BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2617
                                                                  Page 1

          Date of Hearing:  April 29, 2014

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                Bob Wieckowski, Chair
                  AB 2617 (Weber) - As Introduced: February 21, 2014

                              As Proposed to be Amended
                                           
          SUBJECT  :  HATE CRIMES: MANDATORY WAIVERS OF LEGAL RIGHTS AND  
          PROTECTIONS

           KEY ISSUE  :  SHOULD THE CIVIL RIGHTS AND PROCEDURES ESTABLISHED  
          BY THE STATE'S HATE CRIMES LAWS BE PROTECTED AGAINST FORCED AND  
          INVOLUNTARY WAIVERS IN ORDER TO PRESERVE THE IMPORTANT PUBLIC  
          INTERESTS UNDERLYING THOSE STATUTES? 

                                      SYNOPSIS

          This bill repeats a prior measure, AB 1680 (Salda�a) of 2010,  
          the Hate Crimes Protection Act, which passed this Committee but  
          was vetoed by Governor Schwarzenegger.  The bill governs  
          contracts that require the waiver of civil rights, remedies and  
          procedures established by the state's hate-crimes statutes.   
          While the bill permits such waivers, including pre-dispute  
          arbitration clauses, it would require that they be knowing and  
          voluntary, not coerced or compelled as a condition of doing  
          business.  Supporters argue that hate crimes are fundamentally  
          different types of wrongs than the kind of commercial disputes  
          that may be appropriate for contractual private arbitration or  
          other waiver agreements, and that the state has an interest in  
          preventing compulsory waiver of the rights and procedures  
          established by the hate crimes laws, including diversion into  
          secret and unregulated dispute resolution systems.  Opponents  
          representing business interests do not take issue with the  
          involuntary waiver of civil rights, but focus their arguments on  
          the claimed benefits of private arbitration, including that it  
          is fast, fair and economical, and therefore superior to the  
          public court system for the resolution of disputes.  However,  
          opponents do not say why waivers of civil rights should be  
          compelled against the will of the victim if arbitration is  
          indeed a better system, nor do opponents explain why they  
          believe the bill would prohibit all private arbitration  
          agreements regarding hate crimes if contracting parties could  
          voluntarily elect arbitration as an option, as they apparently  
          would be free to do under this bill.  Opponents also contend  








                                                                  AB 2617
                                                                  Page 2

          that the bill is pre-empted by the federal law.

           SUMMARY  :  Restricts contractual waiver of certain civil rights  
          statutes.  Specifically,  this bill  :  

          1)Provides that no person shall require another person to waive  
            any legal right, penalty, remedy, forum, or procedure for  
            violation of the Ralph Civil Rights Act or the Bane Civil  
            Rights Act as a condition of entering into a contract for the  
            provision of goods and services, including the right to file  
            and pursue a civil action or complaint with or otherwise  
            notify the Attorney General or any other public prosecutor or  
            any law enforcement agency, the Department of Fair Employment  
            and Housing, or any court or other governmental entity.

          2)Provides that no person shall refuse to enter into a contract  
            with, or refuse to provide goods or services to, another  
            person on the basis that the other person refuses to waive any  
            legal right, penalty, remedy, forum, or procedure for  
            violation of these civil rights acts.

          3)Provides that the exercise of a person's right to refuse to  
            waive any legal right, penalty, remedy, forum or procedure for  
            a violation of these civil rights laws shall not affect any  
            otherwise legal terms of a contract or an agreement.

          4)Requires that any waiver of any legal right, penalty, remedy,  
            forum, or procedure for violation of these civil rights acts  
            shall be knowing and voluntary, and in writing, and expressly  
            not made as a condition of entering into the contract or as a  
            condition of providing or receiving goods and services, and  
            that any person who seeks to enforce such a waiver shall have  
            the burden of proving that it was knowing and voluntary and  
            not made as a condition of the contract or of providing or  
            receiving the goods or services.

