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
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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
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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
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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
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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
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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
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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
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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
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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
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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."
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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."
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(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
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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
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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.
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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