APPLIES TO All Employers

EFFECTIVE As Indicated

QUESTIONS? Contact HR On-Call (888) 378-2456

Quick Look Employers cannot deny an employee’s request for a religious accommodation under federal law unless the employer can prove that the requested accommodation would result in substantially increased costs for the employer’s business. Affirmative action in education, not employment, ends. First Amendment speech protections apply to business owners providing expressive products or services, not to employees of private employers or employers’ obligations to comply with anti-discrimination laws.

Discussion

The U.S. Supreme Court recently issued three rulings implicating affirmative action, religious accommodations, and first amendment rights. Some rulings will have a bigger impact on employers than others. We summarize the cases as follows.

Affirmative Action

A pair of cases from the Supreme Court struck down the use of affirmative action in higher education. On June 29, 2023, in Students for Fair Admissions, Inc. v. President and Fellows of Harvard College and Students for Fair Admissions, Inc. v. University of North Carolina, U.S. Supreme Court ruled certain race-conscious college admissions policies violate the Equal Protection Clause of the 14th Amendment. The Equal Protection Clause prohibits discrimination based on race.

Here, the cases were brought by Students for Fair Admission (SFFA), a nonprofit which believes racial preferences in the admissions process is unconstitutional. The SFFA challenged Harvard College’s and the University of North Carolina’s (UNC) race-conscious admissions practices which are on par with the college admissions processes for higher education around the country. While Harvard, as a private college, is not subject to the 14th Amendment prohibition against race discrimination, it is subject to Title VI of the federal Civil Rights Act of 1964 as a federal grant recipient. UNC is subject to both the 14th Amendment and Title VI. Both schools argued they only considered race as a single factor alongside extracurricular activities, socioeconomic backgrounds, and military veteran status.

Ultimately the Court ruled direct consideration of a college applicant’s race in achieving diversity in higher education is unlawful. The Court looked at the then-current precedents of Gratz v. Bollinger and Grutter v. Bollinger which established the affirmative action standards currently used by colleges and universities. Gratz and Grutter ruled race could be considered on an individualized, narrowly tailored basis when the university had a compelling interest in diverse student bodies. Interestingly in Grutter, Justice O’Connor in Grutter stated “25 years from now, the use of racial preferences will no longer be necessary to further the interest approved today.” While the current rulings end existing affirmative action programs, the Court did state “nothing prohibits universities from considering an applicant’s discussion of how race affected the applicant’s life, so long as that discussion is concretely tied to a quality of character or unique ability that the particular applicant can contribute to the university.”

Notably, the rulings have no immediate impact on the legal standards that govern affirmative action and DEI programs in private employment.  The 14th Amendment does not apply to private companies, and it is Title VII of the Civil Rights Act of 1964, not Title VI, that governs discrimination in employment. The different legal frameworks, interpreting cases, and agency guidance, limit the reach of the rulings to private workplaces. Also, affirmative action programs in employment do not mean giving any group priority or preference over another.  Decisions are always to be based on merit alone. Employers cannot use race as a factor in employment decisions, the way higher education could before these rulings. Since affirmative action in employment is not the same as in education, the Harvard and UNC rulings do not directly apply to private employer action.

Religious Accommodation

Under Title VII of the Civil Rights Act, employers must reasonably accommodate all aspects of an employee’s religious observance or practice that can be accommodated without creating an undue hardship for the employer. The long-standing interpretation of what constitutes an “undue hardship” for religious accommodation stems from the Supreme Court’s 1977 decision in Trans World Airlines Inc. v. Hardison, which held that an employer did not have to provide a religious accommodation if the accommodation would impose “more than a de minimis” burden on the business, meaning more than a trivial cost. However, on June 29, 2023, the U.S. Supreme Court redefined this standard, stating that employers can only deny an employee’s request for a religious accommodation under federal law if the employer can prove that the requested accommodation would result in substantially increased costs for the business.

