Legislature Expands What Community Colleges Can Charge for Use of Their Facilities

October 2014
Number 81

Until recently, community college districts have not been permitted to charge organizations a share of the costs associated with maintenance and normal “wear and tear” incurred during the use of college facilities and grounds under the Civic Center Act. However, on August 21, 2014, Governor Brown signed into law Assembly Bill (AB) 1906, expanding the types of “direct costs” that community college districts may charge for the use of college facilities or grounds. Effective January 1, 2015, AB 1906 aligns the direct costs that community college districts may charge with those that K-12 districts may now charge as a result of the enactment of Senate Bill (SB) 1404 in September 2012.

The Civic Center Act (Act) (Ed. Code § 82537, et seq.) provides that a community college district must permit the use of college facilities or grounds by nonprofit organizations, clubs, and associations organized for general character building or welfare purposes, when an alternative location is not available. The Act also authorizes a community college district’s governing board to charge a fee, which may not exceed the district’s direct costs, for the use of college facilities and grounds. Under existing law, these direct costs include a share of the costs of supplies, utilities, janitorial services, and community college district services and salaries necessary for the organization’s use of the facilities or grounds.

In amending Education Code section 84542, the Legislature recognized that maintenance costs often exceed the operational costs connected with an organization’s use of college facilities and grounds. Accordingly, AB 1906 expands the types of direct costs that community college districts may charge to include a share of the costs for maintenance, repair, restoration, and refurbishment, proportionate to an organization’s use of college facilities and grounds.

Of note, newly amended section 84542 limits a user’s proportionate share of maintenance, repair, restoration and refurbishment to costs associated with the use of non-classroom space and “grounds,” including but not limited to, playing fields, athletic fields, track and field venues, tennis courts and outdoor basketball courts, Also, classroom-based programs that operate after school hours, including tutoring and child-care programs, and instructional organizations retained by the college or community college district will not be required to bear a share of the costs for maintenance, repair, restoration and refurbishment.

Amended section 84542 requires the Chancellor of the California Community Colleges to develop, and the Governors of the Community Colleges to adopt, implementing regulations by December 31, 2015 to guide community college districts in determining the proportionate share and allowable costs that may be included as direct costs for using college facilities and grounds. On the K-12 side, regulations were slow to be developed, but were finally adopted as of July, 2014. (See Client News Brief No. 33, July 2014.) Since AB 1906 mirrors SB 1404 so closely, the K-12 regulations (Cal. Code Regs., tit. 5, § 14037 et seq.) may offer community college districts some preliminary guidance on how they may be allowed to calculate direct costs in the future.

Amended section 84542 will sunset on January 1, 2020, unless a later statute deletes or extends that date.

If you have any questions regarding AB 1906, or other issues related to the Civic Center Act, please contact one of our eight offices located statewide. You can also visit our website, follow us on Facebook or Twitter, or download our Client News Brief App.

Written By

Devon B. Lincoln
Partner
Monterey Office
dlincoln@lozanosmith.com

Claudia P. Weaver
Senior Counsel
Monterey Office
cweaver@lozanosmith.com

©2014 Lozano Smith

As the information contained herein is necessarily general, its application to a particular set of facts and circumstances may vary. For this reason, this News Brief does not constitute legal advice. We recommend that you consult with your counsel prior to acting on the information contained herein.

New Laws Seek to Improve College Safety

October 2014
Number 80

The Governor recently signed three bills addressing campus or student safety at higher education institutions. Senate Bills (SB) 967, regarding sexual assault, and 1400, regarding keeping students who are subject to protective orders out of classes, take effect January 1, 2015. Assembly Bill (AB) 1433, regarding reporting of crimes, took effect immediately upon the Governor’s September 29, 2014 signature. Together, the three bills signal heightened attention to issues of student safety at California’s colleges.

SB 967: Student Safety – Sexual Assault

According to the authors of this bill, adjudication of sexual assault on college campuses is inconsistent and inadequate. This law, nicknamed the “Yes Means Yes” law, imposes new requirements on the governing bodies of California Community Colleges, the University of California, the California State University, and independent postsecondary institutions (collectively “Higher Education Institutions”). These entities must comply with the new requirements in order to receive state funds for student financial assistance.

