Schools And Public Agencies Face A Rise In Digital Copyright Infringement Claims For Use Of Protected Photos

April 2019
Number 19

Cease and desist letters alleging copyright infringement for the unauthorized use of digital photos-along with demands for settlement payments ranging from hundreds to tens of thousands of dollars-are being sent to public agencies. This trend seems to be on the rise, whether it is a journalism student’s use of a photo for the online student newspaper, or a social media manager’s use of a graphic for the agency’s Facebook feed. Although the initial demands can be quite high, including threats of hundreds of thousands of dollars in statutory damages if the copyright owner has to litigate the claims, sometimes the license fees can be negotiated down depending on the number or nature of infringing uses.

A contributing problem is the ease with which digital photos can be copied online. Additionally, it is increasingly simple to detect unauthorized online use. Advanced algorithms used in today’s Internet search engines make it easy to identify every unauthorized use of a photo online anywhere. Digital photos can also be copied from anywhere on the Internet using a snipping tool or by taking a screenshot and are quite tempting to those who want the perfect photo, but may not have given consideration to the intellectual property rights of the photo’s owner.

A number of law firms seem to be at the forefront of pursuing these claims. These attorneys identify the sites where unauthorized photos appear, the registrants for those sites, and the addresses where the demand letters can be sent. If you receive one of these letters, the first step in addressing the claim is to secure proof of copyright ownership and the lawyer’s authority to act on behalf of the copyright holder.

In addition to assisting public agencies with resolving the pending infringement claims, Lozano Smith is also working with clients to implement “best practices” to avoid future claims of copyright infringement. These best practices include, but are not limited to:

  • Do not use any pictures that are “copied and pasted” from other Internet sites.
  • Consider using only photos that are taken by someone associated with or hired by the agency department responsible for publication of the pictures.
  • If you find that the picture you want to use is “subject to copyright,” contact the copyright holder in advance and get permission or a license to use it.
  • Train staff, or in the case of school districts, students as well, regarding these issues. Focus training particularly on web designers, public information officers and journalism teachers.
  • Use the threat of copyright infringement as a “teaching opportunity” for students and staff to understand what is required to navigate the digital universe.

For more information about the legal requirements for use of copyrighted works or how to implement these and other best practices to avoid such claims, please contact the authors of this Client News Brief or an attorney at one of our eight offices located statewide. You can also subscribe to our podcast, follow us on Facebook, Twitter and LinkedIn or download our mobile app

Written by:

Harold M. Freiman

Partner

Lee Burdick

Associate

©2019 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.

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Lay Opinions May Trigger The Need For An Environmental Impact Report

February 2019
Number 12

A California appellate court has ruled that lay public opinions on nontechnical issues concerning a project’s size and general appearance can provide substantial evidence of environmental impact, triggering the need to prepare an environmental impact report (EIR) under the California Environmental Quality Act (CEQA).

The California Environmental Quality Act

CEQA generally requires public agencies to identify potentially significant impacts of projects they carry out or approve, and mitigate those impacts where feasible. Unless a project is exempt from CEQA, the public agency must prepare one of three types of documents. A negative declaration (ND) can be prepared where there is no substantial evidence that the project may have a significant effect on the environment, and a mitigated negative declaration (MND) can be prepared where the project has potentially significant environmental effects, but these effects will be reduced to insignificance by mitigation measures. An EIR, however, is required whenever substantial evidence in the record supports a “fair argument” that the project may produce significant impacts or effects. An EIR generally involves more time and often more cost than an ND or MND.