          5)Provides that the foregoing protections apply to any agreement  
            to waive any legal right, penalty, remedy, forum or procedure  
            for a violation of these civil rights laws entered into,  
            altered, modified, renewed, or extended on or after January 1,  
            2011. 

           EXISTING LAW  :

          1)Establishes the Ralph Civil Rights Act, which provides that  








                                                                  AB 2617
                                                                  Page 3

            all persons within the jurisdiction of this state have the  
            right to be free from any violence, or intimidation by threat  
            of violence, committed against their persons or property  
            because of political affiliation, or on account of [sex, race,  
            color, religion, ancestry, national origin, disability,  
            medical condition, marital status, or sexual orientation] or  
            position in a labor dispute, or because another person  
            perceives them to have one or more of those characteristics.   
            (Civil Code section 51.7.)

          2)Provides that a person who violates the Ralph Civil Rights Act  
            or aids, incites, or conspires in that act, is liable for each  
            and every offense for the actual damages suffered by any  
            person denied that right, as well as a civil penalty of  
            $25,000, exemplary damages and attorney's fees.  (Civil Code  
            section 52(b).)

          3)Further provides that whenever there is reasonable cause to  
            believe that any person or group of persons is engaged in  
            conduct of resistance to the full enjoyment of any of the  
            foregoing rights the Attorney General, any district attorney  
            or city attorney, or any person aggrieved by the conduct may  
            bring a civil action.  (Civil Code section 52(c).)

          4)Establishes the Bane Civil Rights Act, which provides that if  
            a person interferes by threats, intimidation, or coercion, or  
            attempts to interfere by threats, intimidation, or coercion,  
            with the exercise or enjoyment by any individual of rights  
            secured by the Constitution or laws of the United States, or  
            of the rights secured by the Constitution or laws of this  
            state, the Attorney General, or any district attorney or city  
            attorney may bring a civil action for a civil penalty,  
            injunctive and other appropriate equitable relief in the name  
            of the people of the State of California, in order to protect  
            the peaceable exercise or enjoyment of the right or rights  
            secured.  Likewise, an individual whose exercise or enjoyment  
            of rights secured by the Constitution or laws of the United  
            States, or of rights secured by the Constitution or laws of  
            this state, has been so interfered with, or attempted to be  
            interfered with, may institute and prosecute in his or her own  
            name and on his or her own behalf a civil action for damages,  
            injunctive relief, and other appropriate equitable relief to  
            protect the peaceable exercise or enjoyment of the right or  
            rights secured.  (Civil Code section 52.)









                                                                  AB 2617
                                                                  Page 4

          5)Establishes the California Arbitration Act which provides that  
            agreements to arbitrate shall be valid, irrevocable, and  
            enforceable, except such grounds as exist at law or in equity  
            for the revocation of any contract.  (Code of Civil Procedure  
            section 1280 et seq.)

          6)Similarly establishes the Federal Arbitration Act (FAA) which  
            provides that agreements to arbitrate shall be valid,  
            irrevocable, and enforceable, except such grounds as exist at  
            law or in equity for the revocation of any contract.  (9 USC  
            Section 1 et seq.) 

          7)Provides that trial by jury is an inviolate right and shall be  
            secured to all.  (Cal. Const. Article 1, Section 16.)

          8)Permits arbitrators to disregard the law and/or the evidence  
            in rendering their decisions.  Awards may be enforced by the  
            court, even if they are legally and factually erroneous.   
            (Moncharsh v. Heily & Blase et al (1992) 3 Cal.4th 1.)

          9)Allows private arbitrators to issue binding decisions that are  
            legally enforceable but essentially not reviewable by a court;  
            there is no appeal from an arbitrator's decision to a public  
            court unless the arbitration agreement expressly provides for  
            judicial review.  (Crowell v. Downey Community Hospital  
            Foundation (2002) 95 Cal. App. 4th 730; Cable Connection, Inc.  
            v. DIRECTV, Inc., 44 Cal. 4th 1334 (2008).)