In Goff v. DeJoy, a postal carrier who was unwilling to work on Sundays because of his religious practices sued his employer, the United States Postal Service (USPS), alleging that it could have accommodated his observance of Sunday Sabbath without undue hardship. Initially, at the time the employee started working for the USPS, he was not required to work on Sundays. When USPS agreed to begin making Sunday deliveries for Amazon, the employee was transferred to a smaller USPS station that did not make deliveries on Sundays. However, when his smaller station also began making Sunday deliveries for Amazon, the employee’s assigned deliveries were redistributed to other workers and he was disciplined for continuing to refuse to work on Sundays. Because of this, he eventually resigned from his employment.

In reviewing the standard for denying religious accommodations under Title VII, the Supreme Court focused on the plain meaning of the term “undue hardship,” reasoning that a “hardship” is, at a minimum, “something hard to bear,” and that a hardship only becomes “undue” when it rises to an “excessive” or “unjustifiable” level. Based on these interpretations, the Supreme Court determined the appropriate burden for demonstrating that an accommodation poses an “undue hardship” requires much more than a de minimis or trivial cost for the employer. Instead, the Supreme Court stated that, in order to deny a requested religious accommodation, an employer must show that the accommodation would result in substantial costs to the overall context of the employer’s business.

The Supreme Court declined to state what specific facts would meet this heightened requirement, leaving it up to the lower courts to determine on a case-by-case basis. That said, the Supreme Court’s ruling does clarify that, in reviewing all relevant factors, employers may point to additional workplace burdens on co-workers and other employees as part of demonstrating an undue hardship, in addition to considering other accommodation options, but only to the extent that those impacts are connected to the conduct of the particular business and not tied to religious animosity.

First Amendment

On June 30, 2023, in 303 Creative, LLC v. Elenis, the Supreme Court said that the State of Colorado could not force a business providing goods and services to the public to provide “expressive” goods and services that are contrary to the beliefs of the owner of the business. As is common among most states, Colorado prohibits businesses from engaging in discrimination when they sell goods and services to the public.

Here, a limited liability company, whose owner was the sole employee, provided website design services and was looking to start creating wedding websites for the public. However, the business preemptively sued the state before offering wedding websites to the public because the owner allegedly held a sincere religious belief that marriage is only between a man and a woman and did not want to create wedding websites for same-sex couples. The parties to the lawsuit agreed that what the website’s owner would design and produce was “pure speech,” and that every website will be her “original, customized” creation. Additionally, the parties agreed that the business owner “will gladly create custom graphics and websites for gay, lesbian, or bisexual clients or for organizations run by gay, lesbian, or bisexual persons so long as the custom graphics and websites” themselves do not violate her beliefs. As such, this case should be viewed in the context of these circumstances.

The Court acknowledged that states may still protect “gay persons” and require businesses not to discriminate against them in providing public accommodations. However, the First Amendment does not allow states to compel speech in the context of expressive activity. Moreover, while the First Amendment does not protect status-based discrimination unrelated to expression, generally it does protect a speaker’s right to control their own message. The Court likened website publishing to any other medium used for expressive activity, e.g., books, videos, movies, newspapers, art, speech writing, etc. The Court further indicated that the First Amendment applies to “speakers whose motives others may find misinformed or offensive.”

While this case touches on a sensitive topic, the decision does not involve employment law.  Specifically, this ruling did not change employers’ obligations to prohibit discrimination and harassment against employees or employers’ ability to require employees to attend non-discrimination trainings. Moreover, the ruling does not change the fact that the First Amendment does not apply to employees of private employers. Further, this ruling does not eliminate a state’s ability to enforce its anti-discrimination laws.

Action Items

1. Review any desire to deny a religious accommodation with legal counsel to ensure that the heightened standard for undue hardship is met.
2. Have appropriate personnel trained on the requirements for reviewing religious accommodation requests.
3. Ensure that policies and procedures are consistent with religious accommodation standards.
4. Subscribers can call our HR On-Call Hotline at (888) 378-2456 for further assistance.

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Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2023 ManagEase

APPLIES TO All Employers with NY Employees

EFFECTIVE February 27, 2023

QUESTIONS? Contact HR On-Call (888) 378-2456

Quick Look There is a plausible claim that New York’s “Boss Bill” significantly interferes with an employer’s 1st Amendment right to expressive association therefore litigation can continue on this claim. The Boss Bill prohibits employers from taking adverse actions against employees for their reproductive health decisions or accessing an employee’s personal information regarding their reproductive health decision making.

