BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2256
                                                                  Page 1

          Date of Hearing:  April 24, 2012

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                  Mike Feuer, Chair
               AB 2256 (Portantino) - As Introduced: February 24, 2012
                                           
          SUBJECT  :  CALIFORNIA LEGISLATURE WHISTLEBLOWER PROTECTION ACT

           KEY ISSUES  : 

          1)SHOULD MEMBERS OF THE LEGISLATURE AND ALL TYPES AND LEVELS OF 
            LEGISLATIVE STAFF FACE POTENTIAL INVESTIGATION BY THE FAIR 
            POLITICAL PRACTICES COMMISSION AND SPECIFIED PENALTIES FOR 
            ALLEGED IMPROPER GOVERNMENTAL ACTIVITIES, SUBJECT TO POTENTIAL 
            LEGISLATIVE IMMUNITY?

          2)IS IT APPROPRIATE THAT MEMBERS OF THE LEGISLATURE WHO ALREADY 
            HAVE ACCESS TO LEGISLATIVE AND POLITICAL PROCESSES ALSO BE 
            ABLE TO FILE WHISTLEBLOWER CLAIMS AGAINST OTHER MEMBERS AND 
            LEGISLATIVE STAFF?

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

                                         SYNOPSIS
          
          This bill proposes to create the California Legislature 
          Whistleblower Protection Act. The effect of this bill would be 
          to allow legislative staff to be both potential complainants as 
          well as potential subjects of complaints - apparently by any 
          member of the public - alleging "improper governmental 
          activities," a term that encompasses a wide range of actions 
          such as illegal bribery, corruption and theft, as well as more 
          nebulous terms, such as alleged "incompetence" and 
          "inefficiency."  

          The Committee unanimously passed a similar measure by the author 
          in January, which was held in the Appropriations Committee. 
          Unlike the author's prior measure, however, this bill goes 
          further in imposing on legislative staff an affirmative duty to 
          disclose or report improper governmental activity.  This 
          provision has no known precedent in California law, and the bill 
          does not state how this apparently novel duty would be carried 
          out in light of the amorphous and arguably subjective nature of 
          "improper governmental activity," although staff would 
          presumably be subject to discipline including termination for 








                                                                  AB 2256
                                                                  Page 2

          violation of this duty.

          In addition, as with the author's prior measure, the bill would 
          apparently subject Members of the Legislature to complaints by 
          legislative staff, and seemingly by any member of the public, 
          who alleges the same broad definition of improper governmental 
          activities.  Although less clearly than the author's prior 
          measure, the bill appears to allow Members of the Legislature to 
          be potential complainants against fellow Members as well as 
          against legislative staff.  In the prior measure this provision 
          was amended out when the bill was heard by the Committee because 
          of the potential for mischief and because of the other 
          mechanisms available to Legislators who wish to combat any 
          improprieties they may encounter by staff or fellow Members, and 
          the Committee may accordingly wish to treat this measure 
          consistently.

          The bill would also subject Members of the Legislature and 
          legislative staff to potential penalties for retaliation against 
          a person who filed a complaint of improper governmental activity 
          or other actions, even if no actual improper governmental 
          activity or wrongdoing occurred.  As the sponsor of the bill, 
          the author argues that the Legislature needs to prove to the 
          public that the Legislature is above reproach.  Nevertheless, 
          the bill expressly incorporates the doctrine of legislative 
          immunity, which would appear to largely shield Members from any 
          responsibility for violations of the California Legislature 
          Whistleblower Protection Act, leaving employees of the 
          Legislature as potential targets to the extent they are not also 
          covered by legislative immunity.  

          All of the foregoing types of complaints would be filed with the 
          Fair Political Practices Commission (FPPC), anonymously, over 
          the Internet, and without a deadline, creating the possibility 
          for a substantial volume of complaints.  The choice of the FPPC 
          is a departure from the author's prior measure, which entrusted 
          this responsibility to the State Auditor - the entity that 
          investigates other complaints of alleged improper governmental 
          activities and unlawful retaliation under the Whistleblower 
          Protection Act that covers the executive and judicial branches.  
          The State Auditor has expertise, but a conflict of interest 
          because of its close relationship with the Legislature.  The 
          FPPC on the other hand has independence from the Legislature, 
          but no experience or expertise in the investigation of improper 
          governmental activities or whistleblower retaliation.  The FPPC 








                                                                  AB 2256
                                                                  Page 3

          has recorded its opposition to the bill on the ground that it 
          expands the duties and responsibilities of the Commission 
          without the extensive additional resources that would be 
          necessary.  No letters of support have been received by the 
          Committee.
           