          10)   Permits enforcement of private arbitration agreements that  
            preclude not only access to the courts but also access to  
            other governmental bodies responsible for enforcing state  
            laws, such as administrative complaint procedures regarding  
            employment laws.  (Sonic-Calabasas A, Inc. v. Moreno, 174 Cal.  
            App. 4th 546 (2009), rev. granted, 99 Cal. Rptr. 3d 866  
            (2009).)

          11)   Allows arbitrators to conduct arbitrations without  
            allowing for discovery, complying with the rules of evidence,  
            or explaining their decisions in written opinions.  (Code of  
            Civil Procedure Sections 1283.1, 1282.2, 1283.4.)

          12)   Permits arbitrations to be conducted in private with no  
            public scrutiny.  (Ting v. AT&T (2002) 182 F.Supp. 2d 902  
            (N.D. Cal.), affirmed, 319 F.3d 1126 (9th Cir 2003).)









                                                                  AB 2617
                                                                  Page 5

          13)   Allows arbitrators substantial if not absolute immunity  
            from civil liability for acts relating to their decisions,  
            even in the case of bias, fraud, corruption or other violation  
            of law.  (Baar v. Tigerman (1983) 140 Cal. App. 3d 979.)

          14)   Limits the relief that a court may grant to a party in  
            arbitration, no matter what misconduct has taken place in the  
            arbitration, to potential vacatur of the award and returning  
            the parties to further arbitration, perhaps with the same  
            arbitrator or arbitration company.  The grounds on which an  
            arbitrator's decision may be vacated are narrow and the  
            standards for vacatur are high.  (Code of Civil Procedure  
            Section 1282.6.)

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

           COMMENTS  :  The author explains the reason for the bill as  
          follows:

               While voluntary arbitration agreements are appropriate in  
               many instances, pre-emptively forcing a person to give up  
               their rights to have violations of their civil rights case  
               heard in court as a condition of a contract for employment,  
               housing or education or goods and services is involuntary  
               and coercive. 

               Illustrative of the problem is the case of the high school  
               student who received death threats from classmates. On the  
               advice of law enforcement, he withdrew from the private  
               school and moved to another part of the state. His parents  
               decided to hold the school accountable for inaction on  
               disciplining the perpetrators and for revealing the  
               student's new school. Like any victim of hate crimes and  
               violation of civil rights, he deserved his day in court,  
               yet was denied because of a mandatory arbitration clause in  
               the enrollment contract.

               There is no right without a remedy and the remedy for  
               violations in these cases is best adjudicated under the  
               state's civil rights statutes and enforced by the courts.  
               Mandatory arbitration preemptively forces victims to submit  
               to arbitration proceedings conducted behind closed doors  
               where arbitrators are not required to adhere to the state's  
               civil rights statutes or existing case law, yet their  








                                                                  AB 2617
                                                                  Page 6

               decisions are still binding and enforced by the courts. 

               AB 2617 is about choice: when a dispute arises - or even  
               before - this bill leaves the option open to go to court or  
               to go to arbitration as long as both parties voluntarily  
               agree and it is not imposed as a condition of a contract.  
               When a person is given no choice but to waive his or her  
               rights for legal redress under the state's civil rights  
               statutes in order to get a job, a home or essential  
               services, the effectiveness of civil rights protections is  
               seriously undermined.

           This Bill Responds To A Controversial Appeals Court Decision In  
          A Hate Crimes Case Against A Student Wrongly Perceived To Be  
          Gay.   The impetus for the bill is the controversy arising out of  
          a recent incident involving alleged threats of violence against  
          a young man identified by his initials, "D.C.," who was a  
          student at Harvard-Westlake School, a private educational  
          institution in Los Angeles.  With his parents, D.C. attempted to  
          sue Harvard-Westlake and others under the hate crimes law.  

