BILL ANALYSIS                                                                                                                                                                                                    �






                 Senate Committee on Labor and Industrial Relations
                              Senator Ben Hueso, Chair

          Date of Hearing: June 25, 2014               2013-2014 Regular  
          Session                              
          Consultant: Gideon L. Baum                   Fiscal:Yes
                                                       Urgency: No
          
                                  Bill No: AB 2416
                                    Author: Stone
                         As Introduced/Amended: May 23, 2014
          

                                       SUBJECT
          
                           Liens: laborers and employers.


                                      KEY ISSUE

          Should the Legislature allow an employee to file a pre-judgment  
          lien on an employer's real and personal property in order to  
          assist the employee in collecting unpaid wages in the event of a  
          judgment against the employer?

                                      ANALYSIS
          
           Existing law  provides mechanics, persons furnishing materials,  
          artisans, and laborers of every class the right to file a lien  
          upon the property upon which they have bestowed labor or  
          furnished material for the value of such labor and material.   
          Existing law also requires the Legislature to provide, by law,  
          for the speedy and efficient enforcement of such liens.  
          (California Constitution Article XIV, Section 3)

           Existing law  provides for mechanics liens relating to services  
          and supplies authorized and provided on a work of improvement.   
          Existing law also regulates the conditions under which a  
          mechanics lien may be enforced.  (Civil Code ��8400-8494)

           Existing law  recognizes prejudgment wage liens against property  
          as a remedy in certain industries, including mining (Civil Code  
          �3060), agriculture (Civil Code ��3061.5-3061.6), and logging  
          (Civil Code �3065).

           Existing law  requires the Labor Commissioner and his or her  









          deputies and representatives authorized by him or her in  
          writing, upon the filing of a claim therefor by an employee, or  
          an employee representative authorized in writing by an employee,  
          with the Labor Commissioner, to take assignments of, among other  
          things, wage claims and incidental expense accounts and advances  
          and mechanics and other liens of employees.  (Labor Code �96)

           Existing law  authorizes the Labor Commissioner, after  
          investigation and upon determination that wages or monetary  
          benefits are due and unpaid to any worker in the State of  
          California, to collect such wages or benefits on behalf of the  
          worker without assignment of such wages or benefits to the  
          Commissioner.  (Labor Code �96.7)

           Existing law  authorizes the Labor Commissioner to investigate  
          employee complaints and provide for a hearing in any action to  
          recover wages, penalties, and other demands for compensation,  
          including liquidated damages if the complaint alleges payment of  
          a wage less than the minimum wage fixed by an order of the  
          Industrial Welfare Commission or by statute, properly before the  
          division or the Labor Commissioner, including orders of the  
          Industrial Welfare Commission, and is required to determine all  
          matters arising under his or her jurisdiction.  (Labor Code �98)

           Existing law  authorizes the Labor Commissioner, at the  
          Commissioner's discretion and upon a final order, to place a  
          lien on real property for amounts due under the final order and  
          in favor of the employee or employees named in the order, with  
          the county recorder of any county in which the employer's real  
          property may be located.  (Labor Code �98.2(g))
           
          This bill  would establish the California Wage Theft Prevention  
          Act, which would authorize an employee to have a lien on all  
          property of the employer in California, including after-acquired  
          property, for the full amount of any wages and other  
          compensation, penalties, and interest owed to the employee.

           Specifically, this bill would provide:  

             1.   That the amount of the lien would include unpaid wages  
               and other compensation required by California law,  
               penalties available under the Labor Code, interest at the  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 2

          Senate Committee on Labor and Industrial Relations 
          








               same rate as for prejudgment interest in this state, and  
               the costs of filing and service of the lien, but not less  
               than the amount required by law, including direct wages and  
               compensation required to be paid to other persons or  
               entities that would qualify as "employer payments," as  
               defined.

             2.   That a lien may be filed by any person or entity,  
               including any governmental agency, to which a portion of an  
               employer's compensation is payable or has standing under  
               applicable law to maintain a direct legal action on behalf  
               of the employee.

             3.   That a lien pursuant to this bill is in addition to any  
               other lien rights held by the employee and shall not be  
               construed to limit these rights.