          SUMMARY  :  Creates the California Legislature Whistleblower 
          Protection Act (LWPA).  Specifically,  this bill  :  

          1)Appears to subject Members or employees of either house of the 
            Legislature to complaints of wrongdoing alleging "improper 
            governmental activity" including, among other things: 
            malfeasance, corruption, fraud, coercion, misuse of government 
            property, and willful omission to perform duty, as well as 
            conduct that is wasteful, incompetent or inefficient.  
            Improper governmental activity under the bill is said to 
            include "any activity by a Member or employee of the 
            Legislature," presumably including purely legislative acts 
            that may otherwise be shielded under the constitutional 
            doctrine of legislative immunity.

             a)   Complaints are to be received and investigated by the 
               FPPC via the Internet and other means.

             b)   Complainants are entitled to complete anonymity and 
               confidentiality.  

             c)   There is no statute of limitations on when these 
               complaints can be filed; Members or employees of either 
               house of the Legislature would be subject to complaints 
               about any activities undertaken in the performance of his 
               or her duties, regardless of how long ago the activities 
               may have occurred. 

             d)   Under the bill, these administrative complaints are not 
               expressly precluded by the doctrine of legislative immunity 
               as other provisions of the bill are, although legislative 
               immunity may in fact apply to some acts.

          2)Creates an affirmative duty for employees of each house of the 
            Legislature to disclose or report improper governmental 
            activity.  

          3)Prohibits a Member or employee of either house of the 
            Legislature from directly or indirectly using or attempting to 








                                                                  AB 2256
                                                                  Page 4

            use his or her official authority or influence to retaliate, 
            threaten, coerce, or engage in any similar improper act for 
            the purpose of interfering with the right of an employee of 
            either house of the Legislature to make a protected disclosure 
            of improper governmental activity or to refuse an illegal 
            order as defined.

          4)Appears to subject Members and employees of either house of 
            the Legislature to law suits by employees or applicants for 
            employment with the Legislature alleging that the legislator 
            or employee directly or indirectly used or attempted to use 
            his or her official authority or influence to retaliate, 
            threaten, coerce, or engage in any similar improper act for 
            the purpose of interfering with the right to make a protected 
            disclosure of improper governmental activity or to refuse an 
            illegal order.  A violation of this prohibition would be 
            subject to a potential civil action for damages by the 
            offended party.  However, Members of the Legislature would be 
            protected under the doctrine of legislative immunity.  It is 
            not clear whether employees of the Legislature would also be 
            protected by this doctrine.

          5)Appears to subject Members and employees of the Legislature, 
            to a fine up to ten thousand dollars ($10,000) and 
            imprisonment in the county jail for up to one year for 
            reprisal, retaliation, threats, coercion, or similar improper 
            acts against an employee of the Legislature or applicant for 
            employment with the Legislature.  However, Members of the 
            Legislature would be protected under the doctrine of 
            legislative immunity, while it is unclear whether employees of 
            the Legislature would likewise be similarly immune.

          6)Appears to subject Members and employees of the Legislature, 
            to civil law suits for damages, punitive damages and 
            attorney's fees for reprisal, retaliation, threats, coercion, 
            or similar improper acts against an employee or applicant for 
            employment with the Legislature for having made a protected 
            disclosure.  However, Members of the Legislature would be 
            protected under the doctrine of legislative immunity; 
            employees of the Legislature may or may not be covered by 
            legislative immunity.

          7)Permits anyone, including Members of the Legislature, to 
            invoke the rights and protections of the bill and involve the 
            FPPC in complaints against the Legislature, other Members and 








                                                                  AB 2256
                                                                  Page 5

            legislative staff.  It is unclear whether the doctrine of 
            legislative immunity would cover these complaints either for 
            Members or for legislative staff.

