In AT&T Mobility LLC v. Concepcion et ux., AT&T had charged consumers $30.22 for phones that they had advertised as “free”. That didn’t seem right to two consumers, Vincent and Liza Concepcion, who decided to bring a class action lawsuit against AT&T. The Concepcions chose to bring the lawsuit as a class action because it made no economic sense for them to individually sue AT&T for just $30.22. By bringing everyone together in a class action, the Concepcions could sue AT&T for all of the money that had been overcharged to all consumers in the class.

However, it turns out AT&T’s fine print had a clause that prohibited class actions, thereby forcing the Concepcions and other consumers to sue AT&T individually. Today, the US Supreme Court held that that obscure clause was enforceable.

What does this mean? It means companies now have the power to ban class actions against them and force consumers to bring individual lawsuits, no matter how small the amount of money at stake. Consumer-rights advocates are saying that this ruling would spell the end for small claims involving products or services. They say the devil is in the details. But in this case, it is in the fine print.

Employees are not safe either. The Concepcion ruling will likely spill over into labor and employment law cases throughout the country, as employers who read Concepcion start incorporating class action bans into their own employee policies and contracts. Also, as Andrew Cohen of the Atlantic Monthly points out, Concepcion is a foreshadowing of how the Supreme Court will likely rule on Wal-Mart v Dukes, a class action being brought by 1.5 million women against Wal-Mart for discriminatory pay practices.

Now that the Concepcions’ class action has been thrown out by the highest court in the land, it appears AT&T will get to keep the millions of dollars it fraudulently collected from consumers after all. This is because, as Justice Stephen Breyer noted in his dissent, who in their right mind is going to bother with an individual lawsuit against AT&T for $30.22?

Breyer wrote in his dissent (joined by Associated Justices Ruth Bader Ginsburg, Sonia Sotomayor and Elena Kagan):

In general agreements that forbid the consolidation of claims can lead small dollar claimants to abandon their claims rather than to litigate. I suspect that it is true even here, for as the Court of Appeals recognized, AT&T can avoid the $7,500 payout (the payout that supposedly makes the Concepcions’ arbitration worthwhile) simply by paying the claim’s face value, such that “the maximum gain to a customer for the hassle of arbitrating a $30.22 dispute is still just $30.22.” What rational lawyer would have signed on to represent the Concepcions in litigation for the possibility of fees stemming from a $30.22 claim? In California’s perfectly rational view, non class arbitration over such sums will also sometimes have the effect of depriving claimants of their claims (say, for example, where claiming the $30.22 were to involve filling out many forms that require technical legal knowledge or waiting at great length while a call is placed on hold). Discover Bank sets forth circumstances in which the California courts believe that the terms of consumer contracts can be manipulated to insulate an agreement’s author from liability for its own frauds by “deliberately cheat[ing] large numbers of consumers out of individually small sums of money.” Why is this kind of decision–weighing the pros and cons of all class proceedings alike–not California’s to make?

The Concepcion decision takes its place next to Citizens United v. Federal Election Commission and Lilly M. Ledbetter v. The Goodyear Tire & Rubber Co., Inc. as one of the worst decisions in recent memory to come from the Supreme Court’s conservative faction (Chief Justice Roberts and Associate Justices Antonin Scalia, Samuel Alito, Clarence Thomas and Anthony Kennedy). It is now up to Congress to pass a law that effectively overturns Concepcion, just as they overturned the Ledbetter decision with the Lilly Ledbetter Fair Pay Act of 2009.

If you believe companies and employers should not be allowed to steal even small amounts of money from their customers and employees, please write to your congressional representative and ask him or her to support H.R.1020 and S.931, both entitled “The Arbitration Fairness Act of 2009″. And look for a bill to be introduced in Congress that explicitly overturns Concepcion.

Related posts:

1. Shocker – U.S. Supreme Court Rules in Favor of Employees!
2. Cal. Supreme Court Rules: Medical Pot Users Can be Fired
3. Starbucks Baristas Win $105 Million Class Action Judgment

According to the Whittier Daily News article, “Our View: Court budget woes will slow wheels of justice”, Los Angeles County has the biggest court system in the U.S., handling roughly 9.5 million cases filed in 2006 to 2007 alone. The article reports that the local courts in Alhambra, Downey, El Monte, Glendale, West Covina and Whittier are on the chopping block.