           This bill  would limit an employee's lien upon personal property  
          to property subject to a security interest under the Commercial  
          Code pursuant to the filing of a financing statement with the  
          Secretary of State.

           This bill would PROHIBIT the following in the filing of a lien:
          
              1.   Prohibit a lien from being claimed by an employee who is  
               exempt from the protections of Industrial Welfare  
               Commission wage orders under the administrative, executive,  
               or professional exemptions, and, in any action involving  
               such a lien, the employer would be required to plead and  
               prove exempt status as an affirmative defense.

             2.   Prohibit a lien from attaching if the employer has  
               obtained a surety bond or insurance that provides for  
               payment of the wages and other compensation, penalties, and  
               interest, claimed by the employee and is in an amount that  
               is adequate to fully satisfy the employee's claim.  If the  
               surety bond or insurance contract is inadequate to cover  
               the entire amount of the employee's claim, this bill would  
               require the lien to be limited to the amount of the claim  
               that exceeds the bond or insurance coverage.

             3.   Prohibit the lien from attaching for labor performed  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 3

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               under a valid collective bargaining agreement if the  
               agreement expressly provides for a regular hourly pay of  
               not less than 30 percent more than the state minimum wage  
               rate, addresses the issue of security for the payment of  
               wages, and expressly waives requirements of this chapter in  
               clear and unambiguous terms.

           This bill would create the following FILING requirements:
          
              1.   Require the employee, at least five days prior to  
               recording a notice of lien with a county recorder or filing  
               a notice of lien with the Secretary of State, to provide  
               the owner of the property against which the lien is to be  
               recorded preliminary written notice of the intent to record  
               a notice of lien.

             2.   Require the employee to record a notice of lien on real  
               property with the county recorder in the county where the  
               real property is located. 

             3.   Require the employee to file a notice of lien on  
               personal property with the Secretary of State in the  
               manner, form, and place of filing as specified.  A notice  
               of lien would be required to be placed in the same file as  
               financing statements, as specified.
           
              4.   Provide that the lien attaches to all real property  
               owned by the employer at the time of the filing of the  
               notice of lien, or that is subsequently acquired by the  
               employer, that is located in any county in which the notice  
               of lien is recorded.

             5.   Provide that the lien attaches to all personal property  
               that is owned by the employer at the time of the filing of  
               the notice of lien, or that is subsequently acquired by the  
               employer, that can be made subject to a security interest  
               under the Commercial Code.

             6.   Provide that the lien would be permanently extinguished  
               unless a notice of lien is recorded or filed, and served  
               upon the employer, within 180 days of the date that the  
               employee ceased working for the employer.  That lien would  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 4

          Senate Committee on Labor and Industrial Relations 
          








               also be permanently extinguished as to property that is  
               transferred or sold by the employer, unless a notice of  
               lien was recorded or filed before the transfer or sale, as  
               specified.

             7.   Provide that if an employee, after receiving proper  
               notice under this bill, acts unreasonably and in bad faith  
               in recording or filing a notice of lien or in refusing to  
               file a release or reduction of the lien, the employer would  
               be entitled to recover attorney's fees and costs in an  
               action to remove or reduce the lien, and the court in its  
               discretion would be authorized to issue a fine, not to  
               exceed $1,000.
           
          This bill would require the following NOTICE requirements in  
          filing the lien:  
          
             1.   Require that notice to include specified information to  
               the extent known to the person giving the notice, proscribe  
               an informational statement for the employer, and also  
               provide that the notice would not be invalid by reason of  
               any variance from these requirements if the notice is  
               sufficient to substantially inform the person given notice  
               of the information required by this section and other  
               information required in the notice.

             2.   Require that notice to be made as specified and would be  
               deemed to have been given three business days after mailing  
               of the notice.

             3.   Require a notice of lien for real or personal property  
               to be  executed under penalty of perjury  and include the  
               following information:

                     A statement of the employee's demand for payment of  
                 the wages and other compensation, penalties, and  
                 interest, the amount owed to the employee, and if the  
                 amount is estimated, an explanation for the basis of the  
                 estimate; 
                     A general statement of the kind of work furnished by  
                 the employee and the dates of employment; 
                     The name of the person by whom the employee was  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 5

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                 employed; and
                     The employee's mailing address.
           
