BILL ANALYSIS                                                                                                                                                                                                    �



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          Date of Hearing:  May 6, 2014

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                Bob Wieckowski, Chair
                     AB 1848 (Allen) - As Amended: March 28, 2014

           SUBJECT  :  DISABILITY DISCRIMINATION: PLACES OF PUBLIC  
          ACCOMMODATION

          KEY ISSUE  :  DOES THIS MEASURE, IN ITS EFFORT TO LIMIT THE  
          OBLIGATIONS OF BUSINESSES THAT FEEL THEY ARE UNFAIRLY SUBJECT TO  
          LAWSUITS UNDER OUR DISABILITY DISCRIMINATION LAWS, INADVERTENTLY  
          AND UNFAIRLY SINGLE OUT PEOPLE WITH DISABILITIES BY FORCING THEM  
          TO OVERCOME ADDITIONAL AND SUBSTANTIAL NEW BARRIERS TO THE  
          ENFORCEMENT OF THEIR CIVIL RIGHTS AND BY DENYING REMEDIES TO  
          VICTIMS OF DISABILITY DISCRIMINATION?
                                      SYNOPSIS
          
          Like other civil rights statutes that prohibit discrimination in  
          businesses open to the public, the statutory scheme for  
          enforcement of disability access laws rests on voluntary  
          compliance and individual legal actions.  There is no  
          governmental entity charged with administrative or judicial  
          enforcement of these obligations.  

          This bill reiterates a controversial question that the  
          Legislature has frequently heard and consistently rejected:  
          should people with disabilities be required to comply with  
          special procedural barriers not facing others who endure  
          discrimination before they can assert legal claims against  
          businesses that violate disability access laws, and should they  
          also be prevented from recovering for their injuries when they  
          suffer unlawful discrimination if the business corrects the  
          violation in the future? 

          According to the author, the bill is necessary because law suits  
          under the federal American Disability Act (ADA) have unfairly  
          targeted small business owners and property managers.  The  
          author further claims that the majority of these lawsuits have  
          forced businesses into bankruptcy.  

          Opponents argue that this bill singles out people with  
          disabilities for unprecedented obstacles to the enforcement of  
          civil rights, deprives them of a remedy for actual violations,  
          and will deter, not encourage, compliance with disability  








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          discrimination law.  Moreover, opponents state that the promise  
          of the bill may be misleadingly unattainable because the  
          requirements it would impose are inconsistent with federal  
          disability discrimination law and therefore would not preclude  
          the law suits from which businesses seek protection.

          In contrast to prior measures, this bill has attracted much less  
          support from business advocacy groups, apparently reflecting the  
          continuing consensus that lead to the adoption of SB 1186 in  
          2012 (Steinberg-Dutton), as well as its predecessor SB 1608  
          (Corbett and Harman) of 2008, both of which were historic  
          bipartisan measures to reduce disability access violations and  
          unnecessary lawsuits. 

           SUMMARY  :  Denies statutory remedies to persons with disabilities  
          unless the person first gives an unprecedented pre-litigation  
          notice to the violator.  Specifically,  this bill  :  

          1)Requires disabled persons who have been deprived of their  
            civil rights to full and equal access to places of public  
            accommodation to undertake prescribed notice procedures at  
            least 30 days before filing an action against a business for  
            an alleged violation of the above-described provisions.  

          2)Specifies the required content of the notice, including that  
            the notice must advise the recipient of the nature of the  
            accessibility violation and that the recipient may be civilly  
            liable for actual and statutory damages if the access barriers  
            that constitute the basis of the construction-related  
            accessibility claim are not removed during the 30-day time  
            period.  

           EXISTING LAW  :  

           1)Pursuant to federal law, under the Americans with Disabilities  
            Act (ADA), provides that no individual shall be discriminated  
            against on the basis of disability in the full and equal  
            enjoyment of the goods, services, facilities, privileges,  
            advantages, or accommodations of any place of public  
            accommodation by any person who owns, leases, or leases to, or  
            operates a place of public accommodation.  (42 U.S.C. Sec.  
            12182.)

          2)Provides that individuals with disabilities or medical  
            conditions have the same right as the general public to the  








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            full and free use of the streets, highways, sidewalks,  
            walkways, public buildings, medical facilities, including  
            hospitals, clinics and physicians' offices, public facilities  
            and other public places.  It also provides that a violation of  
            an individual's rights under the ADA constitutes a violation  
            of state law.  (Civ. Code Sec. 54.)

