BILL ANALYSIS                                                                                                                                                                                                    






                       SENATE JUDICIARY COMMITTEE              S   
                      Charles M. Calderon, Chairman            B
                         1995-96 Regular Session
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SB 258 (O'Connell)
As amended on June 12, 1995
Hearing date:  June 13, 1995
Business and Professions Code
GEH:cb


                            HOME INSPECTORS
                           STANDARD OF CARE
                       UNFAIR BUSINESS PRACTICES
                 CONTRACTUAL LIMITATIONS ON LIABILITY

                                 
                               HISTORY


Source:  California Association of Realtors

Related Pending Legislation:  AB 530 (Weggeland)

Prior Business and Professions Committee Action:  6-0

Prior Judiciary Committee Action: 

    This bill was heard on June 6th, but as a result of author's  
    amendments offered in committee, the bill was sent out to print  
    and back on file without a vote.

    The author's amendments deleted the provision measuring the  
    standard of care by the standards of industry trade groups,  
    replacing it with intent language.  The amendments also modified  
    the language of the prohibition against liability limitation  
    clauses, and made technical amendments suggested in the last  
    committee analysis. 


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                              KEY ISSUES

1.   SHOULD A STANDARD OF CARE FOR HOME INSPECTORS BE FIXED IN  
     STATUTE?

    A.       IS THERE A NEED FOR LEGISLATION CREATING A STANDARD OF  
         CARE?




































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    B.       SHOULD THE STANDARD OF CARE BE THAT OF A "REASONABLY  
         PRUDENT HOME INSPECTOR?"

    C.       SHOULD THE LEGISLATURE EXPRESS ITS INTENT THAT COURTS  
        MAY  CONSIDER STANDARDS SET BY PRIVATE HOME INSPECTOR  
        INDUSTRY  ASSOCIATIONS? 

2.   SHOULD STANDING TO BRING SUIT BASED ON A HOME INSPECTION REPORT  
     BE LIMITED TO PARTIES ORDERING OR PAYING FOR THE REPORT, AND TO  
     PARTIES WHO WERE NAMED OR INTENDED BENEFICIARIES OF THE REPORT?

3.   SHOULD CONTRACTUAL PROVISIONS WHICH WAIVE A HOME INSPECTOR'S  
     DUTY OF DUE CARE OR WHICH OTHERWISE UNREASONABLY LIMIT  LIABILITY  
    BE DECLARED INVALID AS CONTRARY TO PUBLIC POLICY?

4.   SHOULD A LIST OF PRACTICES BY HOME INSPECTORS WHICH RAISE  
     QUESTIONS OF CONFLICT OF INTEREST BE PROHIBITED AS "UNFAIR  
     BUSINESS PRACTICES?"

5.   SHOULD REGISTERED ENGINEERS, LAND SURVEYORS, OR LICENSED  
     ARCHITECTS ACTING PURSUANT TO THEIR PROFESSIONAL REGISTRATION  OR  
    LICENSE BE EXEMPTED FROM ALL PROVISIONS OF THIS BILL? 

6.   SHOULD THIS BILL NOT AFFECT THE DUTY OF REALTORS TO DISCLOSE  THE  
    CONDITIONS OF THE PROPERTY?



                               PURPOSE

The purpose of this bill is to provide a number of statutory  
protections for consumers who contract with home inspectors.

Home inspectors are persons who conduct physical examinations of  
residential property in order to inform potential buyers about  
whether there are any defects in the property.  Some home inspectors  
are licensed engineers, land surveyors, architects, etc., but most  
are not.  

 Under existing law, Sections 1102  et.  seq. of the Civil Code,  
sellers of residential real property must make a number of listed  


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disclosures to prospective buyers about the condition of the  
property.  Under both these sections and Section 2079 of the Civil  
Code, real estate agents and brokers have a duty to conduct a  
reasonably competent and diligent visual inspection of the property,  
and to disclose all facts materially affecting the value or  
desirability of the property.

Under Section 1102.4, sellers, brokers and agents cannot be held  
liable for failing to disclose a defect of which they had no  
personal knowledge if they deliver a report or opinion prepared by 
a licensed engineer, land surveyor, geologist, structural pest 

































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control operator,  or other experts, dealing with matters within the  
scope of that person's license or expertise. 

Engineers, architects, land surveyors, general contractors and pest  
control operators must obtain licenses or professional  
registrations, and they must conduct their professional activities  
in accordance with various statutes and regulations.  

There are no licensure, certification, or registration requirements  
for home inspectors; nor are there any other statutes or regulations  
specifically governing the activities of home inspectors. 

It is possible that certain questionable practices by a home  
inspector could be actionable under Sections 17200,  et.  seq. of the  
Business and Professions Code, which provide for actions for  
injunctive relief and civil penalties against persons engaging in  
acts of "unfair competition."  Unfair competition includes any  
unlawful, unfair or fraudulent business act or practice and unfair,  
deceptive, untrue or misleading advertising. 

There is no reported California case law specifically addressing the  
duties of home inspectors.  There are reported cases from other  
states which have held home inspectors liable for damages caused by  
failure to identify defects. (See comment 1 below).

 Proposed legislation

 Standard of care:  The bill defines "home inspection" as a  
noninvasive, physical examination performed for a fee in connection  
with a transfer of residential property with one to four units,  
designed to identify "material defects" in the systems, structures  
and components of the dwelling.  

The bill provides that a defect is "material" if it significantly  
affects the value, desirability, habitability, or safety of the  
dwelling.  

The bill defines a "home inspection report" as a written report  
prepared for a fee and issued after a home inspection, which clearly  
describes and identifies any material defects and recommendations  
regarding conditions observed.  
 