So what does this mean?

At present, civil cases take 1 to 1.5 years on average to get to trial under the California “Fast Track” Rules (“Trial Court Delay Reduction Act”), which were enacted on a pilot basis in 1987 and formally instituted in the early 1990s. Court closures would likely mean a return to the bad old days before the “Trial Court Delay Reduction Act”, when cases typically took 5 years to get to trial and many courts had large backlogs of civil cases.

The closures won’t be good for anyone.

Plaintiffs will suffer because they will have to wait that much longer for resolution of their claims and to collect their judgments. So the claimant who was defrauded out of their life savings by a guilty-as-sin defendant will have to wait 5 years or more instead of 1 year to get his money back. The employee who was sexually harassed or wrongfully terminated will have to live without closure and have to relive painful experiences for 5 years instead of 1 year. Meanwhile, memories will fade, documents will disappear, witnesses will move residences or change their minds about testifying, etc., making it harder to get and keep the evidence needed to prove her case.

Defendants will suffer because they will have litigation hanging over them for that much longer. If a frivolous or baseless lawsuit is filed, they will have to wait longer to clear their names. The lawsuit will remain a distraction from doing business for a longer period of time. The number of lawsuits will pile up for larger corporate defendants and public entities, making harder the tasks of managing them and of forecasting how much money will be needed in their litigation funds to make any potential payouts. Businesses looking for financing or strategic partners will need to disclose a growing list of unresolved and unwelcome pending or threatened litigation to potential investors and partners. In short, the uncertainty introduced by a growing list of lawsuits will mean the business environment itself will become more uncertain.

Both parties will also suffer because they will have to travel to more distant courthouses and, after having trekked there, will more frequently be told to come back again later due to delays caused by a reduced court staff dealing with increased case backlogs. They will also probably have to wait longer for courts to issue decisions.

On the bright side, parties and their lawyers will have less aggressive trial schedules and more relaxed deadlines to deal with (though that is really just another way of saying “being more inefficient”). And perhaps more cases will settle instead of going to trial (although, at present, only 3.5% of cases nationwide actually go to trial anyway).

In the end, the economy will suffer as disputes go unresolved for longer periods of time. Perhaps Judge McCoy sums it up best:

Contracts will go unenforced, vital capital will be tied up in interminable judicial limbo, and cases of every kind will stagnate for years. In the current economic environment, when so much effort is being put into stimulus, and uncertainty plagues the economy, the state cannot afford for court delays to become a brake on economic recovery.
Whittier Daily News

Of course, nothing is definite just yet.

According to an LA Times article, “Schwarzenegger to seek federal help for California budget”, California’s governor is expected to ask Washington for $8 billion in federal help to deal with California’s $20 billion budget deficit. If the federal government comes to the rescue, that could impact planned court closures. Likewise, if the economic recovery starts generating jobs and income soon enough, that could put tax dollars back into the state’s coffers and ease the budget crisis.

In any case, there should be no understating the seriousness of court closures on California. Peaceful and efficient resolution of disputes is an essential requirement of any well-functioning economy in the 21^st century. If we are to return to economic prosperity, we cannot afford to weaken the legal infrastructure that enables that to happen.

No related posts.

1. In recent years, workers have become more likely to check their email outside of normal working hours:

50% of employed email users say they check their work-related email on the weekends. Fully 22% say that they check their work email accounts “often” during weekend hours, compared with 16% who reported the same in 2002.
34% of employed email users say they will at least occasionally check their email while on vacation; 11% say they do so “often.”

2. One in five employed email users and half of Blackberry and PDA owners say they are required to read and respond to work-related emails when they are not at work

Fully 48% say they are required to read and respond to email when they are away from work.

Some experts say that employers are getting a free ride on employees by not paying for these off-hours activities. An ABC News report, “Overtime Pay for E-mails? Debate Grows” quoted Catherine Ruckelshaus, legal co-director of the non-profit National Employment Law Project:

“If you aggregate all the workers [checking e-mail off the clock] and all the hours they do it, that’s really a ton of money. It’s very lucrative for employers”.

Others counter these concerns by pointing out employees shouldn’t be paid around the clock, 24/7, either. ABC News quoted John Robinson, employment attorney with Florida law firm Fowler White Boggs:

“Now the issue is if you have a BlackBerry or a PDA, are you working 24/7? You could be called at any time. . . . The company’s argument always is, ‘Yeah, but you can go to the movies, you can go to Disney World, but you just have the cell phone with you.”