The new law adds section 67386 to the Education Code and requires Higher Education Institutions to adopt a sexual assault, domestic violence, dating violence, and stalking policy, which is a condition of receiving state funds for student financial assistance, and includes specified standards regarding how allegations of sexual assault must be evaluated. Most notably, the policy must contain an “affirmative consent standard,” which is defined as an “affirmative, conscious, and voluntary agreement to engage in sexual activity.”

Higher Education Institutions must adopt “detailed and victim-centered policies and protocols,” as specified, which address how the institution will respond to reported sexual assault, domestic violence, dating violence, and stalking incidents. The new law also requires these entities to form alliances, to the extent feasible, with existing on-campus and community-based organizations (e.g. rape-crisis centers) in order to make services available to both victims and the accused. In addition, Higher Education Institutions must implement comprehensive prevention and outreach programs, which address sexual violence, domestic violence, dating violence, and stalking. Such programs shall be included in every incoming student’s orientation. Lastly, if the Commission on State Mandates concludes that the bill imposes mandated costs, Higher Education Institutions may be entitled to reimbursement for costs associated with implementing SB 967.

SB 1400: Community Colleges – Protective Orders

Under existing law, upon the expiration of a protective order that keeps a student out of class, a student can re-register at a community college without any review of whether the individual presents a continuing safety threat. SB 1400 amends Education Code section 76030 and provides that if a protective order was issued against a student for good cause to protect a campus or person regularly on a campus, the community college district may require the student to apply for reinstatement before the expiration of such order. If the student applies for reinstatement, a review of the application must consider, at a minimum, the gravity of the offense, evidence of subsequent offenses, and likelihood of substantial disruption if reinstated. Upon review, the governing board may approve, deny, or permit conditional reinstatement.

AB 1433: Student Safety

AB 1433 amends section 67380 and adds section 67383 to the Education Code and requires, as a condition for participation in the Cal Grant Program, the governing bodies of California Community Colleges, the University of California, the California State University, and private and independent postsecondary institutions with full time enrollment of more than 6,000 students to adopt written policies and procedures to ensure that reports of certain crimes be forwarded to law enforcement agencies. A report of willful homicide, forcible rape, robbery, assault, sexual assault, or hate crime made by the victims to campus security authority for purposes of notifying the institution or law enforcement must promptly be forwarded to the appropriate law enforcement agency. This requirement applies to crimes occurring both on and off campus. As noted above, these new requirements are already in effect as of September 29, 2014. This means that if the necessary written policies and procedures are not already in effect, they should be adopted as soon as possible.

The new law makes it clear that the report to the appropriate law enforcement agency shall be made without identifying the victim unless the victim, after being informed of his or her rights to have identifying information withheld, consents to being identified. The bill is intended to alleviate the problems of underreporting sexual assaults on campuses and mishandling cases, create a closer relationship between campuses and local law enforcement, improve investigations, outcomes for victims, and community safety.

If you have any questions regarding the implications of these new laws, or would like assistance in complying with the new requirements, including preparation of the necessary written policies, please contact one of our eight offices located statewide. You can also visit our website, follow us on Facebook or Twitter, or download our Client News Brief App.

Written By

Harold M. Freiman
Partner
Walnut Creek Office
hfreiman@lozanosmith.com

Maryn Oyoung
Associate
Petaluma Office
moyoung@lozanosmith.com

©2014 Lozano Smith

As the information contained herein is necessarily general, its application to a particular set of facts and circumstances may vary. For this reason, this News Brief does not constitute legal advice. We recommend that you consult with your counsel prior to acting on the information contained herein.

California Enacts Historic Sustainable Groundwater Management Act

October 2014
Number 79

For the first time in its history, California has passed comprehensive legislation providing for the sustainable management of the state’s groundwater resources. The several bills, Senate Bill (SB) 1168, SB 1319, and Assembly Bill (AB) 1739, collectively enacted the “Sustainable Groundwater Management Act” (Act). The goal of the Act is to achieve “sustainability” for California’s groundwater basins, which will now be regulated by local agencies.

A total of 127 groundwater basins will be required to comply with the Act, while the remaining basins may opt in to its provisions. The impacts and duties imposed by the Act on the autonomy of cities and on land management of school districts may be dramatic. Lozano Smith is assessing these impacts and is ready to assist local agencies in gaining the most control and benefit possible. Agencies that are water providers that have facilities or well systems will wait to pay close attention to these new laws.