          According to the facts recited in the court opinion, several  
          students at Harvard-Westlake, using its computers, went to  
          D.C.'s web site and posted death threats against D.C. and made  
          derogatory comments about him.  One post read, "I'm going to  
          pound your head in with an ice pick."  Another said, "Faggot,  
          I'm going to kill you."  A third stated, "You are an oversized  
          faggot ... .  I just want to hit you in the neck--hard. ... [  
          G]o to the 405 [freeway] bridge and jump."  A fourth read, "I  
          hate fags ... .  You  need to be stopped."  One student wrote,  
          "I am looking forward to your death."  Another commented, "Not  
          only are you a massive fagmo, but must absolutely quit showing  
          your face at my school.  You are now officially wanted dead or  
          alive."  One post read, "I want to rip out your fuc@ing heart  
          and feed it to you."  Several other posts couched threats with  
          references to D.C.'s misperceived sexual orientation as a  
          homosexual.  The students who posted the threats sought to  
          destroy D.C.'s life, threatened to murder him, and wanted to  
          drive him out of Harvard-Westlake and the community in which he  
          lived. 

          The school newspaper, The Chronicle, ran more than one article  
          on the matter.  When D.C.'s father read the threats at the Web  
          site, he immediately informed Harvard-Westlake of the problem,  
          believing that some of its students were responsible.  The  








                                                                  AB 2617
                                                                  Page 7

          father also contacted the Los Angeles Police Department, which,  
          in turn, notified the Federal Bureau of Investigation.  On the  
          advice of the police, D.C. withdrew from Harvard-Westlake.  He  
          and his family moved to another part of California, where he  
          went to a different educational institution.  The Chronicle ran  
          an article disclosing D.C.'s new residential location and the  
          name of the school he was attending.  The article also disclosed  
          that postings at the Web site had referred to D.C. as a  
          "faggot."  The faculty advisor to the staff of The Chronicle  
          approved the article before publication.  Harvard-Westlake did  
          not suspend or expel any of the students who admitted posting  
          the threats.

          In response to the suit by D.C. and his parents, the school  
          filed a petition to compel arbitration of all claims.  The  
          petition was based on the contents of Harvard-Westlake's  
          "Enrollment Contract," signed by D.C.'s father.  The Enrollment  
          Contract consisted of five pages.  One provision stated, "I  
          recognize that alteration of any wording in this Agreement will  
          nullify this offer of enrollment."  Under "TERMS AND  
          CONDITIONS," the contract contained an arbitration provision,  
          stating: "I understand that any legal and actionable controversy  
          or claim arising out of or relating to this Agreement (including  
          but not limited to the determination of the scope and  
          applicability of this Agreement to arbitrate), the student's  
          enrollment in/departure from Harvard-Westlake or the student's  
          educational experience at Harvard-Westlake (including, but not  
          limited to academic matters and extracurricular activities and  
          community service) shall be submitted to final and binding  
          arbitration to be held in Los Angeles County, California, before  
          a single, neutral arbitrator in accordance with JAMS'  
          Comprehensive Arbitration Rules and Procedures.  This  
          arbitration agreement applies during the term of this enrollment  
          agreement and survives after the termination of the enrollment  
          agreement."  Also under "TERMS AND CONDITIONS" was an attorney's  
          fees provision, stating: "In the event of any arbitration or  
          litigation between the parties arising out of this agreement, or  
          which relates in any way to the enrollment of the student at  
          Harvard-Westlake, the prevailing party therein shall be allowed  
          all reasonable attorneys' fees expended or incurred in such  
          arbitration or litigation, to be recovered as part of the costs  
          therein."

          The trial court granted the petition to compel arbitration, the  
          case went to a private arbitrator retained by JAMS as specified  








                                                                  AB 2617
                                                                  Page 8

          in the enrollment contract, the arbitrator found for the school  
          on all counts, and the arbitrator ordered the parents to pay the  
          school over half a million dollars in attorney's fees and  
          arbitration costs.  The school then filed a petition to confirm  
          the arbitrator's award - in essence, to convert it from a  
          private agreement into a court order.  The court upheld the  
          order to arbitrate and confirmed the arbitrator's award in favor  
          of the school, although the award of money to the school was  
          reversed by the court.

