Author Archives: BraniganRobertson

Hospital Employee Whistleblower Laws – Health & Safety Code § 1278.5

Employees, nurses, and medical staff who work at hospitals and health care centers frequently witness horrific patient treatment at the hands of doctors and negligent medical staff. They want to report the abusers to the government, but they don’t want to become a whistleblower. They don’t want to be retaliated against. These folks are also hesitant to call an employment lawyer or attorney to get basic guidance. Fortunately, Health & Safety Code 1278.5 was enacted to protect such health care workers. You will have to call a lawyer, but it will be worth it to protect your rights.

This is a law that every hospital worker, nurse, or physician’s assistant should know: Health & Safety Code 1278.5 states:

(a) The Legislature finds and declares that it is the public policy of the State of California to encourage patients, nurses, members of the medical staff, and other health care workers to notify government entities of suspected unsafe patient care and conditions. The Legislature encourages this reporting in order to protect patients and in order to assist those accreditation and government entities charged with ensuring that health care is safe.

The Legislature finds and declares that whistleblower protections apply primarily to issues relating to the care, services, and conditions of a facility and are not intended to conflict with existing provisions in state and federal law relating to employee and employer relations.

(b) (1) No health facility shall discriminate or retaliate, in any manner, against any patient, employee, member of the medical staff, or any other health care worker of the health facility because that person has done either of the following:

(A) Presented a grievance, complaint, or report to the facility, to an entity or agency responsible for accrediting or evaluating the facility, or the medical staff of the facility, or to any other governmental entity.

(B) Has initiated, participated, or cooperated in an investigation or administrative proceeding related to, the quality of care, services, or conditions at the facility that is carried out by an entity or agency responsible for accrediting or evaluating the facility or its medical staff, or governmental entity.

(2) No entity that owns or operates a health facility, or which owns or operates any other health facility, shall discriminate or retaliate against any person because that person has taken any actions pursuant to this subdivision.

(3) A violation of this section shall be subject to a civil penalty of not more than twenty-five thousand dollars ($25,000). The civil penalty shall be assessed and recovered through the same administrative process set forth in Chapter 2.4 (commencing with Section 1417) for long-term health care facilities.

(c) Any type of discriminatory treatment of a patient by whom, or upon whose behalf, a grievance or complaint has been submitted, directly or indirectly, to a governmental entity or received by a health facility administrator within 180 days of the filing of the grievance or complaint, shall raise a rebuttable presumption that the action was taken by the health facility in retaliation for the filing of the grievance or complaint.

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New California Employment Laws

Laws You Should KnowEmployment attorney Branigan Robertson has reviewed recent legislative enactments coming out of California’s government. Here are the main laws that workers should know about:

  • AB 292 – Which codifies a law reversing Kelly v. Conco Companies (2011) 196 CA 4th 191, to clarify that sexual harassment does not have to be motivated by sexual desire. Governor Brown signed this measure. This is especially important in same-sex sexual harassment cases where there is no evidence that the harasser actually desires to engage in sexual activities with the victim.
  • SB 655 – Addresses Harris v. City of Santa Monica (2013) 56 Cal4th 203, by defining a “substantial motivating factor” for purposes of discrimination or retaliation claims and providing an additional remedy, a statutory penalty up to $25,000, for an employee in a mixed motive case.
  • SB 770 – Expands California’s Paid Family Leave program to include time off to care for a seriously ill grandparent, grandchild, sibling, or parent-in-law.
  • SB 462 – Fixes Labor Code § 218.5’s fee shifting provision by requiring a showing of bad faith in order for an employer to recover attorneys’ fees in a wage claim action. Governor Brown signed this measure.
  • AB 10 – Raises the minimum wage in California from $8.00 per hour to $10.00 per hour. AB 10 will raise California’s minimum wage in two one-dollar increments, from $8 per hour today to $9 per hour, effective July 1, 2014 and from $9 per hour to $10 per hour, effective January 1, 2016.

These are fantastic laws that will dramatically help employees vindicate their rights in California when employers treat them poorly.

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Filed under FEHA, Harassment, Wage & Hour

Money Problem for California’s Courts Continues

Unfortunately, California courts are in a budget crisis. The largest court system in the Country will not share in any of the new revenue in Gov. Jerry Brown’s revised budget plan. Read the article here.

 

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California Companies Must Pay Vacation Pay If They Have A Vacation Policy

Laws You Should Know – Labor Code § 227 – Branigan Robertson is a California employment lawyer who focuses his practice on wage and hour issues and wrongful termination. Call for a free consultation with one of our lawyers.