Georgetown Preservation Society v. County of El Dorado

The Third District Court of Appeal filed its decision inGeorgetown Preservation Society v. County of El Dorado (2018) 30 Cal.App5th 358, on December 17, 2018, affirming the trial court’s writ setting aside El Dorado County’s (County) approval of a project based on an MND. The County had prepared an initial study to analyze the environmental impacts of a proposed Dollar General chain discount store (Project) and found that there was no basis to require an EIR. Local residents acting through plaintiff Georgetown Preservation Society (Society) objected, claiming that the Project would impair the aesthetic character of their town. The Project was located in a historic center and several lay opinions were submitted by the local community, which commented that the Project was
too big and too boxy and would damage the look and feel of the town, and would therefore have significant and negative effects related to aesthetics. The County slightly modified the project and ultimately adopted the MND. In part, it found that the project complied with local zoning because the area was zoned for commercial retail, that the Project’s design, architectural treatments, and associated improvements substantially conform to the County’s Historic Design Guide and, that the Project would not substantially detract from the town’s historic commercial district.

The Society filed a lawsuit seeking to require the County to prepare an EIR. The trial court applied prior case law and found that the Society’s evidence supported a fair argument that the Project may have a significant aesthetic effect on the environment. Accordingly, the trial court issued a writ of mandate compelling the County to prepare an EIR.

On appeal, the County relied on the fact that it had applied its Historical Design Guide principles when it found the project met aesthetic standards. In the County’s view, the ensuing finding of compliance with its Historical Design Guide principles could not be disputed by lay opinion evidence. A key issue addressed by the Court of Appeal was whether non-expert factual evidence or lay opinion evidence proffered by area residents can support a “fair argument” that the Project may have a significant aesthetic impact on the environment. In reaching its decision, the Court of Appeal followed the rationale in Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, and held that (1) consistency with local design guidelines could not be used to insulate a project from CEQA review; (2) lay opinions can provide substantial evidence to support a “fair argument” that a project may have a significant aesthetic impact on the environment, triggering the need to prepare an EIR; and (3) since the County made no credibility determinations, it could not categorically disregard the
public’s comments.

Takeaways

Georgetown Preservation Society serves as a reminder of the impact public opinion may have on projects approved or carried out by public agencies, and that lead agencies should not disregard public opinion in non-technical areas like aesthetics. Previous court decisions have also considered lay opinions in other impact areas such as noise, traffic safety, and parking. Therefore, lead agencies should not solely rely on its industry experts when evaluating the environmental impacts of a project. If the community members’ opinions on these issues are not properly taken into consideration, project delays and increases costs can result.

If you have any questions about the appellate court’s decision in Georgetown Preservation Society and its impact on CEQA compliance, or about the CEQA in general, please contact the authors of this Client News Brief or an attorney at 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:

Kelly M. Rem

Partner

Jose Montoya

Associate

©2017 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.

Court Reaffirms Governing Board’s Ability to Impose Reasonable Limits on Public Comment

September 2018
Number 51

A California appellate court recently reaffirmed the limitations a governing board of a public entity can impose on public comments during a board meeting (Ribakoff v. City of Long Beach).

Background

As was his frequent practice, Joe Ribakoff attended a Long Beach Public Transportation Company (LBTC) board meeting as an interested citizen. LBTC’s lone shareholder is the City of Long Beach, and LBTC operates as a public entity. During the public comment period, Ribakoff spoke for the three minutes that an LBTC board ordinance grants members of the public to address the board. When Ribakoff attempted to speak a second time, after the close of public comment, he was denied the opportunity to speak further and his microphone was cut off. An LBTC representative testified that Ribakoff became argumentative and appeared to approach the dais where the board was seated. A police officer was summoned and told Ribakoff that if he disrupted the meeting again, he would be arrested for violation of a city ordinance prohibiting disturbance or interruption of a board meeting.

Ribakoff sued the board, arguing that the board meeting disturbance ordinance violates the First Amendment, and that its three-minute speaking limit violates the Brown Act and the First Amendment.

To support his argument that the ordinance’s prohibition on disturbance or interruption of a board meeting violated the First Amendment, Ribakoff pointed to precedent that says an ordinance is unconstitutional if interpreted to allow an arrest based on the content of the disruption. However, that precedent also found that an ordinance is constitutional if it is construed to be a content-neutral “time and place” restriction. The court construed the challenged ordinance to be a legitimate “time and place” regulation that only penalized speech based on whether it was disrupting the meeting, not on what was being said.