Discussion

In Slattery v. Hochul, the Second Circuit Court of Appeals ruled there was a plausible claim that New York’s “Boss Bill” significantly interferes with an employer’s First Amendment right to expressive association; therefore, litigation can continue on this claim. Effective November 8, 2019, the Boss Bill or Labor Law § 203-e prohibits employers from taking adverse actions against employees for their reproductive health decisions or accessing an employee’s personal information regarding their reproductive health decision making. This includes an employee’s decision to use or access a particular drug, device, or medical service like a decision to have an abortion or use contraception.

Here, a crisis pregnancy center and its president argued the Boss Bill violated their First and 14^th Amendment rights to freedom of expressive association and sought an injunction prohibiting New York from enforcing the law and declaring it unconstitutional. Since the crisis pregnancy center is opposed to abortion and only hires people who share its same views on abortion, premarital sex, and use of contraception, it alleged the Boss Bill violated its speech, association, and religious rights by forcing the center to associate with employees that contradict its central message. The U.S. District Court for the Northern District of New York dismissed all of the claims. On appeal, the Second Circuit Court agreed with the dismissal of three claims but allowed the First Amendment expressive association claim to continue to litigation.

The case is still in litigation, and as of yet we do not know what impact a ruling will ultimately have on the Boss Bill. The Second Circuit Court stated the Boss Bill severely burdened the pregnancy crisis center’s ability to communicate its message by forcing an association with employees who do not share its views. Employers should continue monitoring developments in the litigation of the remaining claim in the event it ultimately changes the enforcement of the law. For now, employers must still comply with the Boss Bill.

Action Items

1. Review adverse actions against employees for reproductive healthcare decisions with legal counsel.
2. Subscribers can call our HR On-Call Hotline at (888) 378-2456 for further assistance.

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Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2023 ManagEase

APPLIES TO All Employers with CA Employees

EFFECTIVE May 22, 2023

QUESTIONS? Contact HR On-Call (888) 378-2456

Quick Look Whistleblowers are protected from retaliation regardless of whether the employer or agency already know about the alleged violation.

Discussion

In People ex rel. Garcia-Brower v. Kolla’s Inc., the California Supreme Court said that employers can be liable for retaliating against whistleblowing employees, even if the alleged violation is not new to the employer or agency to which it is reported. California prohibits employers from retaliating against whistleblowing employees for disclosing information about suspected violations of law. Previously, “disclosure” was interpreted to mean a new violation that the employer or agency did not already know about. However, the Court determined that the protection applies regardless of whether the employer or agency already knows about the alleged violation.

Here, an employee informed the employer of unpaid wages; the employer then terminated the employee in response. The lower courts said there was no whistleblower protection because the employer already knew that it had not paid the employee’s wages. However, the California Supreme Court said that a “disclosure” can occur “without regard to whether the recipient already knew of the violation.” This interpretation is consistent with the federal Whistleblower Protection Enhancement Act, which says that an employee’s whistleblowing disclosure is protected even if the violation is already known.

Action Items

1. Have appropriate personnel trained on whistleblowing procedures and employee protections.
2. Review adverse employment action against whistleblowing employees with legal counsel.
3. Subscribers can call our HR On-Call Hotline at (888) 378-2456 for further assistance.

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Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2023 ManagEase

APPLIES TO Employers with Employees in CO

EFFECTIVE As Indicated

QUESTIONS? Contact HR On-Call (888) 378-2456

Quick Look Employees of private employers who are members of the Colorado National Guard or military reserve forces are entitled to the equivalent of three weeks of leave in a calendar year. Employer premium rate for unemployment insurance is reduced by 10% for all rates in the standard premium rate schedule. The POWR Act amends Colorado’s Anti-Discrimination Act by broadening the definition of harassment, providing for certain employer affirmative defenses to harassment claims, adding marital status as a protected classification, clarifying accommodation standards for disabled employees, restricting the use of non-disclosure agreements, and expanding applicable recordkeeping requirements. Colorado’s Healthy Families & Workplaces Act is amended to provide for three additional qualifying reasons for employee paid sick leave. Colorado’s Equal Pay for Equal Work Act is amended to include expanded transparency requirements related to job opportunities, clarification on internal transparency requirements for in-line promotions, a new limited exemption for certain employers with no physical Colorado presence, additional notice requirements for employer disclosures, and an expanded enforcement and statute of limitations provision. Colorado’s Job Application Fairness Act prohibits employers from inquiring about a job applicant’s age, date of birth, and dates of attendance at or graduation from an educational institution during the hiring process, subject to limited exceptions.