One thing everyone agrees on is that the problem is growing as the US struggles with a jobless recovery and technology advances. Workers remain less likely to complain about after-hours work in order to hang onto scarce jobs. At the same time, employers trying to do more with fewer employees continue to squeeze more productivity out of workers tethered to Blackberries and email. ABC News quoted Alex, an hourly employee at a Web startup in the San Francisco Bay area:

“I really can’t complain because I know a lot of my old classmates are still looking for jobs”.

Nevertheless, a few workers have recently challenged the practice in the courts. According to a Wall Street Journal article, “Lawsuits Question After-Hours Demands of Email and Cellphones”, two recent lawsuits against employers T-Mobile USA Inc. and CB Richard Ellis Group Inc. involve novel legal claims that hourly workers should be paid for time spent responding during off hours to work messages on company-issued phones. In the case against CB Richard Ellis, a maintenance worker, John Rulli, is suing for back wages because he was forced to remain reachable during off hours via a company-issued Blackberry. Rulli’s lawyer, Larry Johnson, stated:

“This new technology allows employers to invade its employees’ lives by forcing them to work after hours without being compensated for the time they spend on the BlackBerry”.

Ultimately, it appears wage and hour laws have failed to keep pace with new technology and the problems created by it. It remains to be seen how the question of “what is work in a digital age?” will ultimately be answered, and whether it will be answered by the courts or the legislature, or both.

If you have questions about unpaid work after hours, talk to a lawyer.

Related posts:

1. Thou Shalt Not Send Emails from the Office
2. Can My Employer Monitor My Web Surfing or Emails at Work?
3. US Workers: Overworked, Underpaid & Left Behind

This is big news. Lawyers around the country are rejoicing now. And you should be too.

Until now, the biggest providers of caselaw – Lexis-Nexis and Westlaw – have acted as a duopoly, charging lawyers a significant amount to access their caselaw databases via slow, proprietary search engines and arcane, hard-to-memorize search commands. Other vendors like FastCase, Versuslaw, Casemaker, charge less but have serious drawbacks compared to the Big Two, such as incomplete caselaw databases.

At long last, Google has entered the space and is now threatening to change the rules of the game for good.

One would think caselaw should be available free to the public. After all, cases are written by judges whose salaries are paid by the taxpayers. Why then should the public have to pay to view cases, the work product of these judges? More importantly, the US legal system is a common law system – meaning judges make the law bit by bit with each case they decide. This means the cases ARE the law. How then can a democracy rule itself without easy and convenient public access to caselaw?

These are the troubling questions numerous organizations have asked themselves and tried to answer by independently attempting to make caselaw available to the public for free. Google gives an honorable mention to these pioneers in its launch announcement: Tom Bruce (Cornell LII), Jerry Dupont (LLMC), Graham Greenleaf and Andrew Mowbray (AustLII), Carl Malamud (Public.Resource.Org), Daniel Poulin (LexUM), Tim Stanley (Justia), Joe Ury (BAILII), Tim Wu (AltLaw)”.

Now Google has thrown its hat into the ring. And what an entrance it is. Here is an excerpt from Google’s launch announcement:

“Starting today, we’re enabling people everywhere to find and read full text legal opinions from U.S. federal and state district, appellate and supreme courts using Google Scholar. You can find these opinions by searching for cases (like Planned Parenthood v. Casey), or by topics (like desegregation) or other queries that you are interested in. For example, go to Google Scholar, click on the “Legal opinions and journals” radio button, and try the query separate but equal. Your search results will include links to cases familiar to many of us in the U.S. such as Plessy v. Ferguson and Brown v. Board of Education, which explore the acceptablity of “separate but equal” facilities for citizens at two different points in the history of the U.S. But your results will also include opinions from cases that you might be less familiar with, but which have played an important role.”

I did a test run to compare Google Scholar with the conventional search services. I decided to research sexual harassment caselaw in California. On Lexis-Nexis or Westlaw, the search took a prohibitive amount of time and required many steps. First, I had to log on with my username and password. Second, I had to find and select the right database. Third, I had to formulate the correct string of search commands. Fourth, I had to wait a noticeable length of time for the search results. Fifth, I had to wade through a long list of confusing results by clicking on each one, one at a time. Sixth, I had to reformulate my search commands to create a more targeted result. And so on. What an excruciating and time-consuming process. How frustrating waiting for the screen to refresh each time I do something.