The Brown Act permits a public agency’s governing board to adopt reasonable time limitations to ensure adequate opportunity for public comment, but prohibits the board from censoring public criticism of it. Ribakoff argued that the three minute limit is not reasonable because the board used it for a purpose other than time limitation-it allowed the board to censor his criticism. However, the court found no evidence to support this argument. The board did not stop Ribakoff from speaking during his initial three minutes, despite his critical statements. It was only when he attempted to speak after his three minutes had expired that he was restrained from speaking further.

Ribakoff also claimed that the time limit is unreasonable because the three-minute limitation applies only to public comment and not the board or its invited speakers. The court disagreed, pointing out the difference in purpose between public comments and board or invited presenter speech. When the board or its invited presenters speak, it is for the benefit of the public. The board regulates the number and length of these presentations, and ensures that they do not take more time than necessary. Conversely, public comment is potentially unlimited depending on how many members of the public are at the meeting, so a reasonable time limitation is justified.

The court recognized that board meetings are open to the public, yet are still governmental processes with an agenda and a purpose. Therefore, limitations for the purposes of keeping the board meeting on schedule and on topic are justified.

Takeaways

  • Boards are generally not permitted to adopt rules that limit public comment based on the content of the comment. But it is not a free speech violation to limit comments to the topic at hand.
  • Cities or other entities with police power may adopt ordinances that authorize penalties for members of the public when their behavior-and not the content of their expression-impairs the conduct of the meeting.
  • Boards may adopt reasonable time limitations on public comment.
  • Boards may have different time limitations for public comment versus board members or invited speakers.

For questions regarding the Ribakoff decision or about public comment or board meetings in general, please contact the authors of this Client News Brief or an attorney at 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

Jordan R. Fong

Associate

©2017 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.

Court Limits Enforcement of Public Sleeping Ordinances

September 2018
Number 50

A federal appeals court has held that a city could not enforce local ordinances that prohibit homeless persons from sleeping outside when shelter is not available. Municipalities with similar ordinances may be affected by the Ninth Circuit Court of Appeals’ decision in Martin v. City of Boise.

Background

At a time when homelessness is an issue that cities and counties are increasingly called to address, a common trend is to prohibit sleeping and camping on the sidewalk, in parks, and in other public places. The City of Boise enacted ordinances to do just that. The ordinances prohibit the use of “any of the streets, sidewalks, parks, or public places as a camping place at any time” where “camping” is defined as “the use of public property as a temporary or permanent place of dwelling, lodging, or residence” and “[o]ccupying, lodging, or sleeping in any building, structure, or public place, whether public or private” without permission.

Several homeless residents challenged enforcement of the Boise ordinances. The factual basis for their claim was fairly straightforward: Plaintiffs are homeless; there is not enough room at the homeless shelters for all of the city’s homeless; plaintiffs and other homeless persons have no choice but to sleep outside and in public when the shelters are full; therefore, plaintiffs and other homeless persons are forced to violate the city’s ordinances. Their claim rested on the Eighth Amendment’s prohibition against cruel and unusual punishment. Specifically, the Amendment’s “substantive limits on what the government may criminalize” was at issue.

The court examined prior U.S. Supreme Court cases concerning narcotics addiction and public drunkenness, as well as the since-vacated Ninth Circuit decision in Jones v. City of Los Angeles that restrained enforcement of an ordinance that prohibited sitting, lying, and sleeping in public. The court adopted the reasoning of its prior ruling inJones, finding Boise’s ordinances effectively criminalize the status of being homeless, as opposed to undesirable conduct that can be prohibited.

The Martin court concluded that “the Eighth Amendment prohibits the imposition of criminal penalties for sitting, sleeping, or lying outside on public property for homeless individuals who cannot obtain shelter.” “[A]s long as there is no option of sleeping indoors,” the court ruled, “the government cannot criminalize indigent, homeless people for sleeping outdoors, on public property, on the false premise they had a choice in the matter.”