          3)Provides that individuals with disabilities shall be entitled  
            to full and equal access to public accommodations, subject  
            only to the conditions and limitations established by law, or  
            state or federal regulation, and applicable alike to all  
            persons.  It further provides that individuals with  
            disabilities shall be entitled to full and equal access to all  
            housing accommodations offered for rent or lease, subject to  
            conditions and limitations established by law.  (Civ. Code  
            Sec. 54.1.)  

          4)Provides that a violation of the ADA also constitutes a  
            violation of Section 54.1.  A violation of Section 54.1  
            subjects a person to actual damages, plus treble actual  
            damages but not less than $1,000, and attorney's fees as the  
            court deems proper.  (Civ. Code Sec. 55.)
          
          5)Provides pursuant to the Unruh Civil Rights Act that all  
            persons, regardless of sex, race, color, religion, ancestry,  
            national origin, disability or medical condition, are entitled  
            to the full and equal accommodations, advantages, facilities,  
            privileges, or services in all business establishments of  
            every kind whatsoever.  A violation of the ADA also  
            constitutes a violation of Unruh.  A violation of this section  
            subjects a person to actual damages incurred by an injured  
            party, treble actual damages but not less than $4,000, and any  
            attorney's fees as the court may determine to be proper.   
            (Civ. Code Sec. 51 et seq.)  

          6)Establishes the California Commission on Disability Access  
            (CCDA), an independent state agency composed of 19 members,  
            with the general responsibility for monitoring disability  
            access compliance in California, and making recommendations to  
            the Legislature for necessary changes in order to facilitate  
            implementation of state and federal laws on disability access.  
             (Gov. Code Sec. 8299 et seq.)
           
          7)Requires an attorney, when serving a demand for money letter  
            or a complaint on a defendant, to include a written advisory  








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            to the defendant of the defendant's rights and obligations,  
            including the right of a qualified defendant to request a stay  
            and an early evaluation conference regarding the allegations  
            in the complaint.  This written advisory is required from an  
            attorney only and is not required from a pro per plaintiff.   
            (Civ. Code Sec 55.3.)

          8)Defines terms for a disability access action, specifically, as  
            follows:

             a)   defines a qualified defendant as a defendant in an  
               action that includes an accessibility claim as to a place  
               of public accommodation that has been inspected by a  
               certified access specialist (CASp) and determined to meet  
               applicable construction-related accessibility standards or  
               pending determination by a CASp;
             b)   defines a certified access specialist whose inspection  
               report would be the basis for a defendant to qualify for  
               the early evaluation conference;
             c)   defines the construction-related accessibility standard  
               that a CASp would use to inspect and prepare a report on  
               the place of public accommodation; and
             d)   enumerates the duties of the CASp with respect to the  
               inspection, the corrections that may need to be made to the  
               site, written inspection report, and the statement of  
               compliance, including the issuance, upon completion of the  
               inspection and a determination that the site meets  
               applicable construction-related accessibility standards, of  
               a specified, watermarked, and sequentially numbered  
               disability access certificate that may be displayed at the  
               site.  (Civ. Code Sec. 55.52.)

          9)Provides that if a CASp determines that a site meets all  
            applicable construction-related accessibility claims the CASp  
            must provide a written inspection report to the requesting  
            party that includes specified information.  If the CASp  
            determines that corrections are needed to the site in order  
            for it to meet all applicable construction-related  
            accessibility standards, the CASp must provide a written  
            inspection report to the requesting party that identifies the  
            needed corrections and a schedule for completion.  (Civ. Code  
            Sec. 55.53.)

          10)Requires every CASp who completes an inspection of a site to  
            provide the owner or tenant with a disability access  








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            inspection certificate if the site either meets applicable  
            construction-related accessibility standards or is a CASp  
            determination pending site.  Existing law permits the building  
            owner or tenant to post the certificate on the premises  
            unless, after the date of inspection, the inspected site has  
            been modified or construction has commenced to modify the  
            inspected site in a way that may impact compliance with  
            construction-related accessibility standards.  (Civ. Code Sec.  
            55.53.)

          11)Outlines the specific process to be followed when filing a  
            disability access claim:

             a)   specifies the contents of the request and includes a  
               link to the Judicial Council of California's Web site to  
               access the appropriate court forms;
             b)   provides that a qualified defendant may file an  
               application requesting an early evaluation conference (EEC)  
               after the defendant is served with the summons and  
               complaint within 30 days of receiving the summons and  
               complaint;
             c)   grants qualified defendants a 90-day stay of the  
               proceedings with respect to the construction-related  
               accessibility claims, unless the plaintiff has obtained  
               temporary injunctive relief;
             d)   requires a mandatory EEC to be scheduled no later than  
               50 days after issuance of the order but no earlier than 21  
               days after the request is filed;
             e)   directs the parties to appear in person at the time set  
               for the conference;
             f)   directs the defendant to file with the court and serve  
               on the plaintiff a copy of any relevant CASp inspection  
               report at least 15 days prior to the date of the EEC;
             g)   directs the plaintiff to file with the court and serve  
               on the defendant at least 15 days prior to the date of the  
               EEC a statement containing, to the extent reasonably known,  
               an itemized list of the alleged violations, the amount of  
               damages claimed, the amount of attorney's fees and costs  
               claimed, and any demand for settlement of the case in its  
               entirety;
             h)   specifies that the court shall lift the stay when the  
               defendant has failed to file and serve the CASp inspection  
               report when required and also did not produce the report at  
               the EEC, unless good cause for the failure is shown;
             i)   specifies that the court may lift the stay at the  








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               conclusion of the EEC upon a showing of good cause by the  
               plaintiff;
             j)   specifies the court's authority to schedule additional  
               conferences or to extend the stay for no more than an  
               additional 90 days, upon a showing of good cause; and
             aa)  specifies the determinations the court would make at the  
               EEC.  (Civ. Code Sec. 55.54.)

          12)Provides that the stay and early evaluation conference shall  
            not be deemed to make any inspection report or opinion of a  
            CASp binding on the court or to abrogate the court's authority  
            to make appropriate findings of fact and law.  (Civ. Code Sec.  
            55.54.)

          13)Provides that the stay and early evaluation conference shall  
            not be construed to invalidate or limit any California  
            construction-related accessibility standard that provides  
            greater or equal protection for the rights of persons with  
            disabilities than is afforded by the ADA and the federal  
            regulations adopted pursuant to that act.  (Civ. Code Sec.  
            55.54.)
           
           14)Provides that notwithstanding the requirement that offers of  
            compromise are privileged and protected under Evidence Code  
            Section 1152, the court may consider, along with other  
            relevant information, settlement offers made and rejected by  
            the parties, in determining an award of reasonable attorney's  
            fees and recoverable costs in any construction-related  
            accessibility claim.  (Civ. Code Sec. 55.55.)

          15)Provides that statutory damages may be recovered in a  
            construction-related accessibility claim only if a violation  
            or violations of one or more construction-related  
            accessibility standards denied the plaintiff full and equal  
            access to the place of public accommodation on a particular  
            occasion.  Existing law specifies that a plaintiff is denied  
            full and equal access only if he or she personally encountered  
            the violation on a particular occasion or was deterred from  
            accessing the public accommodation on a particular occasion.   
            (Civ. Code Sec. 55.56.)

          16)Requires an attorney to provide a written advisory with each  
            demand letter or complaint, as defined, sent to or served upon  
            a defendant or potential defendant for any  
            construction-related accessibility claim, as specified.   








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            (Civil Code Sec. 55.3.)

          17)Requires an allegation of a construction-related  
            accessibility claim in a demand letter, or any allegation of  
            noncompliance with a construction-related accessibility  
            standard in a complaint, to state facts sufficient to allow  
            the defendant to identify the basis for the claim.  (Civil  
            Code Sec. 55.31.)

          18)Prohibits such a demand letter from including a request or  
            demand for money or an offer or agreement to accept money.   
            (Id.)

          19)Requires an attorney to include his or her State Bar license  
            number in such a demand letter, and to submit copies of the  
            demand letter to the California Commission on Disability  
            Access (CCDA) and, until January 1, 2016, to the State Bar.   
            (Civil Code Sec. 55.32.) 

          20)Requires, until January 1, 2016, an attorney to submit a copy  
            of a complaint to the CCDA and subjects the attorney to  
            disciplinary action for violation.  (Id.)

          21)Requires the CCDA to review and report on the demand letters  
            and complaints it receives until January 1, 2016.  Also  
            requires the State Bar, commencing July 31, 2013, and annually  
            each July 31 thereafter, to report specified information to  
            the Legislature regarding the demand letters that it receives.  
             (Id.)

          22)Permits other defendants to file a request for a court stay  
            and early evaluation conference pursuant to this provision,  
            including (A) a defendant, until January 1, 2018, whose site's  
            new construction or improvement on or after January 1, 2008,  
            and before January 1, 2016, was approved pursuant to the local  
            building permit and inspection process, (B) a defendant whose  
            site's new construction or improvement was approved by a local  
            public building department inspector who is a certified access  
            specialist, and (C) a defendant who is a small business, as  
            described.  (Civil Code Sec. 55.54.)