              1.   Require the employee to serve the notice of lien on the  
               employer, by certified mail with return receipt requested,  
               evidenced by a certificate of mailing, postage prepaid,  
               addressed to the employer at the employer's residence or  
               place of business.

             2.   Require the employee, in order to enforce a lien under  
               this bill, to demonstrate in a civil action, or in a Labor  
               Commissioner proceeding, as specified, that he or she is  
               owed wages or other compensation and any related penalties  
               and interest, or the employer's liability shall be  
               established pursuant to a citation issued, as specified,  
               and the process for contesting such a citation.

           This bill would create the following general LIEN ENFORCEMENT  
          requirements:  
          
             1.   Require the employee to commence an action to enforce  
               the lien and prove the amount owed within 90 days of the  
               date of filing or recording of the notice of lien.  If the  
               employee does not commence an action to enforce the lien  
               within that time, the lien would be permanently  
               extinguished and unenforceable, unless the employee and the  
               owner of the property subject to the lien agree to extend  
               the time.

             2.   Require the employee, if the lien has been extinguished,  
               upon demand and 15 days' notice by the employer or any  
               affected party, to record or file a release of the lien.   
               If an employee fails to file a release of the lien after  
               proper notice has been mailed to the employee's address as  
               indicated on the notice of the lien, the employer or  
               affected party would be authorized to petition the court  
               for an order releasing the lien.

             3.   Provide that if the employee acted unreasonably and in  
               bad faith in refusing to file a release of lien, the  
               employer or affected party would be entitled to recover its  
               attorney's fees and costs incurred in the action, and the  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 6

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               court in its discretion would be authorized to also issue a  
               fine not to exceed $1,000. 

             4.   Provide that if a notice of lien is recorded or filed  
               and an action to recover unpaid wages has been filed by the  
               employee, that action would also be deemed an action to  
               enforce the lien and  foreclose upon any property subject to  
               the recorded lien  .  In the judgment resulting from an  
               action, the court would be authorized to  order the sale at  
               a sheriff's auction or the transfer to the plaintiff of  
               title or possession of any property subject to the lien  .   
               Whether or not the court makes an order as part of the  
               judgment, any property subject to the lien could be  
               foreclosed upon at any point after a judgment for unpaid  
               wages is issued.

             5.   Require the court, if the proceeds of the sale of the  
               property subject to a lien are insufficient to pay all the  
               claimants, whether or not claims have been joined together,  
               to order the claimants to be paid in proportion to the  
               amount due each claimant.

             6.   Provide that if a court finds that false information was  
               knowingly and in bad faith included in a notice of lien by  
               an employee with an intent to defraud, the lien would be  
               extinguished, the right to a lien would be forfeited, and  
               the court would be authorized to award reasonable  
               attorney's fees and court costs to the property owner or  
               employer for action taken to defeat the lien claim.

           This bill would create the following LIEN ENFORCEMENT provisions  
          for the LABOR COMMISSIONER:  
          
             1.   Provide that if the employee chooses to pursue the wage  
               claim in an administrative proceeding before the Labor  
               Commissioner, the Labor Commissioner may establish the  
               amount of lien if a lien has been recorded.  If no lien has  
               been recorded at the time the administrative claim is  
               filed, the Labor Commissioner would be authorized to  
               provide the notice and record the lien on behalf of the  
               employee.

          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 7

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             2.   Provide that if the Labor Commissioner issues a  
               citation, as specified, for the failure to pay wages to an  
               employee, the Labor Commissioner may provide preliminary  
               notice and record a lien on behalf of the employee.

           This bill would create the following LIEN ENFORCEMENT provisions  
          for the COURTS:
          
              1.   Authorize the employee be awarded court costs and  
               reasonable attorney's fees for filing a successful action  
               to enforce the lien.

