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2 ACKNOWLEDGMENTS This report was prepared by /International Human Rights Clinic at the Seton Hall Law School Center for Social Justice. Many current and former students contributed substantially to the report: Jessica Charniga, Katherine Harihar, Alicia Lera, Stephanie Mishler, Joseph Monaghan, Evan Ng, Nicholas Norcia, Gwendolyn Olinski, Rafael Perez, Alexandra Saites, Joshua Trojak, and Ana Yngelmo. They were supervised by Professor Bryan Lonegan. The Center for Social Justice would like to thank the following individuals for their valuable contributions to this project: Vanessa Acevedo, Labinot Berlajolli, Rosa Chilquillo, Jessica Culley, Lida Soledad Delgado, Rita Dentino, Santos Flores, Elias Garcia, Amy Gottlieb, Jose Manuel Guzman, Cait Kennedy, Kimberly Krone, Maria Martino, Diana Mejia, Alexa Malishchak, Kelly Ospina, Marlene Reyes, Sebastian Sanchez, David Socolow, Ted Smukler, Ellie Spiegel, Keith Talbot, Elizabeth Trinidad, Ron Uriguen, Jorge Vasquez, Jessica Zamora, Professor Michael Siegel and Professors Anjana Malhotra, Rachel Lopez, and Lori Nessel. The Center for Social Justice would also like to thank the following organizations: American Friends Service Committee, Casa Freehold, Comite de Apoyo a los Trabajadores Agricoles, Community Friends in Action, Grupo Amigos del Tarabjo, Hunterdon Hispanos, Seton Hall Law School Latin American Law Students Association, Pathways to Work, St. Wind of the Spirit. Finally, we are especially grateful to all the day laborers who had the courage and humility to entrust us with their stories. This report was made possible by the generous support of the New Jersey State Bar Foundation.
3 Table of Contents I. Introduction...1 II. Executive Summary and Recommendations...2 III. Methodology...4 IV. The Survey Results...7 a. Worker Profile...7 b. Wage Theft...7 c. Safety Violations...8 d. Violence Against Workers...8 e. Community Support...8 f. Access to Justice...9 V. The Limits Of Legal and Institutional Remedies...10 VI. Recommendations...11 a. Municipalities Should Standardize the Procedures that Allow Day Laborers to File Citizen Complaints Against Employers in Municipal Court...11 b. The Legislature Should Amend the Wage Theft Statute so that if the Employer Fails to Produce Legally Required Employee Records the Fact Finder May Infer that the Employee Worked for the Employer on the Dates and at the Wage Rate Alleged...12 c. The Legislature Should Amend New to Create a Presumption that Low Wage Workers are Employees and Not Independent Contractors...13 d. The Legislature Should Amend the Wage Theft Statute to Impose Criminal Sanctions for Employer Retaliation Against Employees Who File Complaints...13 e. The Legislature Should Amend the Wage Theft Statute to Impose Sufficient Fines and Damages to Deter Wage Theft...14 f. The Legislature Should Amend the Wage Theft Statute for Jurisdiction to be in Either the Place of Hiring or the Place of Work...14 i
4 g. The Legislature Should Amend the Wage Theft Statute to Import and Create Definitions for Key Terms and Phrases in the Wage Theft Statute...15 h. The NJDOL Should Utilize Community Groups to Assist in the Investigation and Preparation of Wage Theft Complaints...15 VII. Conclusion...16 Appendix...17 Notes...19 ii
5 I. Introduction In August 2010, the Seton Hall Law School Center for Social Justice released a report entitled Ironbound Underground which documented rampant wage theft and other workplace violations among day laborers in the East Ward of Newark. 1 Following the release of Ironbound Underground, various organizations and advocates working with day laborers throughout New Jersey asked that conduct similar surveys of the day laborers in their communities. The Clinic agreed, and during the month of October 2010, students in the Immigrant Rights/International Human Rights Clinic conducted a survey of day laborers in selected communities throughout the state and prepared this report of their findings. Day laborers are workers who are employed on a day-by-day basis without any obligations by an employer to employ the worker in the future. 2 Each morning, day laborers and employers negotiate short-term employment arrangements in open-air markets known as pick-up sites. 3 rkers 4 Workers are usually paid in cash and there are generally no records linking the employer to the day laborer. 5 The underground nature of the day labor market makes enforcement of labor laws difficult, often leading to abuse of workers by their employers. 6 Moreover, many, if not the majority, of the day laborers are undocumented. Their immigration status, ignorance of their rights, fear of authorities, and limited English proficiency make day laborers particularly susceptible to workplace abuses. 7 It would be a tremendous mistake, however, to assume that wage theft is an issue that only involves day laborers or immigrants. Because of antiquated, weak, or under-enforced labor laws, wage theft has become a pervasive problem in the United States. 8 Affected industries include retail, restaurants, grocery and drug stores, home healthcare, childcare, domestic work, construction, food and garment manufacturing, wholesale trades, dry cleaning, industrial laundries, car washes, car repair, parking lots, beauty and nail salons, and janitorial and security guard services. 9 While women, people of color, and immigrants are particularly vulnerable due to their disproportionately high representation i different degrees. 10 The Clinic chose to focus on day laborers because they are a relatively accessible group and are perhaps the most exploited of low income workers and therefore an excellent bellwether of wage theft, problems in enforcement of rights, and opportunities for solutions. Our purpose here, however, is to start public discussion of the issue of wage theft. To that end, we offer several suggestions to improve access to justice for day laborers that we believe would assist other low wage workers as well. 1
6 II. Executive Summary and Recommendations In October and November of 2010, the Clinic and its partner organizations surveyed 113 workers at seven pick-up sites in New Jersey where workers gather for work each morning on a daily basis. Clinic students also interviewed day laborer advocates, mayors, police chiefs, and municipal prosecutors to obtain their views of the extent of and solution to wage theft. As a result of its investigation, the IR/IHR Clinic found: Day Laborers Endure a Significant Level of Wage Theft. Fifty-four percent of day laborers experienced at least one instance in the last year of an employer paying them less money than promised; 48% experienced at least one instance of not being paid at all; 94% of those who on occasion worked over 40 hours per week reported that employers had not paid them overtime as required by state and federal laws. The Financial Loss to the Workers Due to Wage Theft is a Substantial Portion of Their Income. Forty-three percent suffered total losses from wage theft between $100 and $1000 in the past year; 14% suffered losses of $1000 or more. As for income, 60% of the workers earn $200 or less per week in the colder months (October through March) and 78% make an average between $200 and $500 per week in the warmer months (April through September). Working Conditions are Unsafe. Forty-three percent were never provided safety equipment (goggles, hardhats, masks, etc.) and 26% were injured on the job severely enough that they could not work for a period of time. Workers were Subjected to Violence by Employers. Twenty-six percent were assaulted by employers. Of those assaulted, only 14% reported the assaults to the police. Thirty-five percent had been abandoned at a worksite. Workers Do Not Use Legal Recourse to Obtain Unpaid Wages. Only three day laborers (2.6%) reported filing complaints with the New Jersey Department of Labor and NJDOL, with two having success in that effort. Similarly, only four workers (3.4%) reported that they had filed claims in small claims court against non-paying employers, only two of whom were successful. While New Jersey has a wage theft statute, it is almost never used, with only seven complaints brought under the statute in the entire state last year. Wage Theft was Less Frequent in Communities Where Community Organizations Provided Support. Workers in Morristown and Bridgeton, where established organizations with paid staff assisted the workers in wage disputes, had lower rates of wage theft than workers in Elizabeth and Orange, where there were no established organizations in the community to help day laborers. 2