          23)Authorizes a defendant who does not qualify for an early  
            evaluation conference pursuant to these provisions, or who  
            forgoes those provisions, to request a mandatory evaluation  
            conference, as specified, and authorizes a plaintiff to make  








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            that request if the defendant does not make that request.   
            (Id.)

          24)Requires the court, in assessing liability in any action  
            alleging multiple claims for the same construction-related  
            accessibility violation on different particular occasions, to  
            consider the reasonableness of the plaintiff's conduct in  
            light of the plaintiff's obligation, if any, to mitigate  
            damages.  (Civil Code Sec. 55.56.)

          25)Reduces a defendant's minimum liability for statutory damages  
            in a construction-related accessibility claim against a place  
            of public accommodation to $1,000 for each unintentional  
            offense if the defendant has corrected all  
            construction-related violations that are the basis of the  
            claim within 60 days of being served with the complaint and  
            other specified conditions apply, and would reduce that  
            minimum liability to $2,000 for each unintentional offense if  
            the defendant has corrected all construction-related  
            violations that are the basis of the claim within 30 days of  
            being served with the complaint and the defendant is a small  
            business, as specified.  (Civil Code Sec. 55.56.)

          26)Requires the Department of General Services to make a  
            biannual adjustment to financial criteria defining a small  
            business for these purposes, and to post those adjusted  
            amounts on its Internet Web site.  (Id.)

          27)Requires a commercial property owner to state on a lease form  
            or rental agreement executed on or after July 1, 2013, if the  
            property being leased or rented has undergone inspection by a  
            certified access specialist.  (Civil Code Sec. 1938.)
           
          FISCAL EFFECT  :  As currently in print this bill is keyed  
          non-fiscal.

           COMMENTS  :  According to the author:

               In California, American Disability Act (ADA) lawsuits have  
               unfairly targeted small business owners and property  
               managers; with the majority of the lawsuits forcing the  
               business into bankruptcy.  A small minority of lawyers have  
               been taking advantage of these small business owners, many  
               of whom have little English speaking ability or literacy.









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               SB 1186 (Steinberg) (Chapter 383, September 2012) attempted  
               to lessen the impact of ADA lawsuits by adjusting the  
               minimum amount of liability damages against owners and  
               lessees of commercial properties who violated the American  
               Disability Act (ADA) with construction-related access  
               issues. However, this fix is not solving the bigger issue  
               of continued extortion.
                      
               This bill would amend the code section to where owners or  
               lessees who, without intent, are found at fault for  
               construction-related accessibility problems are:

               1.     Served a notice of violation of the ADA to the owner  
                 or lessee.

               2.     Allowed 30 days from the receipt of the notice to  
                 rectify the construction related accessibility issue.

               3.     If rectified within the 30 day allotment, the owner  
                 or lessee is not held liable for damages under the ADA.
           
          The Asserted Need For This Bill Rests On The Premise That The  
          Bipartisan Landmark Revision Of Disability Access Obligations  
          Pursuant To SB 1186 of 2012 Is Inadequate Or Has Failed,  
          Although No Evidence On That Point Has Been Produced  .  This  
          Committee in 2012 was directly involved in negotiating and  
          drafting SB 1186 (Steinberg-Dutton), a landmark bipartisan  
          measure carried by the Senate's majority and minority leaders.   
          The authors of that measure noted that it applied a common sense  
          approach to resolve difficult issues by maintaining the  
          hard-fought civil rights of the disabled community while helping  
          to protect California businesses from predatory demand for money  
          letters and lawsuits.  

          Among the far-reaching reforms worked by that bill was a  
          reduction in the minimum statutory damages for unintentional  
          violations by defendants, including all specified small  
          businesses, provided that they fix the alleged violations.  That  
          bill also prohibited both written and oral demands for money by  
          both lawyers and non-lawyers, and regulated the content and  
          provision of demand letters, including that both demand letters  
          and complaints be written with specificity, and required that  
          demand letters and civil complaints be submitted to the State  
          Bar of California and to the California Commission on Disability  
          Access (CCDA).  That bill was supported by a lengthy list of  








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          business advocates who argued that it would curb lawsuit abuse  
          regarding the American's With Disabilities Act (ADA) while  
          promoting increased compliance with disabled accessibility  
          building codes throughout the state. 

          Although SB 1186 has been in effect for only a scant few months,  
          the premise of this bill appears to be that the bipartisan  
          approach taken by that measure has already failed.  However, the  
          supporters of this bill have provided no evidence in support of  
          that contention.

