districts.  (Gov. Code Sec. 6250 et seq.)  Generally, all 
            public records are accessible to the public upon request, 
            unless the record requested is exempt from public disclosure.  
            (Gov. Code Sec. 6254.)  There are 30 general categories of 
                                                                      



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            documents or information that are exempt from disclosure, 
            essentially due to the character of the information, and 
            unless it is shown that the public's interest in disclosure 
            outweighs the public's interest in non-disclosure of the 
            information, the exempt information may be withheld by the 
            public agency with custody of the information.  (Id.)

             Existing law  authorizes the person whose request for a public 
            record under the CPRA is denied to file an action in superior 
            court for an order requiring disclosure.  (Gov. Code Sec. 
            6258.)  The test for a determination of whether a record may 
            be withheld from public access is whether the public's 
            interest in disclosure is outweighed by the public's interest 
            in withholding disclosure of the record.  (Gov. Code Sec. 
            6255.)

             This bill  would require a charter school to comply with the 
            public disclosure requirements under the CPRA.

          3.  Existing law  provides that a private person or organization 
            can provide funding to assist in the establishment or 
            operation of a charter school.  (Ed. Code Sec. 47603.)  
             
            Existing law  provides that a charter school can elect to 
            operate or be operated by a nonprofit public benefit 
            corporation.  (Ed. Code Sec. 47604.)
             
            Existing law  provides that a state community college district 
            or state university can establish an auxiliary organization to 
            solicit funds for the benefit of the community college 
            district, and the board members of such auxiliary 
            organizations are subject to conflict of interest disclosure 
            requirements.  (Ed. Code Secs. 72670 et seq. and 89907 et 
            seq.)

             Existing law  prohibits officers, board members, and employees 
            of a school district from having a financial interest in any 
            contract made by the officer, board member, or employee, in an 
            official capacity on behalf of the school district.  Existing 
            law provides criminal penalties for such violations.   (Gov. 
            Code Sec. 1090 et seq.)

             Existing law  provides that an officer will not be deemed to be 
            interested in a contract entered into by a board or school 
            district in which the officer, board member, or employee is a 
            member if that individual has only a remote interest in the 
                                                                      



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            contract and that interest is disclosed to the board or 
            district of which the individual is a member, as specified.  
            Existing law provides numerous financial transactions that 
            qualify as a "remote interest."  (Gov. Code Sec. 1091.) 
           
            This bill  would require a charter school to comply with these 
            restrictions on financial interests.  

            This bill  would add to the list of financial transactions that 
            qualify as a "remote interest" certain loan or lease 
            agreements, as specified, entered into between a charter 
            school employee or board member and the charter school. 

             This bill  would allow an individual to serve as a board member 
            of a charter school in the event the individual provides a 
            loan to a charter school, signs for a line of credit on behalf 
            of the charter school, or enters into a lease agreement with a 
            charter school as long as the following criteria are met:
                 the governing board of the charter school declares and 
               describes the existence of a fiscal emergency by adopting a 
               resolution at a public meeting of the governing board; and
                 the terms of the loan agreement, line of credit, or 
               lease of real property are disclosed and approved by the 
               governing body, excluding a vote by the interested 
               individual.

          4.    Existing law  , the PRA, requires public officials to file 
            annual statements of financial interest.  (Gov. Code Sec. 
            81000.)

             This bill  would require a charter school to comply with 
            financial interest disclosure requirements under the PRA.

          5.  Existing law  prohibits an employee of a school district from 
            serving as a board member of the school district.  (Ed. Code 
            Sec. 35107(b).)

             This bill  will allow an individual to be employed as a teacher 
            in a charter school and also serve as a member on the school's 
            governing body provided the individual abstains from voting on 
            all matters uniquely affecting his or her own employment.

          6.    Existing law  prohibits a board member of a school district 
            from voting on personnel matters affecting a relative of the 
            individual.  (Ed. Code Sec. 35107(e).)

                                                                      



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             This bill  would provide this same restriction for a board 
            member of a charter school.

          7.    This bill would become operative on July 1, 2012.

                                        COMMENT
           
          1.  Stated need for the bill  
          
          The author writes:
          
            �S]tatewide there are a handful �of] charter schools that are 
            run by non-profit corporations that have a symbiotic 
            relationship with a for-profit corporation.  These non-profit 
            corporations contract with a single for-profit corporation for 
            everything from curriculum to business services.  Some of 
            these non-profits have a single board making financial 
            decisions for both the corporation as well as the school.  
            Because the same board runs the corporation and the school, 
            these boards are often fraught with conflicts of interest.  It 
            is not appropriate for boards that govern state dollars to be 
            financially interested in the decisions made by the board.  