             2.   Authorize an appeal of the judgment by filing a notice  
               of appeal on or before 60 days after the entry of judgment.  
                If an appeal is filed, the lien would continue in force  
               until all issues on the appeal have been decided.  If the  
               period for appeal runs without an appeal having been filed,  
               or if the appeal fails, the judgment entered would be  
               equivalent to cancellation of the lien and its removal from  
               the record, and the judgment would be a recordable  
               instrument. 

             3.   Authorize any number of claims to enforce employee liens  
               against the same employer to be joined in a single  
               proceeding, but the court would be authorized to order  
               separate trials or hearings. 


           This bill would provide the following process for the  
          RELEASE/EXTINCTION of Lien:  
          
             1.   Require a lien on real or personal property to be  
                extinguished if judgment is entered against the employee in  
               the action to enforce the lien or if the case is dismissed  
               with prejudice  and require the judgment to include the date  
               the notice of lien was recorded and, to the extent  
               applicable, the county in which it was recorded, the book  
               and page or series number of the place in the legal records  
               in which the lien was recorded, and a legal description of  
               the property to which the lien attaches. 

             2.   Release the property described in the judgment from  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 8

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               claim of lien upon recordation of a certified copy of the  
               judgment.  Alternatively, if the lien is extinguished, upon  
               demand and 15 days' notice by the property owner, the  
               employee would be required to file a release of the lien.

             3.   Provide that, if an employee refuses to file a release  
               of the lien after proper notice, an employer or property  
               owner would be authorized to petition the court for an  
               order to file a release of the lien. If the employee acted  
               unreasonably and in bad faith in refusing to file a release  
               of the lien, the employer or property owner would be  
               entitled to attorney's fees and costs incurred in the  
               action, and the court in its discretion would be authorized  
               to also issue a fine not to exceed $1,000.

             4.   Would authorize an employer to release the notice of  
               lien if the employer contends any of the following:

                     That a notice of lien is not effective;
                     That the lien has been extinguished because required  
                 circumstances, as specified, are not present;
                     All wages due the employee have been paid;
                     The employer has obtained a surety bond;
                     The lien is for labor performed under a valid  
                 collective bargaining agreement, as specified;
                     The employee has failed to provide the required  
                 notice;
                     The employee or Labor Commissioner has failed to  
                 commence an action to enforce the lien within the  
                 specified time; or
                     The action has been resolved against the employee.

             1.   Would proscribe the following procedure to release the  
               notice of lien:
                     The employer provides notice to the employee that  
                 the employer believes that the lien should be released  
                 and the basis for that belief, and request that the  
                 employee record or file a release of the notice of lien; 
                     The employee fails to respond within 30 days of the  
                 date of mailing of the notice, the employer may give  
                 notice to the Labor Commissioner that the employee did  
                 not respond, and request that the Labor Commissioner file  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 9

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                 or record a release of the notice of lien; and
                     Upon receiving the employer's request, the Labor  
                 Commissioner would be required to notify the employee  
                 that unless the employee serves an objection on the Labor  
                 Commissioner within 30 days, the Labor Commissioner would  
                 release the notice of lien; 

           This bill would create a parallel wage lien process for a lien  
          on PROPERTY WHERE WORK WAS PERFORMED:
          

           Authorize an employee to have a lien on the real property at  
          which the employee performed work, for the amount of any wages  
          and other compensation, penalties, and interest owed to the  
          employee for performing work at that property, under any of the  
          following circumstances: 

                     The  property owner and the employee's employer are  
                 related parties  ; if the property owner is a natural  
                 person, this lien would apply to the property owner's  
                 principal residence only to the extent that the employee  
                 provided labor to the benefit of that household or  
                 residence; 
                     The employee was  employed by a contractor or  
                 subcontractor performing services for the property owner  
                 or its agent  , or for a related party to the property  
                 owner, or for the related party's agent, regardless of  
                 whether a written contract exists; this provision would  
                 not apply if the services were provided to a household or  
                 residence; or
                     The employee was  employed to perform property  
                 services work on commercial property by the property  
                 owner's lawful tenant or subtenant or by the tenant's or  
                 subtenant's agent  , or by a contractor or subcontractor in  
                 the execution of a contract awarded by the tenant or  
                 subtenant or by the tenant's or subtenant's agent,  
                 regardless of whether a written contract exists.  This  
                 bill would define "property services work" to mean work  
                 in the janitorial, security guard, parking services, and  
                 landscaping and gardening industries; 
           
          This bill  would define "related parties" to mean a party owns or  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 10

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          controls, or is owned or controlled, or is under common  
          ownership or control, with the other party; "ownership" would  
          mean  50 percent or greater ownership  and "control" would mean  
          the right granted by law to exercise decision power over  
                                                          administration, finances, and operations.