7 Based on our survey, as well as interviews with public officials, community leaders, and experts on day laborers, the IR/IHR Clinic recommends: Municipalities Should Standardize the Procedures that Allow Day Laborers to File Citizen Complaints Against Employers in Municipal Court. To help facilitate better access to justice, municipalities should encourage and allow workers in their communities who have been victims of wage theft to file citizen complaints directly with the municipal courts rather than through the police. The New Jersey Legislature Should Revise Current Wage Theft Statute to Make it More Accessible to Low Wage Workers. The Legislature should s current statute to:! create an evidentiary presumption that a worker was employed by the employer if the employer fails to keep accurate employee records as required by law;! create a legal presumption that low wage workers are employees and not independent contractors;! impose criminal sanctions against employers who retaliate against employees who bring claims;! impose stiffer penalties for committing wage theft to provide more effective deterrence; and! allow jurisdiction for filing citizen complaints in either the place where hired or the place of work. The NJDOL Should Utilize Community Groups to Assist in the Investigation and Preparation of Wage Theft Complaints. Given its limited resources, the NJDOL should consider training and utilizing community groups to investigate and document violations and prepare complaints. 3
8 III. The Survey Methodology This report is based upon a survey of 113 day laborers at seven pick-up sites in New Jersey as well as interviews with government officials and community leaders. Based on discussions with day laborer advocates and a review of several hundred newspaper articles mentioning day laborers, the IR/IHR Clinic identified thirty active day labor sites in New Jersey (see Map). The seven sites selected for the survey represent geographical diversity and varying levels of organizational support among the day laborers. The survey consisted of multiplechoice questions and was conducted primarily in Spanish. Survey participants received Spanish translations of the survey questions so they could follow along. The surveys were administered by Clinic students and volunteers from Seton Hall Law School Latin American Law Students Association, except in Flemington and Bridgeton, where the surveys were administered by partner groups Hunterdon Hispanos and El Comite de Apoyo a los Trabajadores Agricoles (CATA), respectively. In order to maintain confidentiality, the interviewers did not ask survey participants for their name or other identifying information. Seton Hall Law School students conducted the survey in Elizabeth, Freehold, Morristown, Orange, and Palisades Park, spending a morning in each town between October 9 and 22, During those visits, the students observed between 40 and 50 workers in Elizabeth, 15 in Freehold, 50 and 60 in Morristown, 50 and 60 in Orange, and approximately 100 workers in Palisades Park. Prior to our arrival in Freehold, Morristown, and Palisades Park, local community organizations alerted the workers that we would be arriving and urged their participation. Workers in Elizabeth and Orange had no forewarning of our coming. Whether alerted to our coming or not, most of the 255 to 285 workers that we observed in those five towns declined to participate in the survey. Hunterdon Hispanos conducted the survey on the morning of October 13, 2010 among approximately 25 workers at a convenience store parking lot in Flemington. In Bridgeton, CATA conducted the survey at the Bridgeton pick-up site over the course of two mornings and one evening in October and November Finally, in compiling the data to make determinations of statewide results, we took into account that the size of the day laborer population and the level of participation in each town varied. Because the number of workers surveyed in any town was not necessarily proportional to its day laborer population, each town has been weighted the same. The statistical difference between these two alternatives is very small for the majority of the results and in no case ever exceeds a 3% difference for any one question. 11 Admittedly, in making these statewide determinations, the results may be more accurate if we factored in the day laborer population of each town. However, this information is not accurately obtainable considering, in part, the migratory nature of some day laborers as well as the seasonal flux of these populations. 4
9 Map used and shaded with permission from Rutgers Cartography. 5
10 Statewide Rates of Workplace Violations of Day Laborers!"#$%&'($ )*(+,-&'($!"$./+,#'0+$ 1*23,+($ 45&*("*+($ 466&37#+($ 89:$ ;8:$ <8:$ =>:$?;:$ =>:$ Rankings of Towns by Violations Percentages of reported violation are in parentheses. Towns appearing in red italics have no community organizations advocating for the workers. Towns appearing in purple underline have community organizations with paid staff. Towns appearing in black have community organizations with volunteer staff. Not paid Underpaid No overtime$ Injured Abandoned Assaulted! Elizabeth (80) Elizabeth (93) Elizabeth (100)! Elizabeth (66) Elizabeth (73) Freehold (50) Flemington (57) Pal Park (56) Freehold (100)! Orange (31) Orange (46) Orange (38) Orange (54) Orange (54) M orristown (100)$ Pal Park (25) Pal Park (44) Elizabeth (26) Freehold (42) Flemington (50) Pal Park (92)! Bridgeton (25) Freehold (29) Flemington (21) Bridgeton (37) Morristown (48) Orange (91)! Flemington (22) Bridgeton (19) Pal Park (19) Pal Park (37) Freehold (43) Flemington (88)! Morristown (8) Morristown (16) Morristown (16) Morristown (37) Bridgeton (31) Bridgeton (87)! Freehold (7) Flemington (14) Bridgeton (12) 6