           EXISTING LAW :

          1)Pursuant to the California Whistleblower Protection Act (WPA), 
            prohibits "improper governmental activities" by state agencies 
            and employees.  (Government Code section 8547.2, 8547.4.)

          2)Defines "improper governmental activity" as an activity by a 
            state agency or by an employee that is undertaken in the 
            performance of the employee's duties, undertaken inside a 
            state office, or, if undertaken outside a state office by the 
            employee, directly relates to state government, whether or not 
            that activity is within the scope of his or her employment, 
            and that (1) is in violation of any state or federal law or 
            regulation, including, but not limited to, corruption, 
            malfeasance, bribery, theft of government property, fraudulent 
            claims, fraud, coercion, conversion, malicious prosecution, 
            misuse of government property, or willful omission to perform 
            duty, (2) is in violation of an Executive order of the 
            Governor, a California Rule of Court, or any policy or 
            procedure mandated by the State Administrative Manual or State 
            Contracting Manual, or (3) is economically wasteful, involves 
            gross misconduct, incompetency, or inefficiency.  (Govt. Code 
            section 8547.2(c).)

          3)Defines employee to include former employees, but specifically 
            excludes Members and staff of the Legislature from the 
            definitions of "employee" and "state agency."  (Govt. Code 
            section 8547.2(a), (f).)

          4)Directs the State Auditor to accept complaints by mail and via 
            Internet, and to conduct investigations of alleged improper 
            governmental activities, and authorizes the State Auditor to 
            issue reports of its findings including recommended corrective 
            actions if it finds reasonable cause to believe an improper 
            governmental activity has occurred.  (Govt. Code sections 
            8547.4, 8547.5, 8547.7.) 

          5)Provides that the State Auditor shall permit complaints to be 
            filed anonymously and shall keep the identity of all 
            complainants and witnesses confidential unless given the 
            express permission of the person, except that the State 








                                                                  AB 2256
                                                                  Page 6

            Auditor may make the disclosure to a law enforcement agency 
            that is conducting a criminal investigation.  (Govt. Code 
            section 8547.5.)

          6)Requires the State Auditor to keep confidential every 
            investigation, including, but not limited to, all 
            investigative files and work product, except that the State 
            Auditor may issue a public report of an investigation that has 
            substantiated an improper governmental activity, keeping 
            confidential the identity of the employee or employees 
            involved.  (Govt.  Code section 8547.7.)

          7)Requires the employing state agency to take adverse employment 
            action against any employee found by the State Auditor to have 
            engaged or participated in improper governmental activity or 
            to set forth in writing its reasons for not taking adverse 
            action, and likewise requires the employing agency to report 
            on actions it has taken to implement the BSA's 
            recommendations.  (Govt.  Code sections 8547.4, 8547.7.)

          8)Prohibits state employees and officers, other than Members and 
            employees of the Legislature, from directly or indirectly 
            using or attempting to use the official authority or influence 
            of the employee for the purpose of intimidating, threatening, 
            coercing, commanding, or attempting to intimidate, threaten, 
            coerce, or command any person for the purpose of interfering 
            with the rights conferred pursuant to the WPA.  (Govt. Code 
            section 8547.3.)

          9)Defines "use of official authority or influence" to include 
            promising to confer, or conferring, any benefit; effecting, or 
            threatening to effect, any reprisal; or taking, or directing 
            others to take, or recommending, processing, or approving, any 
            personnel action, including, but not limited to, appointment, 
            promotion, transfer, assignment, performance evaluation, 
            suspension, or other disciplinary action.  (Govt. Code section 
            8547.3.)

          10)Provides that any employee who violates this prohibition 
            against use of authority or influence to be liable in an 
            action for civil damages brought by the offended person.  
            (Govt. Code section 8547.3.)

          11)Makes a person who intentionally engages in acts of reprisal 
            or retaliation in violation of the WPA subject to a fine of up 








                                                                  AB 2256
                                                                  Page 7

            to $10,000 and up to a year in county jail, and if that person 
            is a civil service employee, subjects that person to 
            discipline by adverse action.  A person injured by such acts 
            may bring an action for damages only after filing a complaint 
            with the State Personnel Board (SPB) and the SPB issued, or 
            failed to issue, findings of its hearings or investigation.  
            (Gov. Code Sec. 8547.8.)

