BILL ANALYSIS                                                                                                                                                                                                    �




                                                                  SB 806
                                                                  Page A

          SENATE THIRD READING
          SB 806 ( Veterans Affairs Committee)
          As Amended  August 15, 2011
          2/3 vote.  Urgency

           SENATE VOTE  :37-0  
           
           PUBLIC EMPLOYMENT         5-0         VETERANS AFFAIRS          
          9-0                 
           
           ----------------------------------------------------------------- 
          |Ayes:|Furutani, Mansoor, Allen, |Ayes:|Cook, Pan, Atkins, Block, |
          |     |Ma, Wieckowski            |     |Nielsen,                  |
          |     |                          |     |V. Manuel P�rez,          |
          |     |                          |     |Williams, Yamada, Beth    |
          |     |                          |     |Gaines                    |
          |-----+--------------------------+-----+--------------------------|
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           APPROPRIATIONS                          17-0                    
           
           ----------------------------------------------------------------- 
          |Ayes:|Fuentes, Harkey,          |     |                          |
          |     |Blumenfield, Bradford,    |     |                          |
          |     |Charles Calderon, Campos, |     |                          |
          |     |Davis, Donnelly, Gatto,   |     |                          |
          |     |Hall, Hill, Lara,         |     |                          |
          |     |Mitchell, Nielsen, Norby, |     |                          |
          |     |Solorio, Wagner           |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :  This bill extends the statute of limitations for 
          salary overpayments to state employees on leave for duty with 
          the National Guard.  Specifically:

          1)Determines, if the state finds, that an overpayment of 
            compensation has been made to a state employee on a leave of 
            absence for active military duty as a member of the California 
            National Guard (Guard).

          2)States that if 1) above is determined then administrative 
            action to recover salary overpayment must be initiated within 
            six years from the date of overpayment, notwithstanding 









                                                                  SB 806
                                                                  Page B

            existing law.

          3)Contains an urgency clause.
           
          FISCAL EFFECT : According to the Assembly Appropriations 
          Committee, minor absorbable administrative costs, particularly 
          to the State Controller's Office.  Costs will be offset to an 
          unknown degree by recovering overpayments.
          
           COMMENTS:
           
          Extending the statute of limitations:  Equities:  There is in 
          most cases equity in, at some point in the passing of time, 
          disallowing claims.  "Statutes of limitation are passed to 
          prevent the production of stale claims when, from the lapse of 
          time, it has become difficult or impossible to furnish the 
          requisite proof to defeat them."<1>  However, there are some 
          claims for which there is no statute of limitations, for 
          example, the crime of murder, because we as a society agree that 
          it is never too late for the court system to take up such 
          claims.

          This bill presents a balancing of equities question for the 
          members:  How long after the date of overpayment is it fair to 
          attempt to recover funds from employees?  This bill proposes to 
          move that date back three years, from three to six years post 
          overpayment.  If funds were paid to an employee to which the 
          employee was not entitled, it might be argued that there should 
          be no time limit at all on when the recovery might occur, after 
          all, the funds should never have gone to the employee in the 
          first place.  Particularly in cases of large overpayments, one 
          could argue that the employee should have known he or she was 
          being over paid.

          However, considering the opposing equities and not including 
          cases of fraud, it may be very difficult for employees, 
          particularly enlisted members at more junior ranks, to confirm 
          or refute a notice of overpayment after six years.  Six years is 
          a long time to keep records for many people.  Service members 
          are likely to have gone through multiple deployments during that 
          time. Moreover, after such a long time it may be extremely 
          difficult for rank and file Guard members to repay even a modest 
          amount mistakenly overpaid paid to them.  



          ---------------------------
          <1> CA Code of Civil Procedure Section 312, Note 4.








                                                                 SB 806
                                                                  Page C

           
          Government Code Section 19838 as written balances these equities 
          at three years.  This time period is also aligned with the 
          three-year Code of Civil Procedure statute of limitations for 
          fraud or mistake.  In addition, the more general "catch all" 
          limitations period in Code of Civil Procedure Section 343 is 
          four years.  If the bill passes as drafted, there will be a six 
          year statute of limitations only for state employees overpaid 
          for leaves of absence for duty with the Guard.  All other state 
          employees will be subject to the general three-year rule.  Is 
          the equitable balance so different for members of the Guard that 
          they should be subjected to a statute of limitations double that 
          of other state employees?  

          Finally, the bill treats Guard members differently than members 
          of other military services.  Inconsistently, members of military 
          services other than the Guard who take a leave of absence and 
          are overpaid are still subject to the three year statute.

          Accrual of the statute of limitations:  If parallel 
          interpretations would be made from the civil to the 
          administrative arena, the civil statute of limitations for fraud 
          or mistake, as set forth above, may be found in Code of Civil 
          Procedure Section 338.  It provides a three year statute of 
          limitations for civil actions based on fraud or mistake.  The 
          statute is interpreted to begin to run only after alleged fraud 
          or mistake has been discovered or in the exercise of reasonable 
          diligence should have been discovered.  Thus in this case, if 
          the facts regarding overpayments were not known or within the 
          scope of reasonable diligence, the cause of action did not begin 
          to run and an extension of the statute of limitations might not 
          be necessary.


           Analysis Prepared by  :    John Spangler / V. A. / (916) 319-3550 

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