Many employees call our firm wondering about vacation pay. What do California’s employment laws have to say concerning vacation pay? If your company offers it, do they have to pay it? If you get fired and you have accrued vacation pay, does the company have to pay it in your final paycheck?

Employment Attorney & Vacation Pay

Labor Code § 227 makes it unlawful for an employer to fail to pay its employees vacation pay when it has agreed with its employees to pay accrued vacation. § 227 states:

Whenever an employer has agreed with any employee to make payments to a … vacation plan … it shall be unlawful for that employer willfully or with intent to defraud to fail to make the payments required by the terms of that agreement. A violation of any provision of this section where the amount the employer failed to pay into the fund or funds exceeds five hundred dollars ($500) shall be punishable by imprisonment pursuant to subdivision (h) of Section 1170 of the Penal Code, or in a county jail for a period of not more than one year, by a fine of not more than one thousand dollars ($1,000), or by both that imprisonment and fine. All other violations shall be punishable as a misdemeanor.

Yikes. That is a serious statute (at least as far as employment law goes).

Vacation Pay Considered Wages

Under California law, earned vacation time is considered wages; and under Labor Code § 227.3 whenever an employment relationship ends for any reason whatsoever and the employee has not used all of his or her earned and accrued vacation, the employer must pay the employee at his or her final rate of pay for all such earned, accrued and unused vacation.

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Companies Must Reimburse the Necessary Business Expenses of Employees

Laws You Should Know – Labor Code § 2802 – Branigan Robertson is a CA employment attorney who focuses his practice on wage and hour issues and wrongful termination. Call for a free consultation with one of our lawyers.

There are many laws out there that employees should know. This is one of the major ones that employees should be armed with so their employers don’t take advantage of them. A company must reimburse employees for necessary business expenditures. Here is our main page on unreimbursed expenses.

Reimburse Necessary Business Expenses

§ 2802 states:

(a) An employer shall indemnify his or her employee for all necessary expenditures or losses incurred by the employee in direct consequence of the discharge of his or her duties, or of his or her obedience to the directions of the employer, even though unlawful, unless the employee, at the time of obeying the directions, believed them to be unlawful.

(b) All awards made by a court or by the Division of Labor Standards Enforcement for reimbursement of necessary expenditures under this section shall carry interest at the same rate as judgments in civil actions. Interest shall accrue from the date on which the employee incurred the necessary expenditure or loss.

(c) For purposes of this section, the term “necessary expenditures or losses” shall include all reasonable costs, including, but not limited to, attorney’s fees incurred by the employee enforcing the rights granted by this section.

Labor Code § 2802 Examples

What are some good examples of necessary business expenses?

  • Mileage
  • Supplies: such as paper, tools, pens & pencils, tape
  • Parking fees
  • Software & hardware
  • Protective equipment
  • Attorneys fees (if you are sued for issues relating to work your employer must indemnify you)

 

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New Case Law: Ventura v. ABM Industries

Attorney Case Law Update: Ventura v. ABM Industries – California Second District Appellate Court. Branigan Robertson is an employment lawyer who focuses his practice on harassmentretaliation, and wrongful termination.

Facts of the Case

This case was brought by Sylvia Ventura. Within a few weeks of becoming Ventura’s supervisor, Carlos Manzano began flirting with her and telling her that she was pretty and that he was in love with her, advances which Ventura turned down. Once, when Ventura was cleaning an office, Manzano pulled her arm, pushed her against a wall, and told her that he liked her, and to pay attention to him. Another time, in an elevator, he asked her to kiss him, and leaned in very close. Ventura’s cleaning cart blocked him from kissing her.

Ventura did not complain about Manzano because she did not think she would be believed, but might be disciplined. She testified that she had seen this happen to other workers. Ventura did not complain about Manzano because she did not think she would be believed, but might be disciplined. She testified that she had seen this happen to other workers.

On August 22, 2005, she again saw Manzano drinking at work. While she was cleaning, he left her several voicemails, suggesting in one of them that she “had had a good time” with her husband the day before. Later that day, while Ventura was cleaning the handicapped stall in one of the men’s bathrooms, Manzano entered the bathroom and closed the door. He grabbed her arms from behind, squeezed her, and started rubbing his parts on her buttocks. She tried to shout, but he had his arm across her neck so tightly that she couldn’t breathe. His fingers left marks on her. He also bit her.