           This bill  would not apply to the extent that the employee would  
          be entitled to a mechanic's lien on the same property.



          
                                      COMMENTS

          
          1.  Amendments Taken in the Senate Committee on the Judiciary:  

            Due to the double-referral of AB 2416 and pending legislative  
            deadline, amendments agreed to by the Judiciary Committee were  
            NOT TAKEN so this Committee could receive AB 2416 in a timely  
            manner.   This Committee will need adopt the Judiciary  
            Committee's amendments if AB 2416 is passed today  .  The  
            Judiciary Amendments were as follows:

             1)   Prohibit the filing of any wage lien on an employer's  
               personal residence;

             2)   Require the clear identification of the property the  
               wage lien would attach to; and

             3)   Change the name of the AB 2416's title to the  
               "California Wage Theft Recovery Act".

          2.  Wage Theft: A Brief Background

             In 2008, the Ford Foundation sponsored a survey of 4,387  
            workers in low-wage industries in the three largest U.S.  
            cities: Chicago, Los Angeles and New York City.  The report of  
            that survey, titled Broken Laws, Unprotected Workers:  
            Violations of Employment and Labor Laws in America's Cities,  
            revealed that 26 percent of workers in the sample were paid  
            less than the legally required minimum wage the prior work  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 11

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            week, and 60 percent of these workers were underpaid by more  
            than $1 per hour.  In addition, 76 percent of the respondents  
            who worked overtime in the previous week were not paid the  
            legally required overtime rate by their employers.

            The study also notes that minimum wage violation rates vary  
            significantly by industry, and occupation.  For example, some  
            industries, such as apparel and textile manufacturing and  
            personal and repair services have minimum wage violation rates  
            that exceed 40 percent, while others, including restaurants,  
            and retail and grocery stores, have rates of 20 to 25 percent.  
             However, the study found that undocumented immigrant women  
            were at the greatest risk of minimum wage violations.  The  
            study estimated that the workers in low-wage industries  
            Chicago, Los Angeles, and New York City lose more than $56.4  
            million per week due to labor law violations.

            A follow-up study by the UCLA Institute for Research and Labor  
            and Employment was published earlier this year, and that study  
            utilized the data from the 2008 survey, but focused  
            specifically on Los Angeles County.  This study, titled Wage  
            Theft and Workplace Violations in Los Angeles: The Failure of  
            Employment and Labor Law for Low-Wage Workers focused on a  
            survey results of 1,815 workers in Los Angeles County.  

            This study found similar results to the national survey:  
            almost 30 percent of the workers sampled were paid less than  
            the minimum wage in the prior work week, and 63.3 percent of  
            these workers were underpaid by more than $1 per hour.   
            Assuming a full-year work schedule, Los Angeles County survey  
            respondents lost an average of $2,070.00 annually out of total  
            earnings of $16,536.00.  The study estimated that  workers in  
            low-wage industries in   Los Angeles County lose more than $26.2  
            million per week  as a result of employment and labor law  
            violations.

            Both of the studies make the same public policy  
            recommendations to address these issues, which included  
            strengthening government enforcement of existing employment  
            and labor laws and stiffening the penalties.

          3.  Wage Theft in California: Collecting Unpaid Wages  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 12

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            Equally troubling, if not more troubling, than the high rate  
            of wage theft in California is the low rate of collections.   
            According to a 2013 report published by the National  
            Employment Law Project (NELP) and the UCLA Labor Center,  only  
            17% of workers who PREVAILED  in their wage claims before the  
            DLSE and won a judgment  were able to receive any payment  
            between 2008 and 2011.   Of those who did receive payment  
            between 2008 and 2011, workers  were able to collect 15% of  
            what was OWED  .  In short, the vast majority of wage theft  
            victims received nothing, and those that received anything  
            received little of what they were legally due.