            �This] bill will continue the long standing tradition that 
            charter schools have greater autonomy than traditional public 
            schools, but at the same time, provide greater transparency to 
            parents and the public regarding the use of public funds by 
            charter schools for the educational benefit of their students. 
            . . . AB 360 will align conflict of interest standards for 
            charter school boards with that of school district boards.

          The California School Boards Association, the sponsor of this 
          bill, writes:
          
            Unfortunately, fiscal management is a common reason for the 
            closure of charter schools.  The most egregious abuses have 
            occurred when charter school board members have benefitted 
            financially from decisions made by their own board.  Charter 
            schools are public schools, and as such, should do business in 
            an open, transparent manner, free of conflicts of interest.  

           2.Charter schools' use of public funds should be subject to 
            public disclosure  

          This bill would require a charter school to hold open meetings 
          and provide public access in the same fashion as public school 
                                                                      



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          districts.  Existing law provides that the people have the right 
          of access to information concerning the people's business and 
          requires meetings of public bodies and the writings of public 
          officials and agencies to be open to public scrutiny.  (Cal. 
          Const., art. I, sec. 3(b)(1).)  The Legislature has declared a 
          charter school to be a school district, and thus a public 
          agency, for purposes of state and local funding.  (Ed. Code 
          Secs. 47612, 47630, 47638, 47650.)  When public agencies receive 
          state and local funds, it becomes necessary to provide public 
          access and scrutiny over the use of these funds to ensure that 
          the public's business is being properly conducted. 

              a.   Open Meetings Requirement  

            Existing law, the Brown Act, provides statutory requirements 
            for local school districts to keep the public informed by 
            holding properly noticed public meetings and requiring certain 
            disclosure of information before and after closed meetings.  
            (Gov. Code Sec. 54950 et seq.)  Existing law, the Bagley-Keene 
            Act, provides similar statutory requirements for state school 
            districts.  (Gov. Code Sec. 11120 et seq.)  

            The California Federation of Teachers AFT, AFL-CIO, a 
            supporter of this bill, argues that "�w]ithout this bill, many 
            decisions will be made without the public knowing where their 
            money is going and what their money is being spent on.  
            Charter schools which receive public funds should be held to 
            the same transparency and abuse prevention rules by which 
            every other public agency must abide."   This bill would 
            require a charter school and its board to comply with the open 
            meeting requirements under the Brown Act or Bagley-Keene Act, 
            as appropriate according to whether the charter school is 
            operated by a local or state entity, and Education Code 
            Section 35147.  The author argues that a charter school should 
            be required to conduct properly noticed, open public meetings 
            to provide students, parents, and communities with 
            transparency and information regarding the use of public 
            funds. 

              b.   Public disclosure of information pursuant to the CPRA
           
            Existing law, the CPRA, governs the disclosure of information 
            collected and maintained by public agencies, including school 
            districts.  (Gov. Code Sec. 6250 et seq.)  Generally, all 
            public records are accessible to the public upon request, 
            unless the record requested is exempt from public disclosure.  
                                                                      



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            (Gov. Code Sec. 6254.)  

            Charter schools, financed by the State School Fund, are deemed 
            school districts for purposes of funding, but are free from 
            many of the constrictions placed on school districts in order 
            to increase the learning opportunities for all students.  (Ed. 
            Code Secs. 47601, 47650.)  Although charter schools are able 
            to operate independently from school district construction, 
            charter schools are still considered to be members of the 
            public school system and under the control of the officers of 
            the public school system.  (Ed. Code Sec. 47615.)

            Proponents assert that since charter schools are funded by 
            taxpayer money, it is the public's business to ensure that its 
            taxes are being spent in a proper manner.  Therefore, actions 
            taken by a charter school and its financial administration 
            should be available for public scrutiny.  Subjecting charter 
            schools to the CPRA would allow access to their records, hence 
            the scrutiny required to prevent misconduct and 
            misappropriation of public funds.  

              c.   Disclosure of conflicts of interest pursuant to the PRA  

            Existing law, the PRA, requires public officials to file 
            annual statements of financial interest.  (Gov. Code Sec. 
            81000.)  The Legislature declared this necessary because 
            "�p]ublic officials, whether elected or appointed, should 
            perform their duties in an impartial manner, free from bias 
            caused by their own financial interests or the financial 
            interests of persons who have supported them."  (Gov. Code 
            Sec. 81001.) 