11 IV. Survey Results The survey resulted in a profile of a very low wageworker who is regularly exploited and often subjected to violence. The extent of the abuse is somewhat dependent upon the community in which they work and the existence of organizational support. They rarely seek legal assistance and have largely accepted the conditions of their employment as the cost of doing business in the United States. a. Worker Profile The average worker participating in the survey was a married 37 year-old man from Central America 12 with a grade school education and limited or no English language skills. He has worked as a day laborer on average from two to more than five years. On average, he looks for work five days a week and finds work one to three days. He works primarily in construction, frequently for homeowners, although in Bridgeton he works primarily in agriculture nurseries, packing plants, or factories. His weekly income from October through April was approximately from nothing to $200 per week and approximately from $301 to $400 per week from May through G&,EH "#!$ %## "%#&!$ '## "'#&!$ (## "(#&$)## 4-,'7$F I+-#+05+, "#!$ %## "%#&!$ '## "'#&!$ (## "(#&!$ )## ")#&* +,- +,- b. Wage Theft Over the past year, 54% of the workers statewide were paid less money than they were promised by at least one employer. The highest rate of underpayment of wages was in Elizabeth, where 93% of day laborers reported that they had been paid less than promised at least once in the past year, followed by Palisades Park (56%), Orange (54%), Flemington (50%), Morristown (48%), Freehold (43%), and Bridgeton (31%). Over 48% experienced at least one instance in the past year where an employer paid them nothing at all for their work, with the highest rate of nonpayment being Elizabeth (80%), followed by Flemington (57%), Orange (54%), Freehold (43%), 7
12 Palisades Park (38%), Bridgeton (37%), and Morristown (24%). Statewide, of those who reported working more than forty hours for the same employer in one week, 94% were never paid overtime. In terms of loss, 31% of the workers surveyed reported that over the past year, they had been deprived of $100 to $500 of wages, 10% reported losses of $501 to $1000, and 14% reported losses of over $1000 in the past year. The remaining workers either suffered no loss or less than $100 during the year or could not recall how much they had lost. c. Safety Violations Approximately 26% of the workers had been injured severely enough while working that they could not work. Of those injured, 41% reported being out of work for one week or less and another 41% reported being unable to work for more than three weeks. Only three workers reported having been compensated for the time that they were unable to work. Despite the high rate of injury, 43% of the workers surveyed were never supplied with necessary safety equipment such as goggles, hardhats, or masks to prevent workplace injury, 39% percent of day laborers were only necessary safety equipment by their employers, and only 17% were necessary safety equipment by their employers. d. Violence Against Workers Statewide, twenty-six percent of the workers were assaulted on the job by an employer and nearly 35% were abandoned at a work site. The highest level of employer assault was reported in Freehold (50%), followed by Orange (38%), Elizabeth (27%), Flemington (21%), Palisades Park (19%). Morristown (16%), and Bridgeton (12%). Only four of the workers who said that they had been assaulted filed complaints with the police. Forty-three percent of those who reported that they had been assaulted by employers but did not report the assault to the police said that they had not done so because they were afraid that the police would report them to immigration authorities. Twenty-five percent believe that the police would not help them. e. Community Support Although not measured in our survey, our research indicated that the workers in Morristown and Bridgeton enjoy extensive support from the advocacy groups Pathways to Work 13 and CATA, 14 respectively, which both have paid staff to assist them in connecting workers with employers and monitoring working conditions. Casa Freehold in Freehold 8
13 Township, 15 Hunterdon Hispanos 16 in Flemington, and Grupo Amigos del Tarabjo and Community Friends in Action in Palisades Park 17 offered many of the same services albeit with a volunteer staff. In contrast, the workers in Elizabeth and Orange have no organization to monitor employment or mediate with the community, though organizers from the American Friends Service Committee recently begun to assist the workers in Elizabeth. Our data indicates that generally those communities with the highest rates of wage theft, employer assault, workplace injuries, and employer abandonment lacked organized locally-based community support. Elizabeth, the town with the highest rates of underpayment and nonpayment of wages, also had the highest rate of workplace injuries and abandonment. Orange had the third highest rate of wage theft and the second highest rate of workplace injuries, abandonment, and assault. On the other end of the spectrum, Morristown and Bridgeton both with strong local advocacy groups with paid staff generally had the lowest rates of wage theft and some of the lowest rates of workplace injuries, abandonment, and assault. f. Access to Justice Statewide, only three workers (2.6%) filed complaints with the New Jersey Department of Labor and Workforce Development and four (3.4%) filed complaints in small claims court. When we asked the remaining workers why they had not filed claims with either the NJDOL or in court, more than half the responses were that they did not know that they could, did not know how to do so, or were afraid to file a complaint. Many said that it simply was not worth the trouble to complain. Notably, 26% percent of those interviewed said that employers had threatened to report them to immigration authorities if they complained. /#.# (# %# !5672 8:3497;3! :78< @8049 9
14 V. The Limits of Legal and Institutional Remedies Despite rampant exploitation and abuse, New Jerse have few legal or institutional avenues for obtaining justice. Due to legal and budgetary constraints, the federal and state Departments of Labor lack the ability to address day labor issues, civil actions in small claims court are too complicated for the workers who cannot afford counsel, and criminal prohibition on wage theft by statute is largely moribund. The United States (WHD) has jurisdiction to prosecute wage theft only when the employee is engaged in interstate commerce. 18 However, according to the workers and the community organizers who assist them, most employers who hire day laborers are small, independent contractors involved in local projects who are not subject to the WHD jurisdiction. Nonetheless, Joseph Petrecca, the northern New Jersey district director, has told advocates that despite its limited jurisdiction, his office was willing to call transgressing employers to attempt to negotiate voluntary payment. 19 While the how effective it will be in the absence of enforcement authority. In contrast to the limitations on the authority, officials at the NJDOL report that the agency investigates every wage and hour complaint it receives. 20 With high caseloads and limited staffing, however, the NJDOL complaint process usually requires more than a year to resolve matters. 21 Advocates told us that while the NJDOL has been sympathetic toward day laborers and meets with workers to educate them on their right to unpaid wages, the backlog of cases and lack of success in getting workers their money has caused advocates to stop filing complaints with the agency. 22 As an alternative to government agency administrative processes, workers can file complaints in small claims court for breach of contract. But this avenue has likewise proven ineffective. In the experience of the IR/IHR Clinic, workers have been unable to collect even when they win judgments, in large part because workers do not have information on the accounts or other financial accounts upon which they can file a lien. Day laborers are generally not privy to any of this type of information and thus are largely unable to collect judgments. Finally, New Jersey has a criminal wage theft statute that states that an employer who has agreed with an employee... to pay wages... commits a disorderly persons offense if the employer fails to pay wages when due 23 This statute, the subject of the following section, is almost never employed by anyone. According to the Administrative Office of the Courts, only seven cases were filed under this statute last year. 24 Indeed, we spoke with twelve municipal prosecutors and none recalled ever prosecuting a wage theft charge. None of the organizers we spoke with were familiar with the statute. 10