           Private Arbitration Is Essentially Unregulated And Highly  
          Controversial When It Is Mandatory, Rather Than Voluntary  .  As  
          supporters of this bill contend, and this Committee has  
          frequently discussed in recent years, private arbitration is a  
          mostly anything-goes private justice industry which can be  
          costly and is allegedly unreceptive to consumers.  There is  
          little if any regulation, oversight or legal accountability to  
          the parties or the public.  

          Surprisingly to some, arbitrators are not regulated in any  
          fashion; they need not be trained in the law, or even apply the  
          law in a particular dispute, or render a decision consistent  
          with the evidence presented to them.  What evidence is presented  
          may, in fact, be incomplete because parties in arbitration have  
          no legal right to obtain evidence in support of their claims or  
          defenses, or the claims or defenses of the other party, contrary  
          to the longstanding discovery practice in public courts.   
          Indeed, unlike judges, arbitrators need not explain or defend  
          the rationale for their decisions.  There is no need to justify  
          his or her decision because the law and the evidence need not be  
          followed and because there is no right for any party to appeal  
          or obtain an independent review of the arbitrator's ruling  
          unless the contract expressly so provides.  Regardless of the  
          level or type of mistake, or even misconduct, by the arbitrator,  
          the most relief a court may grant to a party in arbitration is  
          to vacate the award and return the parties to further  
          arbitration, perhaps with the same arbitrator or arbitration  
          company.  The grounds on which an arbitrator's decision may be  
          vacated, however, are extremely narrow and the standards for  
          vacatur are stringent.  Neither may the parties generally obtain  
          any remedy against the arbitrator for misconduct because  
          arbitrators are afforded substantial if not absolute immunity  
          from civil liability for acts relating to their decisions, even  
          in the case of bias, fraud, corruption or other violation of  
          law.  








                                                                  AB 2617
                                                                  Page 9


          Arbitration's dramatic differences from the public justice  
          system are believed to be appropriate where parties with  
          relatively equal bargaining power have voluntarily chosen to  
          have their dispute and legal rights resolved by a method other  
          than the courts.  For example, the use of binding arbitration  
          has a long and honored history in the resolution of  
          labor-management disputes where both parties are repeat-players  
          to whom arbitrators must be equally accountable in order to  
          enjoy repeat employment.  By the same token, parties to a  
          contract might choose to simply flip a coin to resolve their  
          disputes, and public policy may favor holding them to that  
          bargain.  Private arbitration becomes more controversial,  
          however, when it is imposed by more powerful parties without  
          negotiation or the right to withhold consent to unfair terms.

           The Revenue Incentives Of Private Arbitration Have Caused  
          Concerns About The Advantages Enjoyed By "Repeat-Players" And  
          The Disadvantages For Consumers  .  As this Committee has also  
          frequently discussed, not only is private arbitration  
          effectively unregulated, it has caused concerns because it is a  
          revenue-driven system where, critics contend, "repeat players"  
          have unfair advantages when they are involved in mandatory  
          arbitration against "one-shot" users, such as individual  
          consumers.  

          The favorable reputation arbitration has long enjoyed largely  
          grows out of its use in the resolution of labor disputes in the  
          first part of the 20th Century.  In the labor-management  
          context, where the parties mutually choose the arbitrator from  
          among a small group of specialists, the arbitrator has an  
          incentive to be perceived as fair by both sides over the long  
          term.  By contrast, critics contend, arbitrators have far less  
          incentive to be fair to both sides when they owe their  
          engagement (and future work) to the business that pre-selected  
          the arbitration company in the contract and who will repeatedly  
          appear before them, unlike the consumer party who did not choose  
          the arbitration company and is not likely to be the source of  
          future work for the arbitrator.  This reluctance to offend the  
          source of repeat business may be particularly true where the  
          dispute involves stigmatizing allegations, such as the  
          hate-crimes charges at issue in this bill.

           Is Mandatory Arbitration Appropriate For The Enforcement Of  
          Civil Rights Laws And Particularly Those Predicated On Access To  








                                                                 AB 2617
                                                                          Page 10

          The Courts?   Supporters of this bill contend that hate crimes  
          laws are fundamentally different from the type of commercial  
          disputes that may be appropriate for private arbitration.  Nor  
          do hate crimes appear to generate concerns about "abusive  
          litigation" that have caused some business groups to defend the  
          imposition of mandatory arbitration provisions in consumer  
          contracts.