            The 2013 report noted that there are several tools for wage  
            collection in California, including the administrative court  
            system, the court system, and post-judgment liens, the study's  
            authors argued that these tools were not effective as  60% of  
            businesses were no longer active by the time the wage judgment  
            became final  .  With no active business to file against, a lien  
            for unpaid wages had no property or business entity to attach  
            to.  The authors' specifically argued that a post-judgment  
            lien attachment was necessary, pointing to the successes of  
            Wisconsin as a model for California.

          4.  Wage Theft in Wisconsin: Collecting Unpaid Wages
           
            Since 1993, Wisconsin has allowed workers who claim to be  
            victims of wage theft to file a lien on their employers'  
            personal and real property.  Employees can work through the  
            Wisconsin Department of Workforce Development's Equal Rights  
            Division (roughly equivalent to California's Division of Labor  
            Standards Enforcement), or they can file their own wage liens  
            with an attorney.  Workers who pursue their wage liens can be  
            represented by the Wisconsin Department of Justice, however.

            According to the 2013 NELP-UCLA Labor Center report,  80% of  
            workers in Wisconsin were paid in part or in full  through the  
            wage lien collection process.  55% of the wage liens were paid  
            in full, and 25% of claimed wages were collected.  As was  
            noted in the report, Wisconsin appears to be doing a better  
            job of collecting on wage claims by every possible metric.   
            The report also notes that Wisconsin files a small number of  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 13

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            liens each year (about 3,300), suggesting that the wage lien  
            provisions may provide a significant deterrent to wage theft.

            Committee staff reached out to Wisconsin officials in both  
            Wisconsin's Department of Justice (DOJ) and Department of  
            Workforce Development (DWD) in order to find out of the wage  
            lien statute was a source of nuisance liens or frictional  
            litigation.  Both Wisconsin DOJ and DWD staff reported that  
            they were unaware of any such abuses.  This is particularly  
            noteworthy, as the Wisconsin statute has been in effect for  
            over 20 years.

          5.  AB 2416 and the Wisconsin Wage Theft Statute:  

            Closely modeled after the Wisconsin wage theft statute, AB  
            2416 would create an ability for workers to file a  
            pre-judgment lien on the real and personal property of their  
            employer in order to collect unpaid wages.  A pre-judgment  
            lien could be filed by either the Division of Labor Standards  
            Enforcement or an attorney representing an aggrieved worker.   
            The author believes that AB 2416 will improve California's  
            wage theft collection rates, moving California towards  
            Wisconsin's wage theft collection rates.

             One notable difference  , however, between Wisconsin and  
            California is how the wage liens would be filed.  In  
            Wisconsin, a wage lien can be filed through an online portal  
            run by Wisconsin's Department of Financial Institutions  
            (WIDFI).  WIDFI's portal allows liens to be filed and  
            extinguished through  a simple, one-stop online website  .  AB  
            2416 would require a filing under the penalty of perjury at  
            both the Secretary of State's office and the relevant County  
            Registrar.  This is considerably more complex, and it may pose  
            implementation challenges in California that were not faced by  
            Wisconsin.

          6.  Staff Comments:  

            AB 2416: A Significant Experiment in Improving Wage Theft  
            Collection Rates

            As noted above, AB 2416 stands as a significant experiment in  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 14

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            improving wage theft collection rates.  While California may  
            improve and approach the wage theft collection rates of  
            Wisconsin, it not all guaranteed, nor is there a clear  
            mechanism on how that would be measured.  Therefore, the  
            Committee may wish to consider requiring that DLSE studies the  
            impact of AB 2416. 

            Including a Sunset Clause to Allow for Further Review? 

            Noting the experimental nature of AB 2416 in California, the  
            author may wish to consider including a 7-year sunset in order  
            to allow for the Legislature to return to the issue of  
            pre-judgment wage liens and wage theft collection rates in the  
            future.  Paired with a study, such an approach would give the  
            Legislature and stakeholders a firm sense of the successes and  
            challenges of allowing pre-judgment wage liens in wage theft  
            collections.