15 VI. Recommendations: The Legislature Should Amend New s Wage Theft Statute to Provide Day Laborers Greater Access to Justice To combat wage theft, some states and municipalities have implemented new and comprehensive municipal ordinances, toughened state administrative schemes, or implemented criminal sanctions. 25 Some of these efforts have been very successful. For example, within the first five months of enacting the Miami-Dade County wage theft statute in 2009, complainants collected $25,000 of unpaid wages. 26 Unfortunately, under New Jersey law, municipalities are barred from enacting their own anti-wage theft ordinances under the state preemption doctrine. 27 Some states that have implemented a new wage theft statute have simultaneously created a new administrative process within a newly created governmental division. For example, Illinois created a separate division within the Illinois Department of Labor to specifically handle cases of wage theft and streamline the process of bringing a claim. Ideally, New Jersey would establish a similar office, preferably a dedicated branch within the Division of Wage and Hour Compliance of the NJDOL. In light of the current economic and budget environment in New Jersey, however, it seems unlikely that the Legislature would have the resources to mandate a new administrative scheme. 28 Due to the legal and economic limitations to improving the current available protection against wage theft, we suggest as an alternative that the New Jersey Legislature implement a more robust criminal wage theft statute. If done in earnest, revising the current statute can have almost immediate results. Specifically the legislature should create an evidentiary presumption that a worker was employed if an employer fails to keep accurate employee records as required by law; impose criminal sanctions against employers who retaliate against employees who bring claims; create a legal presumption that low wage workers are employees and not independent contractors; and amend the penalties for committing wage theft to provide more effective deterrence. We discuss these and other recommendations in greater detail below. In addition, based on our review of other wage theft statutes, we have appended a proposed model statute to start discussion of legislative change in New Jersey. a. Municipalities Should Standardize the Procedures that Allow Day Laborers to File Citizen Complaints Against Employers in Municipal Court. Wage theft is not a problem that can be eliminated by statutory amendments alone. 29 An amended wage theft statute will only be effective if victims have the opportunity to safely and effectively use it. To this end, we recommend that municipalities should standardize procedures for for wage theft directly with municipal court to make justice more accessible to victims. A citizen complaint is brought by a private citizen rather than a 11
16 police officer. 30 Although they are usually associated with complaints agai police, they can be utilized in a variety of circumstances. 31 A citizen complaint must be filed with the municipal court in the municipality where the crime took place. 32 The actual procedure for filing a citizen complaint varies from town to town and may vary by the type of crime alleged. For certain types of injuries, some jurisdictions require filing a police report before a complaint may be filed with the municipal court. 33 Other jurisdictions allow a citizen to file a complaint with the municipal court directly without having to go to the police first. 34 In each case, a judge or an administrator authorized by a judge will issue an arrest warrant or summons once the citizen bringing the complaint convinces the judge of probable cause. 35 Considering the delays day laborers experience with complaints to the NJDOL and the problems they encounter in enforcing small claims court civil judgments, citizen complaints in municipal court for wage theft may offer the best opportunity for day labors to obtain swift and effective justice. As a criminal matter, the municipality would be pursuing the employer, eliminating the workers need to retain counsel. Resolution would be relatively quick and lighter sentencing may be conditioned on payment of lost wages and the appropriate damages and fines. Finally, by allowing the workers to complain directly to the court, day laborers need not interact with the police whom, as our survey shows, they are hesitant to complain to even when they are assaulted by employers. b. The Legislature Should Amend the Wage Theft Statute so that if the Employer Fails to Produce Legally Required Employee Records the Fact Finder May Infer that the Employee Worked for the Employer on the Dates and at the Wage Rate Alleged. Under existing New Jersey Wage and Hour Law and Regulations and Wage Payment Law, employers are required to keep true and accurate records of time worked by each employee and the wages paid to each employee. 36 These records must be surrendered to the Commissioner of the NJDOL upon demand. 37 offense but imposes no additional consequences in terms of wage and hour disputes. 38 The Legislature should, therefore, amend the statute to provide that when a defendantemployer fails to present the legally required employee records to refute an employee- or jury may infer that the employee did work for the employer on the alleged occasions at the agreed rate. On the other hand, the production of required business records for the disputed employment period would not automatically negate a claim. In that circumstance, the issue for the court would be the credibility of the parties. The Miami-Dade civil wage theft statute provides for a similar presumption
17 c. The Legislature Should Amend N Presumption that Low Wage Workers are Employees and Not Independent Contractors. According to labor experts, a persistent problem in wage and hour regulation is that employers misclassify employees as independent contractors who are exempted from wage and hour regulation. 40 For example, a defense to the previous recommendation would be that the employer need not maintain or provide employee records because the complainant was not an employee but an independent contractor. Although New Jersey currently criminalizes an independent contractor, and low wage workers rarely qualify as independent contractors, 41 misclassification still presents a substantial evidentiary hurdle for an employee to overcome in any type of legal action seeking to redress their harm. 42 We recommend, therefore, that the New Jersey Legislature also implement a rebuttable presumption which cannot be altered by contract that states that any low wage worker is presumed to be an employee. 43 The presumption would not mean that every worker in a low wage industry is in-fact an employee, but it would presume they are until an employer can demonstrate otherwise. A rebuttable presumption would balance the risk of purposeful employer misclassification of an employee as an independent contractor against the risk of improperly identifying an independent contractor as an employee. 44 The threshold income amount of a low wage industry employee should be determined by the Legislature and set in such a way to keep up with the inflationary or deflationary pressures of the national economy. 45 Miami-Dade County recently enacted a wage theft ordinance that creates a presumption that low wage workers are not independent contractors. 46 New Mexico created a presumption that only applies to the construction industry 47 and Massachusetts for all service industries. 48 Arizona requires an employer to prove that an employee is an independent contractor by clear and convincing evidence. 49 d. The Legislature Should Amend the Wage Theft Statute to Impose Criminal Sanctions for Employer Retaliation Against Employees Who File Complaints. A common aspect of wage theft complaints has been retaliation by employers taken against the employees who files claims. As our survey indicated, 26% of the workers we spoke with said that employers had threatened to report them to immigration authorities in response to filing a claim, which is an illegal retaliatory action. 50 This Clinic has witnessed workers abandon complaints because of such threats. 51 New Jersey law a certain employees retaliated against by certain employers. 52 While some statutes provide for 13