           The Federal ADA Prohibits Businesses From Discriminating Against  
          Persons With Disabilities  .  Under the federal Americans with  
          Disabilities Act (ADA), a business that constitutes a place of  
          public accommodation (e.g., many places of lodging,  
          entertainment, recreation, restaurants, bars, theaters, stores,  
          health clubs, etc.) is prohibited from discriminating on the  
          basis of disability if its operations affect interstate  
          commerce.  Prohibited discrimination can take a number of forms  
          - e.g., denial of participation in the facility, or a service,  
                                                      benefit, or good of the business; denial of equal participation  
          in a good, service, or facility; or provision of a different or  
          separate facility, service or good (unless necessary to provide  
          services and the like that are as effective as that provided to  
          others).  Government facilities are also covered by the access  
          obligations of the ADA.

           Unlike Any Other Type Of Civil Rights Violation, This Bill Would  
          Allow Violators Of Disability Discrimination Laws To Potentially  
          Avoid Legal Responsibility And Would Deprive The Victim Of  
          Remedies If A Specific Notice Were Not Given - Or Even If The  
          Notice Were Given But The Violator Corrected The Condition After  
          The Violation.   The bill requires delivery of a notice to the  
          person alleged to have committed the violation.  However, the  
          identity and location of the business owner, landlord or other  
          violator may not always be apparent to the person who has been  
          denied access to the facility.  Indeed, because they have been  
          denied access to the facility the disabled person may not have  
          any information beyond the name of the business and the address  
          of the facility.  Moreover, the notice is required to specify  
          all the conditions constituting the violation, an accomplishment  
          that may be frustrated by a person's inability to access the  
          facility at all.  

          However, notice of the violations would not be enough by itself.  








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           The bill contains specific requirements that must be included.   
          Since the information contained in the notice must apparently be  
          specific to each and every violation, this obligation would  
          likely result in most claimants needing the assistance of an  
          attorney.  However, the need for an attorney would be frustrated  
          by the prospect that attorney's fees would not be awarded, even  
          if the plaintiff's claims were fully merited.  That is because  
          the bill provides that if a disabled person finds the right  
          person, crafts exactly the right notice, and accomplishes the  
          required delivery by the prescribed method, the victim would  
          nevertheless be prohibited from any recovery, including recovery  
          for attorney's fees for a genuine act of discrimination if the  
          cause of the problem were rectified in the future.  The  
          defendant would not be required to remedy the violation of the  
          plaintiff's rights, only to address the problem in the future.  

          It is highly unusual for a violation of any law to be overlooked  
          or forgiven because the victim has not given notice in advance.   
          It is even more unusual for a violator to avoid any legal  
          responsibility for the violation simply by correcting the  
          problem for the future.  The general principle of our civil (and  
          criminal) laws is that everyone is held accountable for the  
          wrongs they have committed, even if they are not warned in  
          advance and even if they comply with the law in the future.  The  
          Committee is unaware of any comparable provision in civil rights  
          law.

          Apart from the question of precedent, it may be asked whether  
          this bill promotes voluntary compliance and prevents violations,  
          as should be the goal of any law, or whether it might instead  
          inadvertently encourage and reward noncompliance by allowing a  
          business to avoid taking any steps to follow the law -- unless  
          and until a notice is provided, at which point it can avoid  
          responsibility for the legal wrongs and injuries it has caused.

          The bill also treats disability discrimination victims uniquely  
          in other ways.  First, the victim may be denied attorney's fees  
          and any recovery for injuries for bona fide discriminatory acts  
          simply because a prior unrelated complaint had - unbeknownst to  
          the new victim - previously alleged the same or even a "similar"  
          violation.  

           Would Businesses Be Potentially Misled About Their Exposure To  
          Liability If State Law Provided a Defense for ADA Violations  
          That the ADA Itself Does Not Allow?   This bill might immunize  








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          many ADA violations as a matter of state law.  But the ADA  
          itself imposes none of the requirements of this bill.  Of  
          course, state legislation cannot affect liability under federal  
          law, and acts that violate the ADA would therefore still be  
          actionable in state and federal court.  Thus, despite the  
          beguiling appeal of protection from state law violations,  
          businesses that violate the ADA would continue to be subject to  
          costly litigation, including money damages, civil penalties and  
          attorney's fees, irrespective of this bill. 

           Should State Law Single-Out One Minority Group For Special  
          Barriers To Enforcement Of Civil Rights Protections?   Persons  
          with disabilities are one group protected against discrimination  
          in the use and enjoyment of public facilities and  
          accommodations.  Under the Unruh Civil Rights Act, other  
          protected characteristics include race, national origin, sex and  
          sexual orientation.  This bill would uniquely impose its  
          advance-notice and good-faith-efforts rules on persons with  
          disabilities before they could seek a remedy for violations of  
          their civil rights.  