Current Groundwater Regulation

California produces approximately 14 million acre-feet of groundwater each year, which provides for approximately 40% of California’s total water supply in normal years and as much as 60% in drought years. Some communities in California are 100% reliant on groundwater for their water supply. California’s groundwater resources are stored in naturally occurring geologic “basins,” which are separate and distinct geographical and hydrological formations.

Currently, California’s groundwater basins are managed in three general ways. Some counties and cities have adopted local ordinances regulating groundwater under their police powers. More commonly, courts have adjudicated groundwater rights for regional basins. Finally, some local agencies regulate groundwater by express statutory authority or through “groundwater management plans” adopted pursuant to AB 3030. AB 3030 plans are voluntary and provide for the planned use, storage space, transmission capability, and water storage for a basin.

However, no current law requires the reasonable management of these critical water storage resources and, as a result, groundwater management in California has been piecemeal. This has resulted in the overuse (overdraft) of some basins. Given the necessary role of water, the Legislature felt this hodge-podge of management could no longer be accepted.

The Sustainable Groundwater Management Act

The Act authorizes one or more local agencies overlying a groundwater basin that have water supply, water management, or land use responsibilities to become a “Groundwater Sustainability Agency” (GSA) for that basin. GSA’s are granted broad authority under the Act to adopt and enforce rules and regulations for management of groundwater resources, conduct investigations, impose fees and restrictions on groundwater extraction, and require registration and monitoring of groundwater wells among other powers.

Each GSA is authorized to adopt a “Groundwater Sustainability Plan” (GSP) that will guide the exercise of its powers and authorities under the Act. The basic elements of a GSP mirror closely the requirements for existing groundwater management plans adopted pursuant to AB 3030.

A GSP must include interim milestones in five year increments to achieve the adopted “sustainability goal” for the particular basin within twenty years of adoption of the GSP. The sustainability goal must achieve sustainable groundwater management by identifying and causing the implementation of measures that will ensure the basin is operated within its sustainable yield, including preventing the chronic lowering of groundwater levels, reductions in groundwater storage, as well as preventing seawater intrusion, degraded water quality, land subsidence, and surface water depletions.

A total of 127 high- and medium-priority basins, as designated by the Department of Water Resources in Bulletin 118, must be managed by a GSP. Bulletin 118 contains data and evaluations of all groundwater basins in the state. The GSA for the particular basin must be formed by July 1, 2017. For basins that are subject to critical conditions of overdraft pursuant to Bulletin 118, a GSP must be adopted by January 31, 2020. For all other high- and medium-priority basins, a GSP must be adopted by January 31, 2022. All other water basins in California may form a GSA and adopt a GSP, but are not required to do so.

The Department of Water Resources is authorized to revise Bulletin 118 for designation of groundwater basins. Therefore, the number of basins subject to the mandatory provisions of the Act may change in the future. If the deadlines for adoption of a GSP are not complied with, the State Water Resources Control Board has the authority to impose its own “interim” plan until an acceptable GSP is in place in accordance with the Act.

Effects on Local Agencies

Before July 1, 2017, local agencies in California with water supply, water management, or land use responsibilities must decide whether to be the GSA for their groundwater basin, either alone or in conjunction with other similar local agencies overlying the basin. If the local agency wishes to be the GSA, it must commence the procedures for doing so under the Act. Once the GSA is formed, it must adopt a GSP by the deadlines described above.

Effects on Groundwater Extractors

Individuals and entities that extract groundwater in a high- or medium-priority basin in California will be subject to the rules and regulations adopted by the GSA for their basin, including the “sustainability goal” set forth in the GSP, once formed and adopted. Given the goals and intent of the Act, it is likely that restrictions on the total amount of groundwater extracted and fees for groundwater extraction will be imposed. Other rules and regulations can be expected as well and will depend on the specifics of the particular groundwater basin in question. However, domestic users of less than 652,000 gallons of groundwater will not be required to comply with any reporting or monitoring requirements imposed by a GSA for their groundwater basin. Therefore, while most domestic users will be exempt from reporting and monitoring requirements, certain institutions, users, and local agencies will be impacted by the new laws.

Future State Action

Governor Jerry Brown stated in his signing statement for the legislation implementing the Act that he will propose legislation in the next session to streamline the process for judicial adjudication of groundwater rights in the state.

It is very important to develop a strategy early to best protect and benefit your agency as the Act is implemented. If you have any questions regarding the Act, please contact one of our eight offices located statewide. You can also visit our website, follow us on Facebook or Twitter, or download our Client News Brief App.