18 damages and others criminalize retaliatory actions against an employee, there is no overarching framework applicable to all employees in all industries. 53 Therefore, an anti-retaliation provision should be added to the statute that provides for damages and criminal penalties for all low wage workers. ns taken against an employee as a misdemeanor and allows for specific recovery of damages. 54 The New York Legislature also considered adding these provisions although they were ultimately removed from the final legislation that was recently passed. 55 e. The Legislature Should Amend the Wage Theft Statute to Impose Sufficient Fines and Damages to Deter Wage Theft. deterrence for combating it and other employer abuses would be to make it prohibitively expensive to engage in such behavior. Under the current wage theft statute, an employee can only recover wages owed, and a court can fine an employer up to a maximum of $1,000 per offense. 56 In practice, however, courts generally do not impose these fines for minor offenses. 57 Additionally, the wage theft statute does not tier the penalties for repeat offenders, so that the maximum fines and penalties facing a first time offender are the same maximum fines and penalties facing a tenth time offender. 58 This is an inadequate deterrence to wage theft by corrupt employers, especially those who employ day laborers with the intent to cheat them. We recommend that the damages and fines imposed on convicted employers be mandatory, steeper, and tiered for repeated offenses. Further, repeated acts of wage theft should be elevated from a disorderly person offense to a felony. 59 Moreover, wage theft victims should be awarded liquidated compensation, perhaps an additional 100% of the amount in controversy. 60 New Jersey law already provides for augmented victim awards in other contexts including landlord/tenant disputes. 61 While the New Jersey Criminal Code does not provide for liquidated damages for victims of a disorderly person offense, we recommend that the Legislature allow liquidated damages for victims of wage theft to serve as a deterrent to unscrupulous employers and as well to compensation to victims for their lost wages. 62 f. The Legislature Should Amend the Wage Theft Statute for Jurisdiction to be in Either the Place of Hiring or the Place of Work. Currently, New Jersey law provides that citizen complaints have to be filed where the crime occurred, but does not define that term. Because employers hire day laborers in one town but transport them to another, the wage theft statute should explicitly state that the place where the offense occurred, and the resulting jurisdiction, may be either the place hired or the place where the work was performed. 14
19 g. The Legislature Should Amend the Wage Theft Statute to Import and Create Definitions for Key Terms and Phrases into the Wage Theft Statute. Absent explicit definitions in a criminal statute, courts interpret words by their ordinary meaning. 63 This has the potential to lead to inconsistent results and at times creates an unnecessary hurdle in the administration of justice. Therefore, to better protect the employee and to prevent needless litigation, the wage theft statute should explicitly define essential words and h. The NJDOL Should Utilize Community Groups to Assist in the Investigation and Preparation of Wage Theft Complaints. The New Jersey Department of Labor and Workforce Development should consider implementing a program in which community organizations are trained and utilized by the NJDOL to conduct investigations of wage claims and prepare complaints before they are brought to the Division of Wage and Hour Compliance. 64 This would allow the community organizations to act as a force multiplier for the NJDOL and eliminate the need for the NJDOL to investigate each claim that comes before the Division, making it more efficient and less resource intensive. 65! 15
20 VII. Conclusion By no means are the recommendations of this report meant as a panacea for wage theft and other abuses of workers. Instead they are meant to foster discussion about all workers, marginalized and not, and the safeguarding of their rights. Clearly no statutory change is sufficient on its own to address all of the problems encountered by day laborers. This report did not extensively discuss, or in many cases even touch upon, other avenues that could provide additional protection. These other avenues could include the creation of hiring halls, more comprehensive private rights of action, and a dedicated sub-division within the Wage and Hour Division of the New Jersey Department of Labor and Workforce Development. Other statutory considerations include creating effective avenues for workers to bring wage theft claims in civil court. Finally, as some states and municipalities have realized, a new administrative scheme to specifically tackle wage theft claims may be exceptionally useful. As this report found, there are many important players in society that provide support to exploited workers. Community organizations, especially those with a paid staff, have played a crucial role in educating day laborers about their rights and helping to assert these rights in many circumstances. However, they are not alone in this role. Municipal courts, prosecutors, and state and local officials all have essential parts to play in enforcing labor standards and further safeguarding the rights of workers. This report should serve as an invitation to these groups and individuals to engage more thoroughly with all employees who suffer the consequences of wage theft, including day laborers. Critics Ironbound Underground, argued that because many of these workers were undocumented, they deserved to be the victims of wage theft and other abuses. However, what these criticisms failed to recognize is that when one worker suffers we all do. Abuse of labor laws, including wage theft, creates a race to the bottom where all workers see their safeguards erode. Day laborers are akin to the canary in the coal mine, effectively serving as a warning system for those abuses of workers that are becoming all too common. While the recommendations proposed in this report were drafted with a focus on day laborers, this was only done as a starting point to more broadly discuss issues of wage theft and other abuses against employees. 16
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text:
December 24, 2002
Paula Abdul has a "strictly hypothetical" question for Dr. Phil: "Let's say there's a guy from another country, maybe England … and he has a crush on me … I mean, my friend Pauline … but he shows his interest by being incredibly mean. How should I, I mean she, handle him?"