Takeaways

Despite the ruling, there is likely a future for sleeping and camping ordinances. The court declared that “[its] holding is a narrow one” and made some important qualifications regarding its ruling. Some clues are also found in the text of the decision. For example, the court’s regular reference to “public property” suggests that sleeping and camping ordinances may still be enforced when the conduct occurs on private property, regardless of shelter space.

The court further made clear, albeit in a footnote, that the ruling “does not cover individuals who do have access to adequate temporary shelter, whether because they have the means to pay for it or because it is realistically available to them for free, but who choose not to use it.” Moreover, it did not say a city can never prohibit sleeping in public when there is insufficient shelter space. Without making an express decision on this point, the court said that “an ordinance prohibiting sitting, lying, or sleeping outside at particular times or in particular locations might well be constitutionally permissible,” and, “an ordinance barring the obstruction of public rights of way or the erection of certain structures” may be acceptable. This may mean that permitting outdoor sleeping in designated places and times will permit widespread enforcement of such an ordinance elsewhere.

Throughout Martin, the court focused on the natural and necessary act of sleeping, stating that “the two ordinances criminalize the simple act of sleeping outside on public property.” This raises an interesting point about camping ordinances. The court was critical of the city’s enforcement of the camping ordinance against homeless persons “with some elementary bedding,” sleeping “with blankets,” or when other indicators of “camping” are absent. It appears that the problem did not lie with the camping prohibition itself, which would prevent the act of constructing a camp or other shelter, but with sleeping and taking basic precautions in order to sleep outside.

The court stated that its ruling does not require cities to provide homeless shelters. But, when there are more homeless people than available shelter beds, the ordinances will be unenforceable. Practical unavailability of shelter beds may also impact enforcement. During the litigation, Boise instituted a “no space, no enforcement” protocol where the shelters would self-report if they were full so the ordinances would not be enforced that night. However, one shelter had a policy of not turning away anyone seeking shelter and never reported that it was full. As a result, the exception was never actually triggered. There was also evidence of limits on the number of consecutive days someone could stay at one shelter before a mandatory stay-away period. Additionally, due to the time of day that beds were assigned and preferences given to returning guests, a shelter with available room might stop making assignments for the night before prospective guests learn they are unable to get a bed at the other shelter, leaving them with no place to go.

The city reportedly will appeal the panel decision to the full Ninth Circuit. Until new decisions are issued, this ruling applies and municipalities that prohibit sleeping or camping in public places should review their ordinances and consult legal counsel concerning continued enforcement.

If you would like more information about the Martin decision or have any questions regarding municipal sleeping or camping ordinances, please contact the authors of this Client News Brief or an attorney at one of our eight offices located statewide. You can also visit our website, follow us on Facebook orTwitter or download our Client News Brief App.

Written by:

Jennel Van Bindsbergen

Partner

Wesley L. Carlson

Associate

©2017 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.

Ninth Circuit Shoots Down Challenge to Law Prohibiting Concealed-Carry Permit Holders from Possessing Firearms on School Property

September 2018
Number 46

In Gallinger v. Becerra, the Ninth Circuit Court of Appeals rejected a challenge to a 2015 change to California’s Gun-Free School Zone Act that removed an exemption allowing concealed-carry permit holders to carry firearms on school grounds, but maintained the same exemption for retired peace officers.

The Ninth Circuit held that lawmakers had a rational basis for approving this change, effected by Senate Bill (SB) 707, and also that the partial elimination of the exemption did not violate the Equal Protection Clause of the Fourteenth Amendment.

Background

A collection of public interest groups and individuals challenged SB 707 on two bases: that SB 707’s treatment of concealed-carry permit holders is analogous to a similar ban in the Assault Weapons Control Act (AWCA) struck down in Silveira v. Lockyer, and that SB 707 violates the Equal Protection Clause because it favors a politically powerful group and disfavors a politically unpopular one. The Ninth Circuit found both arguments unpersuasive.