            Suggested Amendments

            In reviewing the bill, Committee Staff noted several technical  
            issues that would strengthen the bill moving forward,  
            including requiring a DLSE study.  These suggested amendments  
            are below, and would be taken with the amendments from the  
            Senate Judiciary Committee:

             1)   Conforming the Timeline for Wage Lien Notices
               Currently, the timeline for notifying an employer of a wage  
               lien being filed with the Secretary of State is 5 days,  
               while filing a wage lien notice on a property owner is 20  
               days.  It would make more sense to conform these timelines.

               On page 4, line 21, strike "five" and insert "twenty";

                  On page 4, line 34, strike "five" and insert "twenty";

             2)   Tightening the Timelines
               
               Currently, AB 2416 provides 90 days for an employee to take  
               action on his or her lien, after which it is extinguished.   
               As the lien has already been filed, this length of time  
               seems longer than necessary to create a negotiated release  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 15

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               of the lien, and would seem to invite delaying tactics to  
               the detriment of a property owner.  Shortening the timeline  
               to 45 days would provide sufficient for negotiations but  
               limit delaying tactics.  

               On page 5, line 22, strike "90" and insert "45";

               On page 14, line 22, strike "90" and insert "45";

             3)   Removing Inadvertent "Double Jeopardy"

               Under a strict interpretation of the timelines, it would be  
               possible to fail to pursue a lien within the current 90 day  
               window (the above amendment would change that to 45 days)  
               but still pursue it within a 180 day period due to an  
               unrelated timeline.  This amendment would correct that  
               inadvertent issue.

               On page 5, after line 33, insert: "If a lien has been  
               permanently extinguished pursuant to this subdivision  
               because the employee has not commenced an action to enforce  
               the lien within the applicable time period, the employee  
               may not record or file another lien under Section 3000  
               claiming the same unpaid wages, compensation, penalties  
               and/or costs claimed by the extinguished lien."

               On page 14, after line 32, insert:  "If a lien has been  
               permanently extinguished pursuant to this subdivision  
               because the employee has not commenced an action to enforce  
               the lien within the applicable time period, the employee  
               may not record or file another lien under Section 3010  
               claiming the same unpaid wages, compensation, penalties  
               and/or costs claimed by the extinguished lien."

             4)   Study by the Division of Labor Standards Enforcement:
          
               As was discussed above, this amendment would create the  
               requirement for a study on the impact of AB 2416 on wage  
               theft collection.

               On page 18, between lines 27 and 28, insert: "3017. On or  
               before January 1, 2019, the Department of Industrial  
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 16

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               Relations shall issue a report to the Legislature on the  
               impact of the Wage Theft Recovery Act.  The report shall,  
               at a minimum, report on how many wage liens were filed, how  
               many wage liens led to the foreclosure or seizure of  
               property, and the impact of this legislation on unpaid wage  
               collection.

          7.  Proponent Arguments  :
            
            Proponents, noting the 2010 wage theft study discussed  
            earlier, argue that wage theft is a significant problem in  
            California, with LA County's wage theft resulting in over $1  
            billion unlawfully failing to reach the workers who  
            desperately need it.  Proponents also note that current wage  
            theft collection rates are less than 20%, meaning the vast  
            majority of scofflaw employers are successful in robbing their  
            workers of their lawful wages.  Proponents believe that AB  
            2416 will help combat the high rate of wage theft in  
            California by creating a simple lien process for workers to  
            use against employers who rob them of their wages.   
            Proponents, noting Wisconsin's success, argue that wage liens  
            are simple, effective, and a time tested approach to halting  
            wage theft.

          8.  Opponent Arguments  :

            Opponents argue that AB 2416 would hurt California businesses  
            by allowing any employee, governmental agency, or employee  
            representative to record liens on an employer's real property  
            or any property for an alleged, yet unproven, wage claim.   
            Proponents also note that AB 2416 is not just limited to  
            minimum wage claims, but could include vacation pay, expense  
            reimbursements, and compensation for tools, uniforms, and  
            equipment.  Opponents also argue that the ability of an  
            employee to file a wage lien against a third-party commercial  
            property owner who had no actual control over the employee  
            will create significant market disruptions.  Finally,  
            opponents argue that this bill would place a significant  
            burden on California's courts, and that there are already  
            sufficient protections in place for the failure to pay wages.