On Google Scholar, I merely typed “sexual harassment” into the search window, selected “California cases” in the pulldown menu, and was immediately rewarded with a wealth of highly relevant cases and articles that appeared in the blink of an eye. The results read like the syllabus for a law school class on sexual harassment. Just incredible. Clicking on “related articles” next to a search result or clicking on a result and then selecting the tab “How Cited” takes you to a list of other cases and articles that discuss the case you are looking at. This is useful for quickly familiarizing yourself on the significance of the case, how it has been interpreted, what it means, etc. This is also a great way to quickly learn the key aspects of sexual harassment law in the State of California. Amazing.

To be sure, Google Scholar is not a replacement for Lexis-Nexis or Westlaw. Not yet. The latter offer features which are not included in Google Scholar: 1) expert commentary, case summaries and case indices that remain indispensable to lawyers, 2) case histories which let lawyers know if the case is still valid, has been overturned, criticized, distinguished, etc., 3) a valuable cut and paste function that automatically generates the proper legal citation for the passage you’re cutting and pasting, 4) access to statutes, laws and regulations, 5) properly formatted hardcopy printouts of cases, etc.

However, the possibilities for Google Scholar are endless. One colleague, Carolyn Elefant at MyShingle.com, has already suggested a wiki add-on that would permit Google Scholar users to append their commentary and analysis to individual cases.

I’m truly excited to see what the future holds now that Google is in the cards. In any case, today is a great day. Free and powerful public access to caselaw has at long last truly arrived.

Related posts:

1. Free Access to Federal Cases
2. Free Legal Forms Meet Web 2.0
3. Free Pamphlets on Labor and Employment Laws

1. According to a 2009 Anderson Analytics report, the US has a total population of 305 million. Of that, 187 million are online. Of that, roughly 60%, 110 million, are using social network sites of one form or another. (“New Anderson Analytics Social Media Study – US Social Network Services”).
2. Another 2009 Anderson Analytics report estimates that social networking sites have the following numbers of users: Facebook: 78 million; MySpace: 67 million users; Twitter: 17 million; LinkedIn: 11 million. (“New Social Media Study: Facebook Trumps Other Social Media as Most Valuable; Majority of Users Can’t Do Without Popular Site”).
3. The total minutes spent on Facebook increased from 1.7 billion in April 2008 to 13.9 billion in April 2009. (Nielsen Wire: “Time Spent on Facebook up 700%, but MySpace Still Tops for Video”).

Getting to know people through a social networking site can be fun and rewarding. But as with the rest of the Internet, it comes with risks for the unwary.

According to a 2009 Harris Interactive survey of 2,667 HR professionals, 45% of them said that they go to social networking sites to research job candidates. Another 11% plan to do so soon. (“45% of Employers Now Screen Social Media Profiles”). The study also found 35% of employers decided not to hire a candidate due to content found on their social networking page. Here were some of the big no-nos that HR professionals reported:

1. Posting indiscreet photos and info: 53% of employers won’t hire you
2. Posting activity involving alcohol and/or drugs: 44% of employers won’t hire you
3. Badmouthing former employers: 35% of employers won’t hire you

The trend isn’t limited to just employers. Some lawyers have begun researching social networking sites to gain more information about i) the lawyers on the other side, ii) the parties on the other side, iii) the jurors sitting in on their trials, and even iv) the judges overseeing their lawsuits. While there isn’t any hard data regarding this phenomenon, I have come across a large amount of anecdotal evidence. I have heard tell of other employment lawyers suddenly being confronted by their opponents with damaging, lawsuit-losing information contained in the Facebook pages of their own clients at the most inopportune times.