          It may be instructive on this point to note a recent federal  
          court decision noting: 

               The First Amendment right to "petition the Government for a  
               redress of grievances" - which includes the filing of  
               lawsuits - is "one of 'the most precious of the liberties  
               safeguarded by the Bill of Rights.'" ? Because the right to  
               access the courts implicates due process and First  
               Amendment rights, courts have been exceedingly reluctant to  
               restrict such access.  We have noted that [pre-litigation  
               restrictions on] an individual's access to the court  
               system, ? is an extraordinary remedy that should be  
               narrowly tailored and rarely used."  This is so even [when]  
               litigants and lawyers covered by [such restrictions] are  
               not entirely enjoined from filing suits, but must [merely]  
               obtain the court's approval first.  [Even a] pre-clearance  
               requirement is in itself a serious imposition on the right  
               to access the courts: "Among all other citizens, he is to  
               be restricted in his right of access to the courts.  As far  
               as he is concerned, his future filings run the risk of  
               delay and even possible rejection before he can call upon  
               defendants to respond to those filings.  (Molski v.  
               Evergreen Dynasty Corp., 2008 U.S. App. LEXIS 7372 (9th  
               Cir. Cal. Apr. 7, 2008) (Berzon, Kozinski, et al,  








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               dissenting from petition for rehearing en banc)(citations  
               omitted).)
           
          ARGUMENTS IN SUPPORT  :  The California Dental Association (CDA)  
          states:

               As a health care provider organization, CDA and its 24,000  
               members are especially sensitive to the importance of  
               providing access to disabled individuals, and we strive to  
               educate and encourage our members to accommodate all  
               patients, family members, and others who need access to the  
               dental office by achieving full compliance with federal and  
               state standards wherever needed. However, too many of our  
               members have been impacted by the frivolous lawsuits that  
               have continued to proliferate despite previous reform  
               efforts. 

               CDA supported SB 1186, enacted in 2012, which established a  
               number of new protections including reducing minimum  
               statutory damages, increasing notice requirements, and  
               prohibiting pre-lawsuit "demand letters" seeking payment.  
               Unfortunately, SB 1186 has not adequately resolved the  
               problem. 

               Disabled access modifications can be very costly and become  
               harder to afford after making a settlement payment to a  
               plaintiff. By providing a 30-day window to make necessary  
               fixes that will help prevent costly lawsuits and  
               settlements, AB 1848 will help foster disabled access  
               compliance. The bill does not impact the ability of anyone  
               to file a complaint over an access barrier. However, given  
               that the ADA has been in effect for 24 years and lawsuits  
               over violations continue to proliferate, it is clear that  
               costly litigation is not going to achieve access for all. 

               AB 1848 builds upon SB 1186 and will help resolve a  
               critical issue for disabled individuals and the dental  
               offices that have every desire to serve them. For these  
               reasons, we are pleased to support AB 1848.

          The California Apartment Association also writes in support,  
          stating:

               As an organization, CAA supports the federal and state goal  
               to ensure that individuals with disabilities have an equal  








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               opportunity for independent living.  CAA does not support,  
               however, unscrupulous attorneys who have profited from  
               accessibility laws by pursuing small property owners for  
               minor violations or misconceptions of the accessibility  
               laws.  While CAA does not condone ignorance of the law, CAA  
               has found that accessibility laws and compliance is not  
               easily understood by the general public.  In fact, because  
               of the flexibility in the legal standard referred to as  
               "readily achievable" (meaning changes to a building are  
               required only if they can be easily accomplished and can be  
               carried out by the property owner without much "difficulty  
               or expense"), a property owner cannot be completely sure  
               he/she has complied with the law.  

          In addition, the Civil Justice Association of California argues:

               The Legislature approved SB 1186 in 2012, which CJAC  
               supported, to help reduce the number of disabled access  
               lawsuits in California, recognizing that awareness of  
               disabled access obligations was lacking and that some were  
               abusing disabled access laws for financial gain.

               Senate Bill 1186 enacted a number of new protections  
               including reducing the minimum statutory damages for  
               specified businesses, increasing the notice requirements to  
               businesses, prohibiting pre-lawsuit "demand letters"  
               seeking money, and imposing a $1 fee on business licenses  
               to increase the state's supply of disabled-access experts.   
               Unfortunately, SB 1186 has not fully resolved the  
               underlying problem, which is the ongoing serial filing of  
               disabled access lawsuits by plaintiffs that prioritize  
               financial gain, over disabled access. These types of  
               plaintiffs are still filing "drive-by" lawsuits.