          While a party is free to waive the advantage of a law intended  
          solely for his or her benefit, a law established for a public  
          reason cannot be waived by private agreement.  (Civil Code  
          section 3513.)  Both the Ralph Act and the Bane Act provide for  
          enforcement by the Attorney General and other public  
          prosecutors, as well as the Department of Fair Employment and  
          Housing (DFEH), in addition to private rights of action for both  
          equitable relief, civil penalties and damages - reflecting their  
          intent not only to vindicate individual rights, but to provide a  
          mechanism to redress the harms hate-based violence causes to the  
          larger community.  The creation of civil causes of action was at  
          the heart of both of these civil rights acts.  (Stamps v.  
          Superior Court, 136 Cal. App. 4th 1441 (2006).)  

          The court in DC v Harvard-Westlake recognized the fundamental  
          public nature of the hate crimes statutes in holding that the  
          rights they establish should not be subject to waiver by private  
          contracts.  However, the court disregarded the effect of the  
          arbitration clause by failing to acknowledge that it required  
          the waiver of the right to have the allegations resolved by the  
          court system, with public judges and juries and all of the other  
          values established by that system for the guarantee of fairness  
          and due process and the protection and prosecution of civil  
          rights, including the right to appeal.  In other words,  
          requiring a party to allow a private arbitrator to decide hate  
          crimes violations is, inherently, a waiver of rights and  
          procedures provided by the statutes.

          Moreover, by mandating the arbitration of any issue involving  
          the parties, such as the contract clause in the DC case, private  
          arbitration may block not only individual access to the courts  
          but also public prosecution by the Attorney General or other  
          prosecutors or a complaint to the DFEH.  (See Sonic-Calabasas A,  
          Inc. v. Moreno, 174 Cal. App. 4th 546 (2009), rev. granted, 99  
          Cal. Rptr. 3d 866 (2009)(private arbitration clause precluded  
          employee from making use of the enforcement mechanism of the  
          state Labor Commissioner for redress of alleged labor law  








                                                                  AB 2617
                                                                  Page 11

          violation).)

           Is Mandatory Arbitration Particularly Inappropriate Where  
          Temporary And Other Equitable Relief Is Fundamental To The  
          Statutory Scheme?  Moreover, a fundamental feature of the hate  
          crimes enforcement scheme is that immediate protective and/or  
          restraining orders may often be needed to prevent further abuse.  
           Even if an arbitrator were to believe that immediate  
          intervention was necessary, private arbitration does not allow  
          for such orders.  For an arbitrator's order to be legally  
          enforceable, it must be confirmed by a court judgment - a time  
          consuming process that does not lend itself to immediate  
          injunctive relief.  
               
           Is This Bill Carefully Crafted to Avoid Federal Pre-Emption  
          Questions?   As with other measures that have sought to prohibit  
          a business from conditioning benefits or services on a waiver of  
          statutory rights, this bill is opposed on the ground that it is  
          assertedly preempted by the Federal Arbitration Act (FAA)  
          because it conflicts with the FAA's policy of encouraging  
          arbitration and disapproving special impediments to the  
          enforcement of arbitration contracts.  Proponents respond that  
          the bill as proposed to be amended is not arbitration-specific  
          because it applies to any waiver of legal rights or procedures  
          under the hate crimes statutes, regardless of how that waiver is  
          effected.  Moreover, supporters note, the bill does not  
          single-out arbitration or other waiver agreements for special  
          encumbrances, but simply recognizes the application of a general  
          contract law principle of unconscionability, just as courts  
          routinely apply this same principle to invalidate some  
          arbitration or other waiver agreements.  In addition, supporters  
          argue, this bill does not bar arbitration or other waiver  
          agreements; it simply makes it unlawful to seek an unknowing and  
          involuntary waiver of rights or procedures regarding abuse laws  
          prior to a dispute arising.  Proponents point out that there is  
          no state or federal policy favoring involuntary waiver or  
          arbitration agreements.  If this bill is pre-empted, it would  
          seem that the FAA would logically also then pre-empt courts from  
          applying unconscionability principles to any arbitration or  
          other waiver agreement.  No court decision has been brought to  
          the attention of the Committee or discovered in the Committee's  
          own research lending support to such a far-reaching view of FAA  
          pre-emption.