          12)Under the constitutional doctrine of legislative immunity, 
            prohibits legal action against legislators for legislative 
            activity and other acts within the sphere of legislative 
            activity.  (Tenney v. Brandhove, 341 U.S. 367, 375(1951); 
            Bogan v. Scott-Harris, 523 U.S. 44, 49(1998); Steiner v. 
            Superior Court, 50 Cal.App.4th 1771, 1784 (1996).)  

          13)Provides a process by which a state employee may file an 
            optional written complaint alleging adverse employment actions 
            such as retaliation, reprisal threats, or coercion, with a 
            supervisor or manager and with the SPB.  Existing law requires 
            the SPB to initiate an investigation or a proceeding within 10 
            working days of submission of a written complaint, and to 
            complete findings of the investigation or hearing within 60 
            working days thereafter.  (Gov. Code Sec. 19683.)

          14)Provides that no public or private employer may make, adopt, 
            or enforce any rule, regulation, or policy preventing an 
            employee from disclosing information to a government or law 
            enforcement agency, where the employee has reasonable cause to 
            believe that the information discloses a violation of state or 
            federal statute, or a violation or noncompliance with a state 
            or federal rule or regulation.  (Labor Code section 1102.5.)

          15)Likewise prohibits public and private employers from 
            retaliating against an employee for: (a) disclosing 
            information to a government or law enforcement agency, where 
            the employee has reasonable cause to believe that the 
            information discloses a violation of state or federal statute, 
            or a violation or noncompliance with a state or federal rule 
            or regulation; (b) refusing to participate in an activity that 
            would result in a violation of state or federal statute, or a 
            violation or noncompliance with a state or federal rule or 
            regulation; or (c) having exercised his or her rights to do so 
            in any former employment.  (Labor Code section 1102.5.)

          16)Provides that any employer who violates Labor Code section 








                                                                  AB 2256
                                                                  Page 8

            1102.5 is guilty of a misdemeanor punishable, in the case of 
            an individual, by imprisonment in the county jail not to 
            exceed one year or a fine not to exceed $1,000 or both and, in 
            the case of a corporation, by a fine not to exceed $5,000, and 
            provides that in all prosecutions under this chapter, the 
            employer is responsible for the acts of his managers, 
            officers, agents, and employees.  (Labor Code sections 
            1103-04.)

           COMMENTS  :  In support of the bill the author states:

               The California Whistleblower Protection Act authorizes the 
               California State Auditor to receive and investigate 
               complaints from state employees and members of the public 
               who wish to report an improper governmental activity.    
               State employees who file a complaint are entitled to 
               protection against retaliation by their employers for 
               filing the complaint.  This Act currently covers employees 
               of the Governor, every agency or department of state 
               government, legislative appointees to state boards or 
               commissions and employees of the CSU system.   

               Unfortunately employees of the California State Legislature 
               have no such protections if they report crimes, waste fraud 
               or other governmental irregularities. 

               In a time when public confidence in our state legislature 
               is at an all-time low and we are experiencing a lack of 
               openness and accountability in government, we need to prove 
               to the public that their Legislature is above reproach.  If 
               there is fraud, criminal acts, waste, theft or 
               embezzlement, employees of the legislature need to be free 
               to report these abuses with the same protections as every 
               other state employee.

               The California Whistleblower Protection Act protects every 
               state employee who files a complaint from suffering any 
               retaliation by his or her state employer for having made 
               the complaint. The Whistleblower Protection Act forbids 
               every state official and employee from retaliating or 
               attempting to retaliate against any employee or applicant 
               for employment who reports an improper activity. 
               Retaliation includes intimidation, the denial of 
               appointment or promotion, a threat of adverse action, a 
               poor performance evaluation, involuntary transfer, or any 








                                                                  AB 2256
                                                                  Page 9

               form of disciplinary action.

           This Bill Would Apparently Open Members And Employees Of The 
          Legislature To Complaints By Any Person Who Alleges Improper 
          Governmental Activity, To Be Investigated By The FPPC.   This 
          bill would permit complaints to the FPPC against any Member or 
          employee of the Legislature for alleged improper governmental 
          activity.  As with the Whistleblower Protection Act, which 
          applies to the executive and judicial branches, the right to 
          file a complaint would appear to be held by any person who 
          perceives alleged improper governmental activity.  Although the 
          findings and declarations of the bill express an intent to allow 
          employees of the Legislature to report improper government 
          activities, the bill does not limit who might be entitled to 
          file a complaint.  