Dr. Phil says that Paula, or Pauline, that it "seems like she can hold her own. Besides, he jokes, "the last time England came over here and messed with America, they got a whoopin!"
Kristin Davis of Sex and the City wants to know if Dr. Phil worries about how his guests might handle what he says.
"No, I don't worry about what I say to people on television, but I do take it very seriously," says Dr. Phil. "I don't think we're doing eight-minute cures up here. We're giving people wake-up calls … I weigh very carefully everything I say because there are millions of people watching, and some of them are going to act on some of the things I say."
What's it like to live with Dr. Phil? Robin McGraw, Dr. Phil's wife, seems to also tell it like it is!
"As a husband, he's the sweetest man in the world. On the show, I think he's brilliant. I've known this man for 30 years and I still am amazed at what he does up here," she says. "But when he comes home, when he walks in the door, he is totally helpless. It's like, 'Where do we keep the ice?'"
Christine called in and can't believe her "perfect child" is a lesbian. She believes having a relationship with a woman is her daughter's way of being rebellious. She asks, "Is homosexuality a learned behavior?"
"Jackpot Judy" goes to the casino once a week and spends $60 on the slot machines. "It's my escape," she says. She doesn't drink or smoke, so this is her one indulgence. She's crabby if she doesn't get to go. "Do I have a gambling problem?" she asks Dr. Phil.
"You're just giving money away!" says Dr. Phil. The casinos are raking it in while she squanders cash she can't afford to lose. "The thing that really concerns me is that you feel really drawn to it," he adds. "Don't go." Explaining that he diagnoses her situation as a problem, he suggests that she try not going for six months to see how it feels.
Leslie is 24 years old and can't let go of her baby blanket. She even took it on her honeymoon! Before she and her husband have a baby, she wants to be over her blankie.
If you want to break this habit, says Dr. Phil, you must behave your way out of it. Identify the payoff you get and replace the blankie with something that can give you the same thing. If the blanket gives you comfort and security, for example, try getting this from your husband. Replace the child stimulus with an adult one, and remember that habits are broken when they're replaced with new behaviors.

subset: commoncrawl


text: I've searched and haven't found anything on this, but that doesn't mean it hasn't already been answered. My issue is this: I've linked my email exchange server to my droid and it works great. Actually get emails to my phone before my computer in most cases. All of my inbox folders are accessible and emails that are in those folders can be read. However, when I read an email in my inbox (computer or droid) and it stays in my inbox without being put into a subfolder (say for purpose of needing information later) it disappears from my droid inbox. It isn't actually deleted from the inbox cause I can still access it on my computer outlook but damned if I can't find it on my droid after an hour or so has past from the time I first read it. Anyone know how to fix this? I can't seem to find a setting or anything for this and haven't heard anyone else talking about it. Thanks for the help, James


text:
Jersey Shore's fourth season will wrap tonight (October 20) with the cast saying goodbye to Florence, Italy and preparing to return to the States.
Last week's episode saw the housemates' frustration with The Situation reaching boiling point following a discussion of room allocations back in Jersey, and The Situation surprising everyone by suggesting that he might not return to Jersey with them.
MTV has now teased that tonight's episode will see Ronnie "demanding [The Situation] make amends, but as the crew counts down the days until their return to Seaside, Mike wonders whether or not to join them back on the Jersey Shore".
Watch a teaser video for the finale below (US only):
Teaser videos released by the network also reveal that the cast will do some sightseeing before they leave Italy, which sees Snooki sharing her plans for making over the Statue of David, while Deena thinks he's "sexy".
Jersey Shore airs its finale tonight (October 20) at 10pm ET/PT on MTV. It will be followed by Jersey Shore: The Reunion at 11pm ET/PT, which will see the cast reuniting to talk about the season.
Jersey Shore Hook-Up: Live Edition will then air at 12am ET, where the cast will answer fan questions via Twitter live on MTV.com.


text:
I have always been a fan of the slow cooker. I love that you can add a bunch of ingredients to a big ol' pot, turn it on and walk away. In a matter of hours you have a delicious and flavorful meal that required very little effort. More times that not I use my slow cooker throughout the week. This allows me to have a tasty meal ready for my family whenever we walk through the door at the end of the day. You really can't beat that can you? No racing around the kitchen at 5:30 and more time with my family. It's a win win.
Second to chicken, pork tenderloin is probably one of my favorite meats to cook. I don't use it as much as I'd like but each time I have it I'm reminded just how much I love it. It takes on the flavors of whatever it's marinated it and it penetrates the meat. You not only taste the flavor of the marinade on the outside of the meat but throughout as well. Cooking it in the slow cooker only intensifies the flavor penetration creating a very tender and flavorful meat.