           ARGUMENTS IN OPPOSITION:   A coalition of business interests  








                                                                  AB 2617
                                                                  Page 12

          argues against the bill, based on a perception that the bill  
          would outlaw arbitration agreements, contending as follows:

               The Federal Arbitration Act (FAA) and the California  
               Arbitration Act (CAA) evidence a strong preference for  
               enforcement of arbitration agreements, so long as the  
               underlying contract is fair.  The FAA generally prohibits  
               state laws that restrict enforcement of arbitration  
               agreements. [Citations omitted.] Despite consistent  
               authority from both the United States Supreme Court and  
               California Supreme Court regarding the inclination to  
               promote arbitration and limit any statutes or common law  
               that interfere with arbitration, AB 2617 seeks to do just  
               that.  Specifically, AB 2617 prohibits any contract that  
               requires a waiver of the right to pursue a civil action for  
               the violation of any alleged civil rights under the Civil  
               Code or Fair Employment and Housing Act.  Given that all  
               valid arbitration agreements for goods and services require  
               both parties to waive their rights to pursue a civil  
               action, AB 2617 directly interferes with the FAA and CAA.

               Although both federal and California courts certainly  
               recognize the benefits of arbitration and seek to enforce  
               arbitration agreements where appropriate, the courts in  
               California have imposed certain safety requirements that  
               such agreements must include in order to be enforceable.   
               For example, in Armanderiz v. Foundation Health Psychcare  
               Services, Inc. the California Supreme Court held that, for  
               employment arbitration agreements that encompass unwaivable  
               statutory rights, the following protections must be  
               included:  (1) provide for a neutral arbitrator; (2) no  
               limitation of remedies; (3) adequate opportunity to conduct  
               discovery; (4) written arbitration award and judicial  
               review of the award; and, (5) no requirement for the  
               employee to pay unreasonable costs  that they would not  
               incur in litigation or arbitration fees.  

               Recently, in Wherry v. Award, Inc., a court deemed an  
               independent contractor arbitration agreement unconscionable  
               where it expanded the right to attorney's fees for FEHA  
               violations to the company, and reduced the time to file a  
               FEHA claim from one year to 180 days.  See also Ajamian v.  
               CantorCO2e, L.P., 203 Cal.App.4th 771 (2012) (denying  
               arbitration where terms that required California  
               independent contractor to pay upfront costs, arbitrate in  








                                                                  AB 2617
                                                                  Page 13

               New York, and waived statutory rights was substantively  
               unconscionable); and Trivedi v. Curexo Technology Corp.,  
               189 Cal.App.4th 387 (2010) (refusing to enforce arbitration  
               agreement that provided a prevailing party attorney's fee  
               award without imposing limitation of recovery under FEHA).

               Given the protections courts have imposed in arbitration,  
               there is existing evidence that proves arbitration is  
               equally effective and more efficient than the judiciary  
               system to resolve claims.  According to the U.S. District  
               Court Judicial Caseload Profiler, there were 278,442 civil  
               cases filed in 2012, which was approximately three percent  
               lower than the previous year.   Over thirty thousand of  
               those cases were filed in California.  As of September  
               2012, California had over 25,000 civil cases pending,  
               approximately 8,000 of which have been pending for over a  
               year.  Of those 8,000 cases, approximately 2,000 of them  
               have been pending for over three years.  