            The Los Angeles Unified School District (LAUSD), a supporter 
            of this bill, argues that "the integrity and promise of 
            charter schools are compromised when situations of 
            self-dealing and personal gain appear to be permissible - when 
            this is so clearly not the case for any other public schools 
            in our state. . . . AB 360 . . . will provide additional legal 
            weight to ensuring that charters follow the same minimum 
            integrity standards that are required of all of us who hold a 
            position of public trust in serving California's children."  
            In order to ensure that charter school board members are not 
            receiving inappropriate gifts for the purpose of compromising 
            the board member's decisions relating to the charter school, 
            this bill would require a charter school and its board members 
            to comply with financial interest disclosure requirements 
                                                                      



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            under the PRA.  

           1.Disclosure of financial interests in charter school contracts  

           This bill would provide disclosure requirements when a charter 
           school employee or board member contracts with a charter 
           school.   Existing law prohibits officers, board members, and 
           employees of a school district from having a financial interest 
           in any contract made by the officer, board member, or employee, 
           in an official capacity on behalf of the school district.  
           Existing law provides criminal penalties for such violations.   
           (Gov. Code Sec. 1090 et seq.)  However, certain financial 
           transactions involving a "remote interest" of a board member 
           are exempt from this prohibition.  (Gov. Code Sec. 1091.)
           
           The Santa Clara County Office of Education, in support of this 
          bill, argues that "charter schools are currently exempt from 
          many state requirements.  While many of these exemptions allow 
          charters to innovate, some of them jeopardize our public tax 
          dollars    . . . . �A]s public schools, charter schools should 
          do business in a transparent manner, free from conflicts of 
          interest.  It is important that financial transactions between a 
                                                         charter school and its board members be prohibited.  A charter 
          board member should not attempt to influence a decision of the 
          board in which it has a financial interest."  

          The LAUSD reports that its Inspector General identified a number 
          of conflict of interest situations in Los Angeles charter 
          schools:

                 a charter school director transferred public funds in 
               excess of $230,000 to a private corporation in which the 
               director had a financial interest;
                 a husband and wife team served together as board members 
               for a charter and then conducted a lease transaction for 
               the charter with another organization of which they were 
               officers; and
                 charter board directors wearing additional hats as 
               officers and employees of the same charter school.

          Under Corporations Code conflict of interest laws, the board of 
          directors of a nonprofit organization may have up to 49 percent 
          interested directors.  (Corp. Code Sec. 5227.)  The board may 
          enter into transactions where its members are financially 
          interested, as long as each member's financial interest is 
          disclosed to the board and the member does not participate in 
                                                                      



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          the decision making.  (Corp. Code Sec. 5233.)  In comparison, 
          under Government Code Section 1091, which governs public school 
          districts, no director may have a material financial interest in 
          a decision made by the Board. 

          Proponents argue that the cases of the California Charter 
          Academy and Options for Youth and Opportunities Learning (see 
          Background) demonstrate why it is not appropriate to allow even 
          an incorporated nonprofit charter school to follow the more 
          lenient conflict of interest laws under the Corporations Code.  
          They argue that these cases and others demonstrate that giving 
          charter school board members more flexibility in the management 
          of finances has led to the misappropriation of funds and 
          unethical personal gain, resulting in the closing of some 
          charter schools.  Proponents assert that requiring charter 
          schools to comply with the more stringent standard under the 
          Government Code is necessary in order to protect the public from 
          financial mismanagement of taxpayer money, and the students from 
          an unstable learning environment. 

          Accordingly, in order to expose potential conflicts of interest 
          for the personal gain of a board member, this bill would 
          prohibit a charter school board member from being a party to a 
          contract with a charter school in which the board member has a 
          financial interest.  However, because charter schools operate 
          with both public and private funds, this bill would allow a 
          board member to provide a loan to a charter school, sign for a 
          line of credit on behalf of the charter school, or enter into a 
          lease agreement with the charter school as long as the following 
          criteria are met:  
                  the governing board of the charter school declares and 
               describes the existence of a fiscal emergency by adopting a 
               resolution at a public meeting of the governing board; and
                 the terms of the loan agreement, line of credit, or 
               lease of real property are disclosed and approved by the 
               governing body, excluding a vote by the interested 
               individual.