Discussion

Through its 2023 legislative session, Colorado has passed several laws that either create new rights for employees or substantially amend existing laws that affect employee rights. Some changes have already gone into effect, where others will become effective as soon as August 7, 2023, so employers should work to revise their policies and practices immediately.

Military Leave – As of March 10, 2023 and under HB 23-1045, Colorado clarified that employees of private employers who are members of the Colorado National Guard or military reserve forces must be permitted to take the equivalent of three weeks off work, as compared to 15 days, in a calendar year for military training. During this leave, the employee must be able to use any paid leave or unpaid leave available to the employee.

Unemployment Insurance – As of May 1, 2023, SB 23-232 reduced the employer premium rate by 10% for all rates in the standard premium rate schedule in accordance with the Federal Unemployment Tax Act. Employers are no longer required to submit premium payment reports; however, employers must now submit wage reports.

Protecting Opportunities and Workers Rights Act – Colorado’s Protecting Opportunities and Workers Rights (POWR) Act will have significant impacts on the enforcement of the Colorado Anti-Discrimination Act (CADA). The POWR Act imposes a broader definition of harassment sufficient to constitute unfair practice and discrimination, creates new requirements for nondisclosure agreements, and imposes new recordkeeping requirements. Beginning August 7, 2023, the following changes to CADA will be effective under the POWR Act:

• Harassment Definition – “Harassment” constituting discrimination will be added as an option on charge forms as a violation under CADA. To constitute “harassment,” the challenged conduct will need to be subjectively offensive to the individual alleging harassment and objectively offensive to a reasonable person of the same protected class. This new definition departs from the previous “severe and pervasive” standard, representing a broader definition of what conduct may constitute harassment or unfair practices. Harassment will still need to meet one of the following to constitute discrimination: (A) submission to the conduct or communication must be explicitly or implicitly made a term or condition of the individual’s employment; (B) submission to, objection to, or rejection of the conduct or communication must be used as a basis for employment decisions affecting the individual; or (C) the conduct or communication must have the purpose or effect of unreasonably interfering with the individual’s work performance or must create an intimidating, hostile or offensive work environment. All harassment claims are reviewed based on the totality of the circumstances, and the amendments contain a list of factors to consider in the analysis.
• Affirmative Defenses for Harassment Claims – Under POWR, an employer may assert an affirmative defense to a harassment claim if the employer must establish that it has a program in place that is reasonably designed to prevent harassment, deter future harassers, and protect employees from harassment. To show a program is sufficient under this standard, and employer must demonstrate that: (A) the employer takes prompt and reasonable action to investigate or address the alleged employment practices; (B) the employer takes prompt and reasonable remedial actions in response to complaints of discriminatory or unfair employment practices (when warranted); (C) the employer communicates the existence and details of the program to employees (whether supervisory or non-supervisory); and (D) the employee unreasonably fails to take advantage of said program.
• Marital Status as a Protected Class – Under POWR, marital status has been added as a protected classification under CADA, meaning employers cannot take any adverse action against an employee based on marital status.
• Clarification on Disability Discrimination – The POWR Act amends CADA to clarify that it is not a discriminatory or unfair practice for an employer to discharge, promote or demote, or refuse to hire an individual with a disability only whenthere is no reasonable accommodation that would allow the individual to satisfy the essential functions of the job and the disability actually disqualifies the individual from the job.
• Nondisclosure Agreements – The POWR Act voids new and renewed nondisclosure agreements that limit an employee’s or prospective employee’s ability to discuss or disclose alleged discriminatory or unfair employment practices unless the agreement contains certain provisions. If employers violate the restrictions, employees may sue and recover a penalty of $5,000 for each violation, in addition to actual damages, reasonable costs, and attorneys’ fees. To be compliant, any nondisclosure agreement seeking to limit discussions or disclosures of discriminatory or unfair employment practices must contain all of the following: (1) the provision must apply equally to the employer and the employee; (2) the provision must include an express statement that it does not limit the employee from disclosing the underlying facts of the alleged discrimination or unfair employment practice, including in a settlement agreement, to certain individuals such as immediate family members and attorneys, government agencies, in response to a subpoena, and as otherwise required by law; (3) the agreement must include an express statement that disclosure of the underlying facts of the alleged discrimination or unfair employment practice will not constitute disparagement; (4) the agreement must include a condition stating that if the agreement contains a non-disparagement provision and the employer disparages the employee, the employer may not seek to enforce the non-disparagement or non-disclosure provisions or seek damages against the employee; (5) any liquidated damages provisions, if included, may not constitute a penalty or punishment and the amount must also be reasonable, proportionate, varied based on the severity of the breach, and not punitive; and (6) the agreement must include an addendum attesting to the compliance with each of these requirements. The addendum must be signed by all parties to the agreement.
• Record-Keeping Requirements – Under POWR, employers are required to preserve personnel or employment records for at least five (5) years after either (1) the date the employer made or received said record, or (2) the date of the personnel action that the record pertains to or the final disposition of a charge of discrimination or any related action, as applicable. Employers must also maintain an “accurate, designated repository” of all writtenor oral complaints of “discriminatory or unfair employment practices.” These records must include the date of the complaint, the identities of the complainant and the perpetrator (if disclosed), and the substance of the complaint.