Ventura managed to break free. She hid in an office, under a desk, until she felt safe. She called a friend and also called area supervisor Martinez. She did not tell Martinez about the incident, but told him that Manzano and others were drinking in the janitor’s room and that he should come and see. He told her that he couldn’t do that right now.

She left the building, then returned, afraid that if she left, she would lose her job. She again called Martinez, this time telling him what had happened. He told her to give Manzano her keys and tell him that she was leaving because she couldn’t bear it any longer. He also told her to come to the office the next day to prepare a statement. Ventura said that she was going to call the police. Martinez told her not to, because company ethics did not allow it. (Ventura did go to the police, who documented bruises.)

Ventura called Manzano and told him that she was leaving and that he had to pick up her keys, and that she had called Martinez. Manzano came downstairs. Ventura threw the keys at him and took off running to her car. He followed, calling her name, and saying “oh, we’re going to file a lawsuit, right?” and telling her that he was a very vengeful person. She got into her car. Manzano held the door so that she could not close it, and reached in and banged on the steering wheel, swearing at her and telling her that he loved her. She put the car in reverse, and he let go.

Labor Code § 51.7

California Civil Code § 51.7 states, “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” their “sex, race, color, religion, ancestry, national origin, disability, medical condition, genetic information, marital status, or sexual orientation….”

Defendants next argue that section 51.7’s reference to threats or violence because of a person’s sex logically means that the offending act must be based on hate. They further argued that there was no evidence of hate here, because Manzano told Ventura that he loved her. The Court found that hate is not an element, though it also added that even if it was, we would reject defendants’ argument that Manzano’s protestations of love mean that there was no evidence of hate. The evidence was that Manzano ‘loved’ Ventura enough to attack her and hurt her.

Ventura won her case and was awarded $125,000. Her attorneys applied for their fees and the Court awarded $550,000 in fees.

At the end of the day it was a good result for a client who was in need.

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New Case Law: Harris v. City of Santa Monica

Attorney Case Law Update: Harris v. City of Santa Monica – California Supreme Court. Branigan Robertson is a work lawyer who focuses his practice on pregnancy discrimination, discrimination, and wrongful termination.

Case Facts – Employment Attorney

A bus driver alleged that she was fired by the City of Santa Monica because of her pregnancy in violation of the prohibition on sex discrimination in the Fair Employment and Housing Act (FEHA). When Harris told her boss that she was pregnant, he seemed to react negatively and soon thereafter she was fired. The City claimed that she had been fired for poor job performance. Harris was in a few minor car accidents while on the job and had been late to work a few times.

Attorney Case Analysis

The City argued that the trial court should have instructed the jury with the following: “If you find that the employer‘s action . . . was actually motivated by both discriminatory and non-discriminatory reasons, the employer is not liable if it can establish by a preponderance of the evidence that its legitimate reason, standing alone, would have induced it to make the same decision.” Thus, the City did not object to the burden-shifting aspect of Price Waterhouse. Its primary contention is that the Court should follow Price Waterhouse not only with respect to burden shifting, but also with respect to the legal effect of an employer‘s same-decision showing.

The CA Supreme Court held that under the FEHA, when a jury finds that unlawful discrimination was a substantial factor motivating a termination of employment, and when the employer proves it would have made the same decision absent such discrimination, a court may not award damages, backpay, or an order of reinstatement. But the employer does not escape liability. In light of the FEHA‘s express purpose of not only redressing but also preventing and deterring unlawful discrimination in the workplace, the plaintiff in this circumstance could still be awarded, where appropriate, declaratory relief or injunctive relief to stop discriminatory practices. In addition, the plaintiff may be eligible for reasonable attorney‘s fees and costs.

There are additional holdings of the case that are important. For example, the Court held that the plaintiff does not need to introduce direct evidence of discrimination in a ‘mixed motive’ case such as this. The plaintiff can get by with circumstantial evidence. The defendant must also plead the ‘mixed motive’ defense in its initial answer. It cannot claim mixed motive at trial if it hasn’t fought for it from the beginning. Finally, the defendant must prove it actually would have taken the same action at the same time even if it had not considered the prohibited trait. This is a big deal because the defendant is going to be hard pressed to show this in most discrimination cases.

This case causes problems for many plaintiffs, but it did not turn out as bad as plaintiff lawyers across California had feared. Basically the defendant will try even harder to come up with multiple non-discriminatory reasons why they fired plaintiff. The plaintiff attorneys will have to argue tooth and nail that such reasons would not have led to the firing at the time they made the decision without the discriminatory motive as well. When all the dust settles, I believe this case will work out well for victims of discrimination.

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