               ADA modifications can be very costly, and they become  
               harder to afford after making a settlement payment. This  
               bill would require a business to receive 30 days before a  
               complaint is filed a description of the barriers and then  
               provide 30 days to fix them before a lawsuit commences.  
               This bill does not impact the ability for a person injured  
               by a barrier to file a lawsuit. Drive-by lawsuits that  
               result only in settlement payments are not the way to  
               achieve the goal of disabled access. There are many  
               well-intentioned property owners who are trying to comply  
               but still may have minor technical violations due to the  








                                                                  AB 1848
                                                                  Page 15

               complexity and specificity of the regulations. Furthermore,  
               education and the fixing of barriers would encourage  
               disabled access. 

               This bill will build on SB 1186 and hopefully alleviate  
               some of the continuing shakedown lawsuits.

           ARGUMENTS IN OPPOSITION  :  Disability Rights California writes in  
          opposition: 

               Existing law provides that a plaintiff may recover  
               statutory damages in a construction-related accessibility  
               claim against a place of public accommodation only if a  
               violation of construction-related accessibility standards  
               denied the plaintiff full and equal access to that site on  
               a particular occasion. Existing law also requires a demand  
               letter alleging such a construction-related accessibility  
               claim to state facts sufficient to allow a reasonable  
               person to identify the basis of the violation or violations  
               supporting the claim. 

               This bill would require an alleged aggrieved party to  
               undertake prescribed notice procedures at least 30 days  
               before filing an action against a business for an alleged  
               violation of the above-described provisions. The notice  
               would advise the recipient of the nature of the  
               accessibility violation and that the recipient may be  
               civilly liable for actual and statutory damages if the  
               access barriers that constitute the basis of the  
               construction-related accessibility claim are not removed  
               during the 30-day time period. This bill would further  
               specify the required content of the notice and would  
               declare that a demand letter that includes specified  
               pre-litigation settlement negotiations, sent within the  
               bill's 30-day time period, constitutes compliance with the  
               requirements of the bill.

               Federal and state laws promote full inclusion of people  
               with disabilities and have been on the books for decades.   
               Any proposed revisions to access laws must be considered in  
               this context:  federal and state disability access laws and  
               regulations are vital to the promotion of the total  
               integration of people with disabilities into social and  
               economic life.  Further, California access laws and  
               policies have been in effect for decades and full  








                                                                  AB 1848
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               compliance by businesses still falls significantly short of  
               what is required. Since information regarding the  
               requirements of the law is widespread and available, there  
               is no excuse that compliance is so often dependent on  
               individual complaints and lawsuits.

               It is essential to remember that the current law contains  
               the minimum standards needed to provide access and already  
               takes into account such things as whether a building   
               pre-existed the adoption of the law, whether barrier  
               removal is achievable, and what resources are available to  
               do so.

               This bill treats people with disabilities as second class  
               citizens by targeting them for additional procedural and  
               legal barriers to enforce their rights. The bill singles  
               out people with disabilities, alone among all groups with  
               civil rights protections, to jump through legal hoops  
               before being able to have their civil rights violations  
               addressed.

               To the extent that it can be shown that there are abuses in  
               the use of access law remedies, any proposed solution must  
               be narrowly crafted to target only those abuses, without  
               impairing legitimate actions pursuant to laws necessary to  
               ensure access and civil rights.  

               SB 1186 (Steinberg) signed into law in late 2012 was such a  
               bill.  It provides that businesses [that] make good faith  
               efforts to comply with the law have reduced damage  
               liability and in fact even businesses who had not  
               undertaken any efforts to comply with the law receive  
               damage reductions.  Further SB 1186 has been in effect for  
               about one year, hardly time to assess its impact.

               If the real problem is attorney fees, both SB 1608  
               (Corbett) passed in 2008 and SB 1186 took steps to minimize  
               attorney fee exposure for businesses by setting up  
               processes such as early settlement conferences. As you  
               know, attorney fees are allowable under federal law, thus  
               changes in state law will have no impact on attorney fee  
               claims and in fact state law changes as proposed by this  
               bill may lead to fewer suits under state law resulting in  
               increased litigation costs - the very thing this bill  
               purports to correct. 








                                                                  AB 1848
                                                                  Page 17


               This bill is without factual foundation.  No hard data has  
               been provided regarding the scope and magnitude of the  
               alleged problems. In fact the California Commission on  
               Disability Access has identified the top ten access  
               problems - four of the top ten are related to parking.  See  
               http://www.ccda.ca.gov/Reports.htm.  Parking is one of the  
               easiest access violations to understand and correct.  
               Further other common violations are easy to understand and  
               correct in advance of a lawsuit.  Entities that violate the  
               law do not need advance written notice of their legal  
               obligations and time to correct the violation.  The federal  
               Americans with Disabilities Act has been in force for more  
               than 15 years and California disability access provisions  
               date back to the late 1960's. Businesses should know and  
               comply with these laws.
                