          9.  Prior Legislation  :
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 17

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            AB 469 (Swanson), Chapter 655, Statutes of 2011, increases the  
            statute of limitations and bonding requirements for the  
            failure to pay the minimum wage and overtime wages, as well as  
            requires the provision of a notice at the time of hiring that  
            lists the relevant details of a worker's employment.


                                       SUPPORT
          
          Service Employees International Union California (Sponsor)
          Asian Americans Advancing Justice-Asian Law Caucus
          Asian Americans Advancing Justice-Los Angeles
          California Employment Lawyers Association
          California Labor Federation, AFL-CIO
          California Professional Firefighters
          California School Employees Association; AFL-CIO
          Centro Legal de la Raza
          Chinese Progressive Association
          CLEAN Carwash Campaign
          Coalition for Humane Immigrant Rights of Los Angeles
          Community Action Board of Santa Cruz County
          Consumer Attorneys of California
          Employee Rights Center
          Equal Rights Advocates
          Filipino Advocates for Justice
          Garment Workers Center
          Golden Gate University School of Law
          Koreatown Immigrant Workers Alliance
          Labor & Employment Committee
          Los Angeles Alliance for a New Economy
          Maintenance Cooperation Trust Fund
          National Day Laborer Organizing Network
          National Employment Law Project
          National Immigration Law Center; National Lawyers Guild
          Sunrise Floor Systems LLC
          Wage Justice Center
          Women's Employment Rights Clinic
          Workplace Justice Initiative

          (List from Senate Judiciary analysis)

          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 18

          Senate Committee on Labor and Industrial Relations 
          









                                     OPPOSITION
          
          Acclamation Insurance Management Services
          Air Conditioning Trade Association
          Allied Managed Care
          Associated Builders and Contractors of California
          Associated Builders and Contractors - San Diego Chapter
          Associated General Contractors
          Building Owners and Managers Association of California
          California Apartment Association
          California Association for Health Services at Home
          California Association of Winegrape Growers
          California Building Industry Association
          California Business Properties Association
          California Business Roundtable
          California Chamber of Commerce
          California Chapter of American Fence Association
          California Employment Law Council
          California Farm Bureau Federation
          California Fence Contractors' Association
          California Grocers Association
          California Hospital Association
          California Hotel and Lodging Association
          California Land Title Association
          California Landscape Contractors Association
          California League of Food Processors
          California Manufacturers and Technology Association
          California Mortgage Bankers Association
          California Newspaper Publishers Association
          California Pool and Spa Association
          California Professional Association of Specialty Contractor
          California Restaurant Association
          California Retailers Association
          Civil Justice Association of California
          Coalition of Small and Disabled Veterans Businesses
          Construction Employers' Association
          El Centro Chamber of Commerce
          Flasher Barricade Association
          Fullerton Chamber of Commerce
          Greater Bakersfield Chamber of Commerce
          Greater Riverside Chambers of Commerce
          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 19

          Senate Committee on Labor and Industrial Relations 
          








          Independent Insurance Agents & Brokers of California
          International Council of Shopping Centers
          Marin Builders Association
          NAIOP of California
          The Commercial Real Estate Development Association
          National Federation of Independent Business
          Orange County Business Council
          Oxnard Chamber of Commerce
          Palm Desert Area Chamber of Commerce
          Plumbing-Heating-Cooling Contractors Association of California
          Porterville Chamber of Commerce
          San Jose Silicon Valley Chamber of Commerce
          Santa Clara Chamber of Commerce and Convention-Visitors Bureau
          Simi Valley Chamber of Commerce
          Southwest California Legislative Council
          Tahoe Chamber of Commerce
          Visalia Chamber of Commerce
          Western Electrical Contractors Association
          Western Growers Association
          1 individual

          (List from Senate Judiciary analysis)



















          Hearing Date:  June 25, 2014                             AB 2416  
          Consultant: Gideon L. Baum                               Page 20

          Senate Committee on Labor and Industrial Relations