Some tips to keep in mind for those of you who are Facebooking or MySpacing:

1. Don’t be an oversharer. People have a tendency to reveal far more private details on social networking sites than they ever would in person. Don’t be the “Too Much Information” guy or gal. Err on the side of disclosing less.
2. Don’t hit that submit button too quickly. Always take a second or two to think before you release a picture or a note into the wild. Once it’s out there, chances are you won’t be able to reel it back in.
3. Don’t accept every invitation to connect with someone that comes your way. Think twice before you “friend” an employer, a co-worker, a subordinate, a stranger whose identity you haven’t verified, etc.
4. Do imagine how the information on your page would look to i) a current or potential employer, ii) your co-workers and business acquaintances, iii) the judge and jury if you’re considering a lawsuit, iv) your great-great-grandkids (“Hey kids, look, here’s your great great grandmother lying naked, wrapped around a toilet with a bottle of vodka on her face and obscenities written in permanent marker all over her body”).
5. Do review the privacy settings for your account. Sites like Facebook permit you to decide which pictures and information you will show to which circles of friends and acquaintances.
6. Do a Google search of your name periodically to see what comes up. If something damaging or embarrassing comes up, perhaps it can be repaired.

So do yourself a big favor. If you’re going to share on Facebook or MySpace, do it the smart way. Or you might end up like the woman in the picture above.

Related posts:

1. Fired Chase Manhattan Employee’s Recovery for FMLA Violations Could Exceed $7 Mil.
2. Disabled Employee in San Francisco Wins $350K Judgment

California, and its sister states, Nevada and Oregon, have been especially hard hit by the recession, as can be seen from the graph at right (darker is worse). California is struggling with an unemployment rate that hit 11.6% in June 2009. But California also continues to track the rest of the country toward a bottoming out. In short, we appear to have pulled back from the precipice of the “Greatest Depression”.

At times like this, BusinessWeek reminds us that it is more important than ever to be optimistic. Read “Why It’s Smart To Be Optimistic” (and watch the video) to understand why optimists, or “opportunists”, will be better positioned to seize on the opportunities that have been opened up by a restructured economy. If you’ve come this far, you’ve probably weathered the worst of it. Here’s to sunnier skies for hard-working and can-do Americans like you.

Related posts:

1. Fired Chase Manhattan Employee’s Recovery for FMLA Violations Could Exceed $7 Mil.
2. ‘If you’ve got a job, hang on to it’

Given the current recession/depression we are in, there is more than the usual level of controversy attending the increase. Conservative economists contend the wage increase will only deepen unemployment as employers respond by cutting jobs. Liberal economists contend the wage increase will put more money into consumers’ pockets, leading to $5.5 billion in additional consumer spending over the next 12 months.

So who’s right?

We may never know. NPR interviewed an economist at UC Berkeley, David Card, who noted that a famous study he conducted (studying the impact of a minimum wage increase on New Jersey’s fast-food industry in the 1990s) showed that the wage increase caused no significant change in the total number of jobs. UC Irvine economist David Neumark, however, says not so for the least-skilled workers such as teenagers. He estimated that the wage increase will lead to the elimination of roughly 300,000 jobs for people in the 16-24 year age group.

Related posts:

1. Minimum Wage is Now $8.00 per Hour
2. Minimum Wages around the World
3. Dept. of Labor Fails to Protect Workers: “We have a crisis in wage theft”

On March 25, 2009, the U.S. General Accountability Office issued a 35-page report, entitled “Wage and Hour Division’s Complaint Intake and Investigative Processes Leave Low Wage Workers Vulnerable to Wage Theft” , that chronicles the GAO’s undercover investigation of the Labor Departments Wage and Hour Division (WHD) . The GAO report found that 9 of the 10 complaints lodged by its undercover agents with the WHD were mishandled and:

. . . that the Department of Labor has left thousands of actual victims of wage theft who sought federal government assistance with nowhere to turn. . . . Unfortunately, far too often the result is unscrupulous employers taking advantage of our country’s low wage workers.

The report also found that the WHD mishandled worker complaints by ignoring them, waiting months to process them, lying about progress, closing them and in some cases, simply dropping them. One undercover GAO agent posing as an aggrieved worker was told to hire an attorney and file a private lawsuit instead. In another case involving over 50 minors being used for illegal child labor, the GAO found that the WHD waited over a year after the complaint had been received before beginning an investigation.

Kim Bobo, executive director of Interfaith Worker Justice, a low-wage earner advocacy group, told the New York Times “We have a crisis in wage theft, and the Department of Labor has not been aggressive enough in recent years. . . The new secretary of labor says she’s the new sheriff in town, but I’m concerned she’s facing the wild, wild West of wage theft.” Representative George Miller (D-Cal.), chair of the House Education and Labor Committee and the impetus behind the GAO report, put it even more pointedly, telling the New York Times: “It’s clear that under the existing system, employers feel they can steal workers’ wages with impunity, and that has to change.”