          EdVoice and California Business for Education Excellence, 
          opponents of this bill, argue that it will subject a 
          "philanthropic board member" to "a felony punishable by 
          imprisonment in a state prison and disqualification from holding 
          any office" for providing a no-interest or low-interest start-up 
          loan or facility to help the charter school.  In response, the 
          author argues that the exemption for loans created under this 
          bill would include start-up loans.  In the event the charter 
                                                                      



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          school has not received federal or state funding prior to the 
          school opening, the board can declare a fiscal emergency in 
          order to receive start-up loan funding.  
            
          Further, the author argues that "�i]t is not appropriate for 
          boards that govern state dollars to be financially interested in 
          the decisions made by the board.  Charter schools must operate 
          with integrity and transparency in order to assure the public 
          about its fiduciary responsibility as well as cast a bright 
          light on those who might violate their fiduciary trust."  
          Accordingly, this bill provides conflict of interest protections 
          and disclosure requirements so that charter school communities 
          will be better informed as to who is involved in financial 
          transactions with the charter school and how the charter school 
          monies are utilized. 

          4.  Author's recent amendments to address opposition's concerns
           
          The California Charter Schools Association (CCSA), previously 
          opposed to this bill, argued that there is no demonstrated need 
          for the bill since existing law has provided oversight and 
          transparency such that financial impropriety has been 
          identified, and "�i]f there are shortcomings in the 
          identification of fiscal management and malfeasance, it is not 
          due to a lack of tools or recourse; it is due to the failure of 
          charter school authorizers to effectively exercise their 
          oversight responsibilities."  Further, CCSA argued that 
          prohibiting "key leaders of the community from serving on a 
          nonprofit charter school if they have any interest in a 
          contractual relationship with the school" would "cut to the 
          heart of traditional charter school governance and contradicts 
          longstanding charter law."

          To address the concerns of CCSA, the author has amended the bill 
          to provide exemptions from conflicts of interest for board 
          members who loan money to, sign for a line of credit on behalf 
          of, or lease property to the charter school and disclose these 
          financial arrangements in a public meeting and recuse themselves 
          from voting on such arrangements.  Accordingly, CCSA is now in 
          support of this bill.

          5.  Governor Schwarzenegger's veto of AB 572 and AB 5112  

          This bill is substantially similar to the enrolled version of AB 
          572 (Brownley, 2010).  In vetoing AB 572, Governor 
          Schwarzenegger stated:
                                                                      



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            Charter school educators have proven that poverty is not 
            destiny for students that attend public schools in California. 
             Repeatedly, charter schools with high proportions of 
            disadvantaged students are among the highest performing public 
            schools in California.  Any attempt to regulate charter 
            schools with incoherent and inconsistent cross-references to 
            other statutes is simply misguided.  Parents do not need 
            renewed faith in charter schools as suggested in this bill.  
            On the contrary, tens of thousands of parents in California 
            have children on waiting lists to attend a public charter 
            school.  Legislation expressing findings and intent to provide 
            "greater autonomy to charter schools" may be well intended at 
            first glance.  A careful reading of the bill reveals that the 
            proposed changes apply new and contradictory requirements, 
            which would put hundreds of schools immediately out of 
            compliance, making it obvious that it is simply another veiled 
            attempt to discourage competition and stifle efforts to aid 
            the expansion of charter schools.

          This bill is substantially similar to the enrolled version of AB 
          2115 (Mullin, 2008).  In vetoing AB 2115, Governor 
          Schwarzenegger stated:

            Not only would this bill create state mandated costs for 
            charter schools to comply with its provisions, the measure 
            runs counter to the intent of charter schools, which were 
            created to be free from many of the laws governing school 
            districts.
           

          Support  :  California Charter Schools Association; California 
          Federation of Teachers AFT, AFL-CIO; California Newspaper 
          Publishers Association; California School Employees Association; 
          Californians Aware; Kern County Superintendent of Schools; Los 
          Angeles County Office of Education; Los Angeles Unified School 
          District; Public Advocates; San Francisco Unified School 
          District; Santa Clara County Office of Education; United 
          Teachers Los Angeles

           Opposition  :  California Business for Education Excellence; 
          EdVoice

                                        HISTORY
           
           Source  :  California School Boards Association
                                                                      



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           Related Pending Legislation  :  None Known

           Prior Legislation  :

          AB 572 (Brownley, 2010) See Background.

          AB 2115 (Mullin, 2008) See Background.

          SB 1448 (Hart, Ch. 781, Stats. 1992) See Background.

           Prior Vote  :

          Senate Education Committee (Ayes 7, Noes 2)
          Assembly Floor (Ayes 50, Noes 27)
          Assembly Education Committee (Ayes 7, Noes 3)

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