          "Improper governmental activity" includes, among other things: 
          "malfeasance, corruption, bribery, fraud and theft," which may 
          be the author's primary objective, as well as broader concepts 
          such as "coercion, misuse of government property and willful 
          omission to perform duty" and conduct that is "economically 
          wasteful, or involves incompetency or inefficiency."  The bill 
          specifically includes as potential improper governmental 
          activity "any activity of a Member or employee of either house 
          of the Legislature undertaken in the performance of the Member's 
          or employee's duties," presumably including legislative acts.  

          There is no deadline or statute of limitations by which 
          complaints must be filed so long as they allege improper 
          governmental activities undertaken in the performance of his or 
          her duties.  

          The FPPC would be required to receive complaints via mail or 
          other carrier or electronically through the Internet.  All 
          complainants would be entitled to complete anonymity, as well as 
          virtually complete confidentiality.  Each complaint would be 
          received, evaluated and investigated by the FPPC, which would 
          prepare a written report if it finds reasonable cause to believe 
          that improper governmental activity may have occurred. 

          The expansive and imprecise nature of the term "improper 
          governmental activity," the undefined pool of potential 
          complainants, and the open-ended time period for filing 
          complaints would in combination appear to permit a substantial 
          volume of complaints to be handled by the FPPC.  As many 








                                                                  AB 2256
                                                                  Page 10

          observers have noted, the legislative process is inherently 
          inefficient by constitutional design, and reflects the 
          celebrated "checks and balances" that are often said to be the 
          genius of our democratic republic.  Of course, many people 
          naturally feel frustrated when government is unable to solve 
          various social problems or chooses to address those problems in 
          ways other than that person would prefer.  In light of the 
          nature of the legislative process and the competing political 
          values of any large and diverse population, it seems likely that 
          there may be many potential complainants who allege anonymously 
                                                    over the Internet that a Member of the Legislature is corrupt, 
          incompetent, inefficient, wasteful, or has willfully omitted to 
          perform his or her duties.   

          Moreover, particularly because complaints may be filed 
          anonymously and confidentially, it would unfortunately appear 
          impossible to exclude potential complaints that might be 
          initiated for the nefarious purpose of seeking political 
          advantage or embarrassment by an individual, business, 
          association or local government subject to a legislative probe 
          or engaged in a dispute or rivalry with a Member.  While the 
          FPPC would not be legally obligated to investigate every 
          complaint, the FPPC would be expected to undertake a serious and 
          thorough assessment of every complaint.  The bill may therefore 
          place significant pressure on the resources of the FPPC and 
          impose substantial additional costs.


          The Bill Creates An Apparently Unprecedented Affirmative Duty 
          For Legislative Employees To Report Improper Government 
          Activity  .  The bill declares that "�e]mployees of each house of 
          the Legislature have an affirmative duty to disclose or report 
          improper government activity" and that, "the Legislature 
          encourages and requires that instances of fraud, waste, abuse of 
          authority, violations of law, or threats to public safety be 
          reported to an independent entity for review and action."  
          (Sections 9149.51(a) and 9149.51(b).)

          This provision appears to have no corollary in the Whistleblower 
          Protection Act (WPA) applicable to executive and judicial branch 
          employees.  The WPA simply encourages such reporting, providing 
          that, "state employees should be free to report waste, fraud, 
          abuse of authority, violation of law or threat to public health 
          without fear of retribution."  









                                                                  AB 2256
                                                                  Page 11

          Other statutes applicable to local government and higher 
          education likewise encourage but do not require employees to 
          report alleged improper governmental activity.  (See Education 
          Code sections 44111, 87161, 89571.)  It may be unclear how a 
          legislative employee would comply with the duty under this bill 
          in some circumstances.  For example, what constitutes 
          legislative "inefficiency"?  The question may be more than 
          theoretical if an employee could presumably be terminated for 
          failure to comply with the duty to report.   The Committee may 
          wish to explore the author's purpose for including this 
          provision in the bill, the criteria employees would be required 
          to apply in order to obey the command of the bill, and the 
          circumstances in which employees would be subject to termination 
          or other discipline if they fell short of the bill's dictate.  