The new U.S. Secretary of Labor, Hilda Solis, certainly has her work cut out for her considering the mess left behind by her Bush administration predecessor, Elaine Chao. Fortunately, Solis’s office wasted no time in responding to the critical GAO report, issuing a press release announcing the hire of 250 new field office investigators, a 33% staff increase . Solis told the New York Times that she took the GAO report’s findings seriously and that the staff increase would “reinvigorate the work of this important agency” .

The next time you hear someone complain that there are too many wage and hour lawsuits, be sure to send them a copy of the GAO’s report. It might open their eyes.

If you or someone you know is being denied overtime payments or meal or rest breaks, forced to work off the clock or below the minimum wage rate, or suffering other wage and hour violations, contact a labor lawyer immediately.

Related posts:

1. California Labor Dept Org Chart
2. 2009 Federal Minimum Wage Increases to $7.25
3. Minimum Wage is Now $8.00 per Hour

The shift in power that will result is hard to overstate. At present, Democratic-appointed judges comprise the majority on only 1 out of 13 federal Circuit Courts of Appeal in the U.S. That court is the 9^th Circuit based in San Francisco, CA. Experts estimate that within the next 4 years, that number could jump to 9 out of 13. The first test for Obama will be the 4^th Circuit based in Richmond, VA. That court has 4 open seats and is currently deadlocked between 5 Republican- and 5 Democrat-appointed judges.

As the article states, judges appointed by Obama can be expected to side more often with “workers, consumers, homeowners, women and people of color who were discriminated against”. In contrast, Bush-appointed judges have generally favored business in employee and consumer disputes.

As the balance of power shifts in the Federal judiciary, it is likely that the number of employee-plaintiffs filing lawsuits in federal rather than state court will start to increase. Plaintiff lawyers typically avoid filing suit in federal court because of the anti-employee bias many federal judges have exhibited. Federal district court judges will likely also begin ruling in a more employee-friendly direction as Democrats being taking spots in the Courts of Appeal that oversee them. It should be an interesting eight, errr, four, years.

Related posts:

1. A Good Jury Duty Experience (For a Change)
2. 2009 Federal Minimum Wage Increases to $7.25
3. Free Access to Federal Cases

If you thought ‘road rage’ was a problem, make way for ‘desk rage’. According to this Reuters report, "Desk rage spoils workplace for many Americans" , anger in the workplace is on the rise. And it isn’t just about ‘going postal’. The article contains some startling statistics – of the workers who responded to research surveys:

1. 2%-3% admitted to pushing, slapping or hitting someone at work – amounting to as many as 3 million people out of a total U.S. workforce of 100 million.
2. Nearly 50% reported yelling and verbal abuse at work
3. One in four admitted to being driven to tears by abusive behavior at work.
4. One in six reported anger-induced property damage occurring at work.
5. One in ten reported physical violence and fear their workplace might not be safe.

The Bureau of Labor Statistics Census of Fatal Occupational Injuries (CFOI) also cites this interesting statistic regarding number of fatal work injuries : In 2006, there were a total of 5,840 fatal workplace injuries. Out of those, 9% were homicides.

Increasing frustration with rising fuel prices and a slowing economy might be one of the reasons for the rise in desk rage. "People are coming to work after a long commute, sitting in traffic watching their discretionary income burn up. They’re ready for a fight or just really upset," said John Challenger of the placement firm Challenger, Gray & Christmas.

Desk rage alone won’t necessarily create legal liability or justify a lawsuit. You can read about one reason why here, in my post "My Boss, the Equal Opportunity Jerk" . If you are physically or mentally injured by behavior in the workplace, you might have a workers’ compensation claim but that’s about it.

However, you DO have a right to a safe environment. If your physical safety is threatened and management does nothing about it, you may have a case. If you make a complaint to management regarding threats to your physical safety and management actually fires or punishes you for complaining, that could be the basis for a wrongful termination or retaliation claim. When in doubt, talk to a lawyer . The initial consultation is usually free.

For more information, also check out the U.S. Department of Labor’s webpage on Safety and Health Topics: Workplace Violence .

Stay safe out there.

No related posts.