I think this is one of my new favorite recipes. It requires very little preparation and it's bursting with flavor. I love balsamic vinegar; it's tangy, thick and sweet and adds so much flavor. I think it's one of my many addictions! The balsamic combined with the mustard, onions, sticky maple syrup, sweet brown sugar, thick honey, and herbs provides the ultimate of marinades that penetrates throughout the meat. This marinade not only provides tons of flavor but allows the meat to cook slowly and keeping it tender where it literally falls apart at the touch.
Slow Cooker Maple and Brown Sugar Pork Tenderloin
2 lbs pork tenderloin (either one 2 pound pieces or two 1 pound pieces)
2 Medium sweet onions cut in quarters
2 Cloves garlic, minced
2 Tbsp maple syrup
4 1/2 Tbsp Dijon mustard
2 Tbsp honey
2 1/2 Tbsp brown sugar
2 Tbsp balsamic vinegar
1/2 Tsp dried thyme
Salt and pepper, to taste
1 Cup chicken or beef stock
Wash and trim the pork and pat dry. Season with salt and pepper and place in the slow cooker. Evenly sprinkle the minced garlic over the pork loin(s).
In a small bowl combine mustard, honey, brown sugar, vinegar, thyme and maple syrup and whisk together. Pour the mixture over the pork loin and turn to coat. Pour the stock over the broth. Place the lid on the slow cooker and turn on low for 7-9 hours or high for 3 1/2-4 1/2 hours.
Remove pork from slow cooker and transfer to plate or platter, cover with foil and set aside. Remove a few spoonful's of the cooked onions to the platter as well. Using an immersion blender, blend the juice and onions in the slow cooker. This will provide you with a creamy gravy to spoon over your tenderloin and mashed potatoes (if serving).
Recipe source: adapted from Six Sisters Stuff and Joelen's Culinary Adventures, who adapted it from Southernfood.about.com


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Tuesday, May 8, 2018
Kylie Jenner returns to the red carpet in peekaboo dress with boyfriend Travis Scott at Met Gala
Kylie Jenner walked the Met Gala red carpet three months after having her baby Kylie Jenner.
The 20-year-old who stayed away from the limelight all through her pregnancy, made her return on Monday night, accompanied by her baby daddy Travis Scott.
However, fans were not so impressed with her choice of outfit. The theme of the gala was Heavenly Bodies And The Catholic Imagination, but Kylie and Travis' attire was not exactly in line with the theme.
The new mum wore a simple peekaboo black Alexander Wang gown with a train, and paired it with sheer black stockings and nearly invisible PVC heels. Travis sported a matching black look with chain detailing.
This is Kylie's first big event since welcoming daughter, Stormi Webster.
Labels: CELEBRITY UPDATES, NEWS
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Broken Drum Records' News
Hi everyone – here's some updates from Broken Drum Records
Record labels don't really exist, at least not since the demise of the old music industry. Broken Drum Records is really just a couple of people (and sometimes a few of their friends) making the music we like. The label is really a brand. It gives you a clue about what to expect musically from the label's releases.
We've had ongoing but significant computer problems in our studio for almost a couple of years now. Well, the PC won't load up at all some days. It means some projects are a year overdue but we've squeezed a small number of releases out. This will hopefully be resolved within a couple of weeks and we'll be getting back to work as quickly as possible.
Secret Archives of the Vatican have long had a collaborations album in the pipeline. We've started on some tunes and have contacted various potential collaborators but it all ground to a halt. That album will be the first priority as we get rolling again. In the meantime, their most recent release, Damascene, is still available.
One strategic decision we made recently was to separate out the occasional political rant tune from among Secret Archives' repertoire. Secret Archives will focus on their core Middle-eEastern, romantic, kung-fu, science fiction orientated output and more political tunes will be released in the name Tyrantbane. The first release, Flame, came out recently.
Thousand Yard Prayer, who are slightly more "acoustic" than Secret Archives of the Vatican and often have a Central Asian or Persian flavour to their tunes, continue to release eclectic and challenging releases. We are particularly happy with their recent album, Golden Section.
We've also been developing our admittedly rudimentary video making skills. Check some out here.
We've been disappointed at our failure to acquire any reviews or coverage at all lately, despite notifying various outlets about our releases. Even those who promise to write something don't.
Anyway, we will continue to make music. This is digital resistance to the forces of bland music industry homogeneity and a quiet resistance to the apparently inexorable rise of the political right with its disdain for culture.


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Dear Friends!!!
I hope I will get a good response as always!!!
My sister who was pregnant with twins, lost her one baby in the 19th week of her pregnancy. It started with high BP and yellowish discharge. she had donor egg blastocyst transfer.
The other one is doing just fine, gowing well, but she is having bleeding and not spotting. although its brown in colour but no blood is good in the pregancy. She also has fibroids and she is admitted into the hospital.
I just want to know if we have had any other case like this and went on to deliever a healthy baby.
Thanks friends!!!


text: Dr Hazel Wilkinson, Junior Research Fellow in English, has been awarded a Carr-Thomas-Ovenden Visiting Fellowship in English Literature 2016-17 at the Bodleian Libraries. She has also been awarded the Mark Samuels Lasner Fellowship in Printing History by the American Printing History Association. Both awards are in support of work her new monograph on the Wild […]Continue Reading


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The Privacy of Your Laptop at International Borders
The blogosphere has been bubbling over the past few weeks over the subject of laptop searches and seizures at international borders. The source of the buzz? A couple of recent court cases.
First, The Ninth Circuit recently held in United States v. Arnold that the Fourth Amendment does not require government agents to have reasonable suspicion before searching laptops or other digital devices at the border, including international airports. The privacy and free speech implications of this decision are very significant because many of us store a wide range of private information on our laptops.
US Customs agents now have free reign to search through all the photos of your personal life, emails to your friends and family, all the e-books you have purchased, and your entire music library. If you have confidential work information about clients, patients, breaking news stories, or business deals, US Customs may attempt to view those materials. And if you try to keep that information private through the use of encryption, you may face a further problem with US Customs.
In a second case currently working its way through District Court in Vermont, United States v. Boucher, the federal government is arguing that it can legally compel someone crossing an international border to enter their data decryption password, in order to search the encrypted files on a laptop computer.