               Procedures already exist to deal with "vexatious litigants"  
               and "frivolous" law suits.  People with disabilities should  
               not have enforcement of their civil rights limited or  
               delayed because of the actions of a few, especially when  
               current procedures deal adequately with the problem.  
               Further SB 1186 provides for the California State Bar to  
               review attorney demand letters for possible disciplinary  
               action if it does not comply with California Civil Code  
               requirements. 
                
               California should not promote "wait and see if we get  
               caught" by businesses rather it should provide incentives  
               to comply up front.  Current law serves as a deterrent to  
               noncompliance, thereby preventing violations and helping to  
               ensure access.  This bill would eliminate this effect since  
               businesses and other entities would not need to correct  
               violations until or unless they receive notice of a  
               violation.

               Rather than encouraging businesses to wait and see if they  
               are caught - your bill should be looking for ways to  
               provide incentives to businesses to comply, such as:  
               collecting additional fees on business licenses to help  
               fund certified access specialist inspections and resulting  
               needed improvements (SB 1186 already require $1 be  
               collected to fund education activities); lease provisions  
               to ensure landlords have buildings inspected and brought  
               into compliance before they are leased (SB 1186 requires  








                                                                  AB 1848
                                                                  Page 18

               leases to state whether they have been inspected for  
               accessibility); educational material and training programs  
               provided to businesses when they apply for a business  
               license; and inspection programs similar to those conducted  
               by health and safety departments.  Let's have meaningful up  
               front access improvement efforts rather than efforts to  
               stop enforcement of the law.

          Consumer Attorneys of California also opposes the bill, stating:

               AB 1848 limits the legal rights of persons with  
               disabilities and treats them differently than other classes  
               of consumers by requiring notice and an opportunity to cure  
               violations.

               Restrictions on the rights of persons with disabilities  
               ignore the consensus product found in SB 1608  
               (Corbett-2008) and SB 1186 (Steinberg-Dutton-2012).   
               Significant and major legislation in this area passed last  
               session - let's give it an opportunity to work before we  
               enact more changes.  

               Our organization worked for more than five years - meeting  
               at least weekly and at times daily - with key advocates  
               from the disability community, the California Chamber of  
               Commerce, the California Restaurant Association, the  
               Business Properties Association, the California Hotel  
               Association, Disability Rights California, the California  
               Foundation for Independent Living  and others to craft a  
               workable solution to this issue. The resulting consensus  
               product, SB 1608 (Corbett-Harman), was signed into law,  
               effective January 2009. The law provided a number of  
               measures designed to both increase access and address the  
               abuse by those few attorneys who are abusing the system by  
               sending demand letters to businesses with the aim of  
               collecting fees and not enforcing compliance.  The effort  
               continued last session as CAOC participated in a year of  
               meetings, which resulted in the bi-partisan SB 1186 which  
               enacted further changes in the law.  

               CAOC has been actively involved to stop the few attorneys  
               who are sending demand letters without seeking access  
               change. 

               Since 2008, CAOC has been in the forefront of attempting to  








                                                                  AB 1848
                                                                  Page 19

               alert businesses about the legal protections received if  
               they hire a certified access specialist (CASp) and about  
               the law generally. We produced pamphlets in both English  
               and Spanish (attached), have put out business alerts via  
               our website, have participated in workshops and produced a  
               video for small businesses with 10 steps they can take to  
               make sure their businesses comply with the law. (Video  
               attached.)  

               Given the passage of SB 1608 and SB 1186 and our aggressive  
               outreach on this issue, we strongly believe that those  
               bills must be given a chance to work. Like any legislation,  
               they may not be perfect, but we think that it is an example  
               of diverse interest groups can work toward a collective  
               solution.  CAOC believes that California's disability  
               access laws should continue to ensure equal access to  
               business establishments for persons with disabilities. We  
               are aware of cases that have received publicity in this  
               area, but believe that the Legislature must be extremely  
                                                                careful in attempting to amend this area of the law. We do  
               believe that the goal of any ADA lawsuit should be to  
               ensure compliance, and we acknowledge that there have been  
               some suits that failed to target compliance as the primary  
               goal.  We are willing to continue to work on this issue.
           
          REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Apartment Association
          California Dental Association
          Civil Justice Association of California

           Opposition 
           
          Consumer Attorneys of California
          Disability Rights California
           
          Analysis Prepared by  :  Kevin G. Baker / JUD. / (916) 319-2334