           Despite Creating the California Legislative Whistleblower 
          Protection Act, It Is Not Clear Whether the Doctrine of 
          Legislative Immunity May Nevertheless Protect Members From 
          Complaints.   Unlike other provisions of the bill, discussed 
          below, the provision permitting complaints against Members and 
          employees of the Legislature for alleged improper governmental 
          activities does not expressly incorporate the doctrine of 
          legislative immunity as a defense.  

          Members of the Legislature are largely immune from liability 
          under the longstanding doctrine of legislative immunity.  
          Legislative immunity is rooted in the protection afforded by the 
          speech and debate clause of U.S. Constitution Art. I �6, cl.1., 
          stating that legislators shall, "be privileged from Arrest 
          during their Attendance at the Session of their respective 
          Houses, and in going to and returning from the same; and for any 
          Speech or Debate in either House, they shall not be questioned 
          in any other Place."  Legislative immunity has also been 
          recognized as a principle of the separation of powers doctrine 
          in article III, section 3 of the California Constitution on the 
          ground that it prohibits judicial inquiry into the motives 
          behind legislative actions.  (Steiner v. Superior Court, 50 
          Cal.App.4th 1771, 1784 (1996).)  Legislative immunity serves to 
          ensure that legislators can be free to carry out their duties as 
          representatives without fear of criminal and civil liability.  
          (Tenney v. Brandhove, 341 U.S. 367, 375(1951).)  This protection 
          is absolute, and generally provides legislators complete 
          immunity - not only from liability, but from initiation of legal 
          action - for their legislative activities, as well as all other 
          actions "within the sphere of legitimate legislative activity."  








                                                                  AB 2256
                                                                  Page 12

          (Bogan v. Scott-Harris, 523 U.S. 44, 49(1998).)  Legislative 
          immunity has sometimes also been extended to legislative staff, 
          although there appears to be no California case law on this 
          point and cases from other jurisdictions are not consistent in 
          extending to staff the immunity that legislators enjoy.

          Case law suggests that legislative immunity may apply to 
          administrative processes, such as investigation by the FPPC, in 
          addition to civil and criminal court actions, although 
          legislative immunity may be waived by statute.  It is not clear 
          whether this bill intends to waive legislative immunity with 
          respect to complaints made to the FPPC, both because the 
          doctrine of legislative immunity is not referenced in this 
          section of the bill and because the bill declares that 
          legislative immunity is intended to exempt members from 
          "liability," which the administrative complaint process does not 
          involve. 
           
          It is therefore not clear whether, or the extent to which, 
          legislative immunity would prevent the FPPC from investigating 
          some potential complaints.  To that extent, the bill's promise 
          of reform may be more apparent than real.  Nevertheless, if 
          legislative immunity is intended to apply to complaints of 
          improper governmental activity, the bill would require the FPPC 
          to engage in complex legal determinations whether an alleged act 
          falls within the scope of legislative immunity.

           This Bill Would Purportedly Also Open Members And Employees Of 
          The Legislature to Lawsuits By An Employee, Former Employee, Or 
          Applicant For Employment Who Alleges Retaliation For Filing A 
          Complaint.  However, Members Would Be Largely Shielded From Any 
          Liability For Wrongdoing By The Legislative Immunity Doctrine.   
          In addition to allowing complaints to the FPPC against Members 
          and employees of the Legislature for alleged improper 
          governmental activity, this bill would also permit law suits 
          against Members and staff who are alleged to have retaliated 
          against any employee, former employee, or applicant for 
          employment for filing a complaint with the FPPC or otherwise 
          exercising a right under the LWPA.  

          This prohibition against retaliation provides that a Member or 
          employee of the Legislature may not "directly or indirectly use 
          or attempt to use his or her official authority or influence to 
          retaliate, threaten, coerce, or engage in any similar improper 
          act for the purpose of interfering with the right of an employee 








                                                                  AB 2256
                                                                  Page 13

          of either house of the Legislature to make a protected 
          disclosure of improper governmental activity or to refuse an 
          illegal order."