Paid Sick Leave – Effective August 7, 2023, employees will be entitled to use paid sick leave under Colorado’s Healthy Families & Workplaces Act for three new reasons (in addition to those already in effect). Specifically, SB 23-017 permits employees to also take paid sick leave (1) to grieve, attend funeral services or a memorial, or deal with financial and legal matters that arise after the death of a family member; (2) to care for a family member whose school or place of care has been closed due to inclement weather, loss of power, loss of heating, loss of water, or other unexpected events; and (3) to evacuate the employee’s place of residence due to inclement weather, loss of power loss of heating, loss of water or other unexpected events.

Colorado Equal Pay for Equal Work Act & Pay Transparency – SB 23-105 brings several changes to the Colorado Equal Pay for Equal Work Act (CEPEWA), as outlined below. These amendments become effective on January 1, 2024.

• Expanded Transparency Requirements – Amendments to CEPEWA under SB 23-105 expand an employer’s obligation to provide notice related to each job opportunity’s compensation, benefits, and application closing date. Specifically, the amendments expand the notification requirement beyond providing the required information for all external job postings (i.e., hourly rate or salary range, description of benefits, and closing date), and require employers to disclose such information in other situations when an employer begins discussions about hiring for a vacant or soon to be vacant position with potential recruits, even in situations where the employer does not externally post an opening. Additionally, employers must “announce, post, or otherwise make known each job opportunity to all employees on the same calendar day and prior to the date of which the employer makes a selection decision.”
• Clarification on In-Line Promotional Postings – The amendments clarify an employer’s obligation to post internally about in-line promotional opportunities. Specifically, employers only need to internally make the disclosures described above for “job opportunities,” which specifically excludes when an employee’s role changes because of (1) a “career development” change (i.e., a change to an employee’s terms of compensation, benefits, full-time or part-time status, duties, or access to further advancement in order to update the employee’s job title or compensate the employee to reflect work performed or contributions already made by the employee), or (2) a “career progression” change (i.e., a regular or automatic movement from one position to another based on time in a specific role or other objective metrics). However, if a company position involves career progression, employers must disclose and make available to all eligible employees the requirements for career progression for the role (in addition to compensation, benefits, full- or part-time status, duties, and access to further advancement).
• New Limited Exemption for Out-of-State Employers – Under the amendments, theCEPEWA now provides that, through July 1, 2029, employers with physical locations exclusively located outside of Colorado and less than 15 Colorado-based employees whom all work remotely will only need to provide notice for remote job opportunities.
• Additional Employee Notice Requirements – The amendments require that, within 30 days after an employer selects a candidate for an open position, the employer must disclose the following information to employees who regularly work with the selected candidate: (1) the name of the selected candidate; (2) the selected candidate’s former job title; (3) the selected candidate’s new job title; and (4) how employees can apply for similar jobs in the future.
• Updated Statute of Limitations and Enforcement – The amendments expand the CEPEWA’s statute of limitations from three (3) to six (6) years, as well as require the Colorado Department of Labor (CDLE) to create a process to investigate and mediate claims of sex-based wage discrimination.