Written By

William P. Curley III
Senior Counsel
Los Angeles Office
wcurley@lozanosmith.com

Gary B. Bell
Associate
Fresno Office
gbell@lozanosmith.com

©2014 Lozano Smith

As the information contained herein is necessarily general, its application to a particular set of facts and circumstances may vary. For this reason, this News Brief does not constitute legal advice. We recommend that you consult with your counsel prior to acting on the information contained herein.

Student Privacy Issues and Technology Addressed in Three New Bills – UPDATED

October 2014
Number 78

Three new bills intended to protect students in cyberspace recently became law, including a bill that affects how educational agencies contract for technology services. These new laws are the result of a fast changing landscape educators must navigate in order to provide students with state of the art technology. Until now, state law was largely silent on the specific rules applicable to student privacy in the cyber world. In response to a demand for guidance, Assembly Bill (AB) 1584, Senate Bill (SB) 1177, and AB 1442 address how students, parents, educators and technology vendors interact with each other when it comes to protecting students online.

New Provisions That Must be Included in Contracts for Cloud Computing Services, Digital Storage, and Educational Software Agreements Involving Pupil Records

AB 1584 requires the inclusion of new contract provisions in the contracts between educational agencies and vendors for cloud computing services, digital storage, and educational software related to pupil records. The bill adds Education Code section 49073.1, which will apply to school districts, county offices of education and charter schools. In order to enter into such contracts, educational agencies must now have board policies authorizing these types of arrangements. This appears to be a conscious effort by the Legislature to involve educational agency governing boards in making policy revisions as to how student information will be stored, transmitted or handled on-line. Failure to comply with the new requirements may void the contract.

As of January 1, 2015, such technology agreements must include provisions that:

  • State student records are the property of the educational agency;
  • Allow students to retain control over their pupil-generated information;
  • Prevent third parties from using information for any purpose other than those specified in the contract;
  • Describe a process allowing parents to review and correct personally identifiable information;
  • Describe actions a third party will take to ensure the confidentiality and security of the pupil records;
  • Describe a process by which parents are notified of a security breach;
  • Require a certification declaring that pupil records shall not be retained or available to a third party upon completion of the contract;
  • Describe how the educational agency and third parties will comply with the federal Family Educational Rights and Privacy Act (20 U.S.C. § 1232g); and
  • Prohibit a third party from using identifiable information in pupil records to engage in targeted advertising.

Online Service Providers Must Now Protect Student Information

SB 1177 will add Business and Professions Code section 22584, requiring operators of educational internet websites, online services, online applications, and mobile applications to refrain from practices that compromise the security of student information or impinge on student privacy. As of January 1, 2016, online vendors that provide services to K-12 students, whether in the classroom or at home, are prohibited from advertising to students and using, selling or disclosing information gathered from students, with limited exceptions. Additionally, technology vendors must implement and maintain reasonable security measures to protect student data. This bill also empowers schools and school districts with the right to demand that technology vendors delete their copies of student data.

Limitations on Gathering and Using Information from Social Media

AB 1442 limits the types of information an educational agency may collect from social media sources regarding students. The bill adds Education Code section 49073, which will apply to school districts, county offices of education and charter schools as of January 1, 2015. Under this statute, educational agencies that consider establishing a program to collect information from social media sources regarding students must first notify student and parents of the proposal, and give the public an opportunity to comment on the proposal at a regularly scheduled meeting of the educational agency’s governing board. The notice and comment period is a prerequisite to the educational agency’s ability to collect and use student information gathered from any social media source.

Once the program is established, the educational agency may only collect information that is directly related to school or pupil safety. Like traditional student records, students and parents are entitled to access the information educational agencies gather from social media, and have the right to challenge the veracity of the information. However, unlike other student records, the information gathered from social media sources must be destroyed within one year of the student turning 18, or from the student’s departure from the educational agency, whichever occurs first. The statute also provides protections against third party use of the information gathered where the district contracts with a third party to gather such information. Contracts with third parties will likely need to incorporate certain of these statutory requirements.