               Comparatively, in 2007 the American Arbitration Association  
               produced a study titled "AAA Arbitration Roadmap" that  
               provided the following statistics:  for cases involving a  
               claim of up to $75,000, the median time for a final  
               resolution was 175 days; for claims between $75,000 and  
               $499,999, the median time for final resolution was 297  
               days; and, for claims between $500,000 and $999,999, the  
               median time for final resolution was 356 days.  Similarly,  
               a 2004 report issued by the California Dispute Resolution  
               Institute found that the average arbitration from the date  
               of filing until the date of resolution was 116 days.  Also,  
               a 2003 article in the New York University School of Law  
               legal journal authored by Theodore Eisenberg and Elizabeth  
               Hill regarding employment arbitration found that  
               arbitration was resolved within a year, while litigation  
               usually lasted over two years.  

               Not only is arbitration more efficient, but also it is less  
               costly for employers/businesses, as well as financially  
               beneficial to consumers/employees.  A 2006 study by Mark  
               Fellows, Legal Counsel at the National Arbitration Forum,  
               titled "The Same Result as in Court, More Efficiently:   
               Comparing Arbitration and Court Litigation Outcomes,"  
               concluded that consumers and employees actually fare better  
               in arbitration than in court.  Fellows specifically  
               analyzed data from California and found that consumers  








                                                                  AB 2617
                                                                  Page 14

               prevail in arbitration 65.5% of the time, as compared to  
               61% of the time in court.  Additionally, California  
               businesses paid an average of $149.50 in arbitration fees  
               whereas consumers only paid an average of $46.63.  A recent  
               report in July 2013 published by the Heritage Foundation  
               titled "The Unfair Attack on Arbitration:  Harming  
               Consumers by Eliminating a Proven Dispute Resolution  
               System," supported these findings by Fellows, concluding  
               that "[a]rbitration is generally faster, cheaper, and more  
               effective than the litigation system. It is not affected by  
               cutbacks in judicial budgets or the increases in court  
               dockets that significantly delay justice."  

               In addition to prohibiting arbitration agreements, AB 2617  
               also appears to ban pre-litigation settlement agreements as  
               well.  Specifically, section 51.7(b)(7) of the bill states  
               that the provisions of AB 2617 do not apply "after a legal  
               claim has arisen."  To the extent this section refers to  
               claims that have actually been filed in civil court, AB  
               2617 would restrict pre-litigation settlement agreements as  
               well.  There are certainly numerous situations where two  
               parties are able to come to a resolution regarding a  
               dispute before litigation is filed.  AB 2617 would remove  
               this opportunity and force the parties to actually file a  
               claim in civil court before they could proceed with a  
               settlement agreement that include a waiver of all claims.  
                 
          Author's Technical Amendments.   To address technical drafting  
          issues, the author proposes the following amendments:  
                                           
          On page 2, in line 26, strike out "No" and insert:    A
                                          
          On page 2, in line 26, after "shall" insert:     Not

          On page 3, in line 7, strike out "No" and insert:     A

          On page 3, in line 7, after "shall" insert:    not

          On page 4, in line 14, after "1668" insert:      , 1953,
           
          REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          American Civil Liberties Union








                                                                  AB 2617
                                                                  Page 15

          California Civil Rights Coalition
          Consumer Attorneys of California
          Equality California 
          NAACP - California State Conference

           Opposition 
           
          California Chamber of Commerce
          Acclamation Insurance Management Services
          Allied Managed Care
          California Apartment Association
          California Association of Health Facilities 
          California Bankers Association 
          California Chapter of American Fence Association
          California Employment Law Council
          California Farm Bureau Federation 
          California Fence Contractor's Association
          California Grocers Association 
          California Hospital Association
          California Manufacturers and Technology Association 
          California New Car Dealers Association
          California Restaurant Association 
          California Retailers Association 
          Civil Justice Association of California 
          Coalition of Small and Disabled Veteran Business
          Cooperative of American Physicians
          Flasher Barricade Association
          Marin Builders Association 
          National Federation of Independent Business
          Southwest California Legislative Council
          Western Growers Association
           
          Analysis Prepared by  :  Kevin G. Baker / JUD. / (916) 319-2334