While the right to keep your encrypted data to yourself is making its way through court, there are several documented instances of US customs pressuring travellers into typing in their passwords to enable a "voluntary" search of their data. The Washington Post recently reported this:
A few months earlier in the same airport, a tech engineer returning from a business trip to London objected when a federal agent asked him to type his password into his laptop computer."This laptop doesn't belong to me," he remembers protesting." It belongs to my company." Eventually, he agreed to log on and stood by as the officer copied the Web sites he had visited, said the engineer, a U.S. citizen who spoke on the condition of anonymity for fear of calling attention to himself.
And if you say no to the US Customs agent requesting your data? You may miss your flight (at your own expense). Again, from the Washington Post:
Maria Udy, a marketing executive with a global travel management firm in Bethesda, said her company laptop was seized by a federal agent as she was flying from Dulles International Airport to London in December 2006. Udy, a British citizen, said the agent told her he had "a security concern" with her. "I was basically given the option of handing over my laptop or not getting on that flight," she said.
Legal minds have chimed in on the issues that these cases present. Jennifer Granick of the Electronic Frontier Foundation has weighed in a couple of times, while the gang at the Volokh Conspiracy have discussed the cases at length.
On the technology side of things, CNET's Declan McCullagh and Christopher Soghoian have also given their own advice to avoiding a border search, as has security guru Bruce Schneier. Finally, father of crypto Whitfield Diffie and cyber-activist John Gilmore have further suggestions.
As unfortunate as it is, there doesn't seem to be any disagreement that if you have data on your laptop, US customs may try look at it. The real question is whether or not to try to maintain confidentiality of data through encryption. There are essentially three different methods:
- Encrypt your data with one of many off-the-shelf encryption tools. Most modern operating systems (Mac OS X, Windows Vista, and Linux) include disk encryption support out of the box.
- Encrypt the data with TrueCrypt, or one of the other encryption suites specializing in plausibly deniable encryption. TrueCrypt has multiple layers of encryption, which can be peeled back depending on the situation. When stopped by law enforcement, a TrueCrypt user would simply peel back the first layer, which would only reveal a collection of innocent and boring files. Other more confidential files could still be behind additional layers of data.
- Encrypt the data, and either email it to yourself, upload it to an online storage service, or burn it to DVD, and mail it to your final destination. Then, securely erase your laptop, re-install a fresh operating system onto the machine, and pass through US Customs, calm and content with the knowledge that you are not in possession of anything that could cause you legal problems.
The first solution is very problematic. A US Customs agent will turn on your laptop, see the encrypted partition or folder, and ask you for your password. If you are a US citizen, saying no may lead to you losing your laptop. If you are not a US citizen, you may be rejected entry to the US. No matter what happens, the mere presence of encryption software is likely to lead to you being exposed to significantly more suspicion.
The second solution, while an innovative application of technology, also has many problems. If a user has hidden the entire encrypted folder, or has opted to use the multiple levels of plausibly deniable encryption, they can still be undone with two simple questions: "Sir, do you have any encrypted data on this disk?" and "Sir, do you have any additional encrypted data on this disk?"
This can put you in a very bad situation-disclosing the data or lying to law enforcement. Lying to US Customs or other law enforcement officer may result in criminal prosecution. Just ask Martha Stewart, who was indicted, under Title 18, United States Code, Section 1001, for lying to federal government agents.
So, the only way to protect your confidential information until the law is settled may be option number three. Prepare and encrypt your data ahead of time, and upload that encrypted data to the Internet. When you do get stopped by a US Customs agent, you will be able to truthfully state that you have no sensitive or encrypted data at all on the computer. With a clean laptop, you can travel through customs with confidence that confidential data will remain protected.
Nicole A. Ozer is the Technology & Civil Liberties Policy Director at the ACLU of Northern California.


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Definition of theocrats
plural of theocrat 1
The word "theocrats" uses 9 letters: A C E H O R S T T.
No direct anagrams for theocrats found in this word list.
Words formed by adding one letter before or after theocrats (in bold), or to acehorstt in any order:
i - rheostatic l - charlottes y - athrocytes
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All words formed from theocrats by changing one letter
Other words with the same letter pairs: th he eo oc cr ra at ts
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Mark Nordenberg Honored at Excellence is Ageless Gala
Nearly 500 friends, supporters and partners of Lutheran SeniorLife gathered at Heinz Field on April 28 to celebrate Abundant Life at the Excellence is Ageless Gala, helping to raise approximately $235,000. Proceeds will benefit benevolent care.
This year's honoree was Mark Nordenberg, chancellor emeritus at the University of Pittsburgh. Throughout his distinguished career, Nordenberg has inspired others to be vibrant and productive, while making significant contributions to the community through his service, philanthropy and leadership.
(l to r) David Fenoglietto, Jane Bittcher, Mark Nordenberg
"I am deeply grateful to Luthean SeniorLife for honoring me in such a special way," Nordenberg said.
In his remarks, Nordenberg cited many examples of people in his life who have taught him to live abundantly, and said that it is important to stay active and engaged as we age.
"At every stage of our lives, we all have things we want to accomplish, experience and enjoy. Helping people maintain the ability to effectively pursue their dreams - whatever they may be - sits at the heart of the Lutheran SeniorLife mission," Nordenberg said. "And the passionate pursuit of wide-ranging dreams promotes an Abundant Life."
Attendees had the opportunity to bid on auction items including many pieces of art created by some of our residents and program participants, sports memorbilia and much more.
"We are committed to never asking somebody to leave one of our programs or our residences, or to stop using one of our services because they have run out of financial resources," said Jane Bittcher, president of the Lutheran SeniorLife Foundation, adding that Lutheran SeniorLife provides $3 million annually in benevolent care.
"Our passion for serving seniors has helped make us the most comprehensive and diverse faith-based non-profit provider in the tri-state area," said David Fenoglietto, president and CEO of Lutheran SeniorLife. "Thank you all for your support in helping us to continue to provide an Abundant Life to the seniors we serve."