The plaintiffs, citing Silveira, argued that distinctions between concealed carry holders and retired peace officers do not serve a valid legislative purpose. However, the Ninth Circuit distinguished its holding in Silveira, in which the court determined that the AWCA’s retired-officer exemption was “wholly unconnected to any legitimate state interest.” The court reasoned that it did not serve a valid purpose to exempt retired officers from AWCA’s ban affecting one specific type of firearm-assault weapons-but found that SB 707’s ban on all guns on school grounds did serve a legitimate policy interest. The Ninth Circuit determined that SB 707’s retired-officer exemption serves a valid public purpose, deferring to the Legislature’s reasoning that allowing retired peace officers to carry weapons on school grounds both provided for the officer’s safety and also the public’s safety. The court additionally determined that the legislative history of SB 707, which detailed the Legislature’s concerns about gun-rights organizations advising gun owners to bring firearms onto school campuses in the wake of several school shootings, provided sufficient rationale for ending the concealed-carry exemption.

The Ninth Circuit was similarly unpersuaded by the plaintiffs’ argument that SB 707 violated the Equal Protection Clause by disfavoring a politically unpopular group, concealed-carry owners, and favoring a politically powerful group, retired peace officers. The court held that there was no evidence of explicit legislative intent to harm concealed-carry holders. Evidence demonstrating that retention of the retired-officer exemption was the product of political lobbying also did not show impermissible discrimination: Favoring retired officers did not show a parallel intent to harm concealed-carry holders.

Takeaways

The court’s application of current events to legal aspects surrounding gun control is notable. In the Gallinger decision, the Ninth Circuit cited numerous school shootings to support both the Legislature’s purpose in banning concealed-carry holders-to reduce the number of guns on campus-and also, the Legislature’s intent to provide for safety by allowing retired officers to carry firearms on school campuses or in school zones. Going forward, school administrators and personnel responsible for school safety can rely upon the Gun-Free School Zone Act to prohibit firearms on school grounds, regardless of whether someone possesses a permit to carry a concealed weapon.

More broadly, Gallinger shows a significant level of judicial deference to the Legislature’s findings of public purpose related to school safety. Such safety policies and gun control legislation often inspire tension with an individual’s rights under the Second Amendment and the public’s right to access to government facilities. Recognizing a newfound emphasis on school safety, the court in Gallinger showed deference to the rationale advanced for both ending the concealed-carry exemption and upholding the retired-officer exemption.

For more information about this decision and its impact on school districts, please contact the authors of this Client News Brief or an attorney at 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:

Thomas R. Manniello

Partner

Tilman A. Heyer

Associate

©2017 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.

Ninth Circuit Upholds California’s Voters’ Choice Act

September 2018
Number 45

The Ninth Circuit Court of Appeals recently affirmed the constitutionality of California’s Voters’ Choice Act (VCA), which provides for an all-mail ballot election system. The court’s opinion validates the ability of states and local election officials to implement and operate systems that are designed to increase voter turnout.

In this litigation, Lozano Smith represented respondent County of Madera, which had opted in to the VCA system for the 2018 election cycle and beyond.

Background

Responding to low voter turnout in the 2014 election cycle, the California Legislature enacted the VCA in 2016. Prior to the VCA, California voters could opt to vote by mail on an individual basis. Under the VCA, a ballot is automatically mailed to every registered voter 29 days before the election date. A voter may cast the ballot by mailing the ballot back in, depositing the ballot at a designated locked mailbox location, or turning in the ballot at a “vote center” (which replaces traditional polling places).

However, the VCA did not require all California counties to adopt the new system. Instead, under a pilot program, 14 enumerated counties were authorized to opt in after January 1, 2018. With an exception for Los Angeles County (which has its own set of options by statute), all other counties may opt in to the VCA system on or after January 1, 2020. For the 2018 election cycle, five counties-Madera, Napa, Nevada, Sacramento, and San Mateo-opted in to the VCA system. The option of voting by mail is still open in non-VCA counties.

Jeffrey Short, et al. v. Edmund G. Brown et al.