Job Application Fairness Act – Beginning July 1, 2024, Colorado’s Job Application Fairness Act (JAFA), prohibits employers from inquiring about a job applicant’s age, date of birth, and dates of attendance at or graduation from an educational institution during the hiring process. JAFA’s restrictions apply only “at the time of an initial employment application,” mirroring the limitations on inquiring as to criminal histories under the Colorado Chance to Compete Act. There are some limited exceptions to JAFA’s requirements, in instances where age needs confirmation for occupational qualification, or where such information is required under federal, state, or local law. The law does not maintain a private right of action; however, aggrieved individuals have one year to submit a complaint to the CDLE. Upon finding a violation, the CDLE will order compliance within 15 business days and assess a civil penalty increasing in severity with each subsequent violation (up to $2,500). A violation is determined based on the application not the number of individuals that have applied using the noncompliant application.

Action Items

1. Implement policies and procedures for state-required military leave.
2. Review and update unemployment insurance reporting procedures to be consistent with updated reporting requirements.
3. Update anti-discrimination and harassment policies to account for revised definition of harassment.
4. Update anti-discrimination policies to account for marital status protected classification.
5. Have appropriate personnel trained on disability accommodation requirements.
6. Review applicable nondisclosure agreements with legal counsel.
7. Implement or review policies and procedures for state-required paid sick leave to account for additional qualifying reasons.
8. Review and revise job postings and job descriptions pursuant to updated pay transparency requirements.
9. Have appropriate personnel trained on updated pay transparency requirements.
10. Review and update application and recruiting practices to comply with restrictions under JAFA.
11. Subscribers can call our HR On-Call Hotline at (888) 378-2456 for further assistance.

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Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2023 ManagEase

APPLIES TO Employers with FL Employees

EFFECTIVE June 1, 2023

QUESTIONS? Contact HR On-Call (888) 378-2456

Quick Look Florida employers cannot require proof of vaccination status or post-infection recovery, or otherwise discharge, discipline, demote, or discriminate against individuals because of their vaccination or immunity status. Florida employers cannot mandate or require masks in order to gain entry to the employer’s facilities.

Discussion

Florida has passed legislation that protects individuals from discrimination on the basis of their “healthcare choices,” prohibiting certain COVID-19 related mandates. Specifically, Florida employers are prohibited from: (1) requiring individuals to provide proof of vaccination (e.g., vaccination passports) or post-infection recovery (e.g., proof of negative testing) from any disease to gain access to, entry upon, or service from such entities; (2) refusing employment to or discharging, disciplining, demoting, or otherwise discriminating against an individual solely on the basis of vaccination or immunity status; and (3) mandating or requiring masks in order to gain entry to their facilities. Under the new law, Florida employers are prohibited from mandating the COVID-19 vaccine or any other vaccine under “emergency use authorization.”

Certain limited exceptions exist for the prohibition on mandated face coverings, specifically for healthcare providers or practitioners. The Florida Department of Health (DOH) and the Agency for Health Care Administration have jointly developed standards for the “appropriate use of facial coverings for infection control,” which were released on July 3, 2023. Employers in the healthcare industry must create and post standards that conform to the DOH’s guidelines by August 1, 2023.

Action Items

1. Review the bill here.
2. Have policies and procedures updated for compliance.
3. Implement face covering standards if in the healthcare industry by the August 1, 2023 deadline.
4. Subscribers can call our HR On-Call Hotline at (888) 378-2456 for further assistance.

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Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2023 ManagEase