Over the years, Lozano Smith has been on the forefront in advising school districts on legal issues related to the use of technology, including protecting student and employee information. Preparing students for the 21st century is sometimes hindered by 20th century laws, making it all the more important to give thought to how new technology can be used. Many of the new laws discussed above have at last begun to give express legal authority in support of best practices that we have recommended and our clients have implemented in recent years. The new laws may prove particularly helpful when dealing with larger internet, software and cloud computing providers, who have sometimes resisted these types of specific protections.

Our Technology and Innovation practice area has years of experience in reviewing and drafting technology-related contracts, advising on social media issues, developing email retention and electronic communications policies, and providing counsel to school districts and municipalities on a wide array of emerging technology matters. If you have any questions regarding such matters, please contact one of our eight offices located statewide. You can also visit our website, follow us on Facebook or Twitter, or download our Client News Brief App.

Written By

Harold M. Freiman
Partner
Walnut Creek Office
hfreiman@lozanosmith.com

Manuel F. Martinez
Associate
Walnut Creek Office
mmartinez@lozanosmith.com

©2014 Lozano Smith

As the information contained herein is necessarily general, its application to a particular set of facts and circumstances may vary. For this reason, this News Brief does not constitute legal advice. We recommend that you consult with your counsel prior to acting on the information contained herein.

New Law Imposes Written Notice Requirement on School Employers Related to Collective Bargaining

October 2014
Number 77

Governor Brown recently signed into law Assembly Bill (AB) 1611, effective January 1, 2015. AB 1611 amends Government Code section 3543.2 to require public school employers to provide “reasonable written notice” to an exclusive representative of the employer’s intent to make any change to matters within the scope of representation. The purpose of the written notice is to provide the exclusive representative “a reasonable amount of time to negotiate” the proposed change with the employer.

Under the Educational Employment Relations Act (EERA), employee organizations have the right to represent their members in employment relations with public school employers. Government Code section 3543.2 provides that the scope of representation is limited to matters relating to “wages, hours of employment, and other terms and conditions of employment.” Public Employment Relations Board (PERB) decisions have long supported the right of exclusive representatives to receive notice of and an opportunity to negotiate any proposed change relating to matters within the scope of representation. However, unlike other bodies of law dealing with other public employee groups, such as the Myers-Milias-Brown Act governing cities, there was no statutory provision in the EERA that explicitly mandated a public school employer to give reasonable, written notice of the employer’s intent to make changes to matters within the scope of representation. According to proponents of AB 1611, this caused the exclusive employee representatives to frequently file claims with PERB to enforce their rights to such receive written notice.

While proponents of the bill claim that AB 1611 provides clarification to both employers and employee representatives regarding a public school employer’s obligation to give notice of a proposed negotiable change, the bill has the potential to do just the opposite. Specifically, AB 1611 does not define what constitutes “reasonable written notice” for purposes of giving a “reasonable amount of time to negotiate.” Therefore, this change to the law may actually lead to more uncertainty as opposed to clarity regarding an employer’s notice obligations. Further, AB 1611 may place a significant burden on school districts if “notice” and “reasonable amount of time” are not subsequently defined by PERB in the employer’s favor.

In light of the above, public school employers must be mindful of this new written notice requirement if they intend to implement a change that impacts a matter within the scope of representation. While the law is not clear with regard to what the written notice must look like or the timelines required by the law, public school employers should ensure they clearly articulate the proposed change in writing and should err on the side of caution in determining how much advanced notice to provide in order to ensure a “reasonable time to negotiate.”

If you have any questions regarding the above, please contact one of our eight offices located statewide. You can also visit our website, follow us on Facebook or Twitter, or download our Client News Brief App.

Written By

Roberta L. Rowe
Partner
Fresno Office
rrowe@lozanosmith.com

Marisa R. Lincoln
Senior Counsel
Walnut Creek Office
mlincoln@lozanosmith.com

©2014 Lozano Smith

As the information contained herein is necessarily general, its application to a particular set of facts and circumstances may vary. For this reason, this News Brief does not constitute legal advice. We recommend that you consult with your counsel prior to acting on the information contained herein.

New Compensation Disclosure Requirements for School and Special Districts Under Assembly Bill 2040

October 2014
Number 76

The Governor signed Assembly Bill (AB) 2040, which amends Government Code sections 12463 and 53892 to mandate disclosure of the compensation of school and special district elected officials, officers and employees. Starting January 1, 2015, these agencies will have new reporting and internet posting requirements to provide the public with easy access to this compensation information.