On February 26, 2018, plaintiffs Jeffrey Short, Trina T.R. Heter, and the Sacramento Valley Lincoln Club sued the State of California and the counties of Madera, Nevada, and Sacramento, seeking to enjoin the operation of the VCA. The individual plaintiffs were citizens of counties who could not opt in to the VCA until 2020, and they alleged that the VCA’s structure violated the Fourteenth Amendment’s Equal Protection Clause by permitting voters in certain counties to receive a mail ballot automatically, while requiring voters in other counties to register to receive a mail ballot. According to the plaintiffs, this would result in the dilution of votes in non-VCA counties because voter turnout would likely be greater in VCA counties, as intended by the Legislature.

In the trial court, the plaintiffs’ motion for preliminary injunction was denied based on the hardship that enjoining the 2018 elections would create. However, the trial court also held that the plaintiffs had raised “serious questions on the merits” as to the constitutionality of the VCA related to vote dilution.

The plaintiffs appealed to the Ninth Circuit Court of Appeals. On June 22, 2018, the Ninth Circuit denied the appeal. The Ninth Circuit held that the injunction request was properly denied based on hardship, and further held that the injunction should also have been denied based on a lack of substantive merit. Consistent with established constitutional law holding that challenges to state election laws are only strictly scrutinized when there is a severe burden on the right to vote, the Ninth Circuit held that the VCA did not burden the right to vote, but simply made it easier for some voters to cast mail ballots by mail. The burden on non-VCA county voters in having to request a mail ballot was considered minimal at best, and thus not demanding of strict scrutiny. Assuming such a slight burden even would exist, the Ninth Circuit held that California had a legitimate interest in increasing voter turnout, and that there was a specific interest in the incremental phasing that the VCA provides for, to allow for reporting back on the results of the VCA for legislative guidance.

Takeaways

The Ninth Circuit’s opinion supports the proposition that unless there is a substantial burden placed on the voters, state legislatures have ample discretion as to how to deal with low voter turnout, including the implementation of pilot programs that can eventually be applied to the entire state.

If you have any questions about Short et al. v. Brown et al., or the VCA in general, please contact the authors of this Client News Brief or an attorney at 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:

Sloan R. Simmons

Partner

Michael R. Linden

Senior Counsel

©2017 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.

Field Trip Immunity Does Not Apply to a Community College’s Hosting of an Intercollegiate Athletic Event

August 2018
Number 44

Community college districts are generally immune from liability for injuries sustained in the course of field trips and excursions under the California Code of Regulations, title 5, section 55220. However, inAnselmo v. Grossmont-Cuyamaca Community College District, an appellate court determined that such immunity does not apply to an injury sustained during an intercollegiate athletic tournament.

Background

In this case, a community college hosted an intercollegiate beach volleyball tournament at its campus. During the competition, a beach volleyball player, who attended a different community college district, was injured when she dove into the sand and hit her knee on a rock.

The student filed a complaint against the college, claiming that she was injured due to a dangerous condition that existed at the college’s facility. The college sought to dismiss the case, contending that the field trips and excursions immunity under section 55220 applied.

The court disagreed with the college and concluded that section 55220 did not apply to this situation. The court determined that the college did not conduct the student’s field trip or excursion (i.e., direct or manage the actual travel). Rather, it provided the sports facility that the student traveled to with her team. As the host of the intercollegiate athletic competition, the college had an ongoing responsibility to provide reasonably safe premises to all teams participating in the tournament, including the visiting beach volleyball players.

Takeaways

Field trips and excursions immunity has specific and limited application for community college districts. While the court did not expressly state that such limitations apply to immunity provided to K-12 school districts, it did note the similarities in the statutory immunity language for K-12 districts. Finally, this case highlights the importance of public entities maintaining their property in a safe condition.

If you have any questions regarding the Anselmo case or field trip immunity in general, please contact the authors of this Client News Brief or an attorney at 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:

Edward J. Sklar

Partner

Aria G. Link

Associate

©2017 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.