          Allegations of retaliation are separate and distinct from 
          allegations of improper governmental activity.  That is, a 
          complaint of alleged improper governmental activity could be 
          investigated and found to be groundless, but the complainant 
          would still have the independent right to file suit alleging 
          retaliation for having filed the complaint.  Complaints of 
          alleged retaliation would not be subject to investigation by the 
          FPPC; they would first be filed with an officer designated by 
          the Senate Committee on Rules and Assembly Committees on Rules, 
          and subsequently, could be filed as lawsuits in court. 

          As noted above, notwithstanding the bill's ostensible goals, 
          Members of the Legislature would be largely immune from 
          liability under the doctrine of legislative immunity.  

          Although the bill provides for liability to be imposed against 
          Member and employees of the Legislature, in light of legislative 
          immunity for Members of the Legislature, the primary target of 
          these lawsuits would appear to be current and former legislative 
          employees.  It is not clear whether legislative employees would 
          be protected by the doctrine of legislative immunity.  There 
          appears to be no California case law on this issue, and 
          disagreement among the courts in other jurisdictions regarding 
          when and how legislative immunity may be extended to employees. 

          Separate provisions of the bill would allow for potential fines 
          and imprisonment.  Again, however, Members of the Legislature 
          would be protected by the doctrine of legislative immunity.  The 
          primary object of these penalties therefore would appear to be 
          legislative employees, unless they too were found to be 
          protected by legislative immunity, an issue that is not clear in 
          the author's proposal.

           This Bill May Also Allow Legislators Themselves To Invoke The 
          Whistleblower Protection Act Against the Legislature, Other 
          Members, and Legislative Staff.  However, Legislative Immunity 
          May Largely Shield Members From Investigation or Responsibility 
          For Any Potential Wrongdoing.   In addition to being potential 
          subjects of complaints alleging improper governmental activities 
          by Members and employees of the Legislature, as discussed above, 
          this bill would allow Members to be potential complainants under 








                                                                  AB 2256
                                                                  Page 14

          the LWPA.  Anyone, including Members, would have the right to 
          file complaints with the FPPC alleging improper governmental 
          activities by fellow Members or legislative employees, including 
          the Member's own staff.  

           Possible Committee Amendment:  Leaving aside the unresolved 
          issues discussed above regarding the broad variety of 
          allegations permitted by the bill, the Committee may determine 
          that it is not necessary or appropriate to allow Members of the 
          Legislature to invoke the LWPA to complain about improper 
          governmental activity by other Members or employees of the 
          Legislature.  As direct participants in the political and 
          legislative processes, Members of the Legislature have access to 
          all of the political, legislative and other governmental 
          mechanisms available to prevent and correct any alleged 
          improprieties that a Member may perceive.  

          Further, many of these alleged improprieties may be inherently 
          political, or at least highly impressionistic.  It may therefore 
          not be necessary or appropriate to allow Members to invoke the 
          LWPA and the apparatus of the FPPC for the purpose of 
          investigating disputes regarding alleged conduct by fellow 
          Members or employees of the Legislature.  Moreover, because the 
          doctrine of legislative immunity may preclude any investigation 
          or responsibility on the part of Members, the primary effect of 
          authorizing Members to file complaints alleging improper 
          governmental activity may be to expose only legislative 
          employees to such complaints - an avenue that may be unnecessary 
          in light of the substantial authority Members currently have 
          regarding legislative employees.   The Committee may therefore 
          wish to amend the bill - as it did with the author's prior 
          measure - so that Members do not have resort to the FPPC 
          complaint process.

          ARGUMENTS IN OPPOSITION  :  The FPPC opposes the bill, arguing 
          that:  

                The Commission has concerns about any legislative measure 
               that expands the duties or responsibilities of the 
               Commission or requires additional Commission resources to 
               implement, unless the measure includes an appropriation 
               adequate to carry out its provisions.  Commission staff has 
               determined that the implementation of AB 2256 would require 
               extensive additional resources that cannot be absorbed 
               within the Commission's current budget.








                                                                  AB 2256
                                                                  Page 15

           
          REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          None on file

           Opposition 
           
          Fair Political Practices Commission
           

          Analysis Prepared by  :  Kevin G. Baker and Dalea Fong/ JUD. / 
          (916) 319-2334