For transparency, the compensation of all state, county and city elected officials, officers and employees has been available to the public through mandatory disclosure obligations under the prior versions of Government Code sections 12463 and 53892. AB 2040 expands these obligations to school districts and other special districts, such as water and fire districts. Under AB 2040, school and other special districts must include the compensation disclosures of their elected officials, officers and employees in their annual reports to the state Controller. Additionally, the compensation must be listed in a conspicuous location on each agency’s website if the district maintains a website. The information will also be available on the state Controller’s website.

Examples of the types of compensation that must be disclosed include:

  1. Salary;
  2. Vacation and sick leave; and
  3. Health and retirement benefits.

Compensation can also include less obvious forms of remuneration, such as salary step advancements. However, compensation does not generally include tenure or seniority credits. Agencies should contact their legal counsel to determine what compensation should be reported and made available on the agency’s website to adhere to the technical rules of disclosure.

AB 2040 is an effort to build confidence in all forms of local government. The new bill allows schools and special districts to demonstrate the ethical compliance and financial responsibility of its operations. Full disclosure of the compensation of elected officials, officers and employees will provide assurances to the public that such compensation is within industry standards. The disclosure and reporting practices from the state, county and cities have been well received. Compliance with AB 2040 will provide further confidence in our schools and special districts now that the Legislature has extended the requirements to these agencies as well.

A full copy of AB 2040 can be found on the California Legislature’s website.

If you have questions regarding the new disclosure requirements or other local governance obligations, please contact one of our eight offices located statewide. You can also visit our website, follow us on Facebook or Twitter, or download our Client News Brief App.

Written By

William P. Curley III
Senior Counsel
Los Angeles Office
wcurley@lozanosmith.com

Jessica Gasbarro
Associate
Sacramento Office
jgasbarro@lozanosmith.com

©2014 Lozano Smith

As the information contained herein is necessarily general, its application to a particular set of facts and circumstances may vary. For this reason, this News Brief does not constitute legal advice. We recommend that you consult with your counsel prior to acting on the information contained herein.

Baccalaureate Degrees Soon to Be Available at Select California Community Colleges

October 2014
Number 75

In late September 2014, Governor Brown signed Senate Bill (SB) 850, granting California community colleges the authority to award certain baccalaureate degrees. This brings California in line with twenty-one other states. The new legislation will be found in Education Code sections 78040, et seq.

Beginning January 1, 2015, the Board of Governors of the California Community Colleges may establish a pilot baccalaureate degree program at no more than 15 community colleges. The Board of Governors must adopt regulations by March 31, 2015, detailing the funding model for the program. Each of the participating colleges will be limited to establishing one baccalaureate degree program. There are several requirements participating districts must satisfy in order to establish a baccalaureate degree program, including but not limited to the following:

  • The baccalaureate degree offered must not be offered by the University of California (UC) or California State University.
  • The district is limited to one baccalaureate degree which shall only be available at one campus in the district.
  • The district must identify and document unmet workforce needs in the subject area that the baccalaureate degree program will be offered.
  • The district must have the expertise, resources, and student interest to offer a quality program.
  • A community college must commence its pilot program no later than the 2017-2018 calendar year.

SB 850 will provide additional opportunities for students drawn to educational programs unique to the community college system and creates a more affordable option for a baccalaureate degree. That said, the new legislation raises several key questions. The California community college system has been able to provide affordable quality education in the face of rising tuition fees and costs in the UC and California State University systems. Whether community colleges will be able to keep tuition costs low while providing baccalaureate degrees remains to be seen. There is also some concern that if successful, the baccalaureate degree programs will detract from the two-year degree programs which have historically been the foundation of the community college system. Finally, there will be questions about the specific funding formula for this program that will have to await adoption of new regulations. These and other questions will likely be answered over the life of the pilot program, which is set to expire in 2023.

If you have any questions regarding this legislation or community college issues in general, please contact one of our eight offices located statewide. You can also visit our website, follow us on Facebook or Twitter, or download our Client News Brief App.

Written By

Harold M. Freiman
Partner
Walnut Creek Office
hfreiman@lozanosmith.com

Gabriela D. Flowers
Associate
Sacramento Office
gflowers@lozanosmith.com

©2014 Lozano Smith

As the information contained herein is necessarily general, its application to a particular set of facts and circumstances may vary. For this reason, this News Brief does not constitute legal advice. We recommend that you consult with your counsel prior to acting on the information contained herein.