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The bill provides that it is the duty of a home inspector who is not  
a a licensed contractor, pest control operator, architect or  
engineer to conduct a home inspection which identifies all the  
material defects of the property which can be identified through an  
inspection conducted with the degree of care that a  reasonably  
 prudent home inspector would exercise.  This does not preclude a  
home inspector from explicitly excluding matters from the home  
inspection report.

The bill states that it is the intent of the legislature that, in  
ascertaining the degree of care, a court may consider the standards  
of practice and code of ethics of the California Real Estate  
Inspection Association or the American Society of Home Inspectors,  
or other nationally recognized home inspection association.

 Standing to sue:  The bill provides that a legal action arising from  
a home inspection report may be maintained only by the party  
ordering the report, the party paying for the report, a party named  
in the report as a beneficiary of the report, or an intended  
beneficiary of the report.   
 
 Contractual limitations on liability:  The bill declares that  
contractual provisions that purport to waive the duty created by  
this bill or otherwise unreasonably limit a home inspector's  
liability, such as limiting liability to the cost of the report, are  
contrary to public policy and invalid.

 Specified unfair business practices:  The bill provides that the  
following practices by home inspectors are "unfair business  
practices":

1.  Performing or offering to perform for an additional fee repairs  
    to a structure which has been inspected by the inspector.

2.  Inspecting any property in which the inspector has any financial  
    interest.

3.  Offering an inducement to the owner of the inspected property  
    for the referral of business to the inspector.

4.  Entering into a contract to perform an inspection if the  
    employment or the payment is contingent upon the results of the  


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    inspection, preestablished findings, or the close of escrow.

 Exemption for licensed engineers, architects, and land surveyors:   
The bill exempts from all of its provisions registered engineers,  
licensed land surveyors, and licensed architects acting pursuant to  
their professional registration. 

The bill provides that it does not allow home inspectors who are not  
registered engineers to perform any analysis that would constitute  
the practice of civil, electrical, or mechanical engineering, and  
that it does not exempt a home inspector from the Professional  
Engineers Act, the Contractors' State License Law, and from the laws  
governing architects and structural pest control operators.

 Effect on realtor disclosure obligations:  The bill provides that it  
does not affect the obligations of a real estate licensee or  
transferor of real property to make the disclosures required by  
Sections 1102  et.  seq. of the Civil Code, or to conduct the  
reasonably diligent inspection required by Section 2079 of the Civil  
Code.



                               COMMENT

1.   Fixing a statutory standard of care for home inspectors

    a)       Is there a need for a statutory standard of care?      

            The sponsors of this legislation, the California  
        Association of Realtors (CAR), point out that an  
        increasingly significant percentage of the 500,000 persons  
        who purchase existing homes each year are relying on reports  
        prepared by home inspectors.  

            CAR argues that, because no statutory standards exist  
        for home inspectors, incompetent or unscrupulous home  
        inspectors can cause prospective home buyers to make a  
        decision with economically disastrous consequences.

            Last year, CAR sponsored AB 2780 (O'Connell), which  
        would have provided for state certification of home  


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        inspectors by a new certification agency created by the  
        bill.  That bill was defeated on the Senate Floor, and this  
        bill is an attempt to accomplish the same consumer  
        protection purpose without creating a new state  
        certification program.
       
            The purpose of the provision in this bill which  
        establishes a statutory standard of care is to clarify that  
        home inspectors who negligently prepare a home inspection  
        report may be sued for damages arising from the negligent  
        preparation of that report. 

            Specifically, the bill intends to allow a suit against a  
        home inspector who negligently fails to identify in his or  
        her report a "material defect" -- a defect which  
        significantly affects the value, desirability, habitability  
        or safety of the dwelling, and which can be identified by a  
        noninvasive physical examination of the property's systems  
        and components.

            Because of the case law cited below, it is not clear  
        that legislation is needed to ensure that victims of a  
        negligent home inspection can sue for damages.  

            There are no reported California cases addressing the  
        issue of whether a home inspector may be sued for damages  
        arising from a failure to identify material defects.   
        However, there are California cases allowing suits against  
        pest control inspectors for failure to identify infested  
        areas.   Wice v. Schilling (1954) 124 Cal.App.2d 735 (fraud);  
         Seelenfreund v. Terminix (1978) 84 Cal.App.3d 133 (negligent  
        breach of oral contract).  

            There are many cases from other states in which suits  
        against home inspectors have been allowed on the basis of  
        common law causes of action which are recognized by  
        California courts. 
            
            For example, in April of this year, the Arkansas Supreme  
        Court upheld a constructive fraud action against a home  
        inspector who made negligent misrepresentations in a home  
        inspection report.  Quinney v. Pittman (Ark. 1995) 895 S.W.2d  


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        538.  In February of this year, the West Virginia Supreme  
        Court upheld a jury verdict finding that a home inspector  
        was not negligent, but the court stated that a reasonable  
        jury could have found the home inspector to be negligent and  
        therefore responsible for damages.  Eblin v.  Coldwell Banker  
        (W.Va. 1995) 455 S.E.2d 774.    

            There are also cases on home inspector liability from  
        Connecticut, Illinois, Delaware, Indiana, Wisconsin, and  
        Maryland.  Some of these cases hold home inspectors liable  
        for damages, and some of them state that home inspectors can  
        be held liable for damages for failure to disclose defects,  
        even though the court did not find the home inspector liable  
        in the particular case.  These cases have based potential  
        liability on various common law causes of action, including  
        breach of contract, ordinary negligence, negligent  
        misrepresentation, constructive fraud, and fraud.  See  
         Sorkin v. Schuck (1995) 1995 Conn. Super. LEXIS 1281;  
         Mitchell v. Skubiak (1993) 618 N.E.2d 1013;  Freeman v.  
         Yetter (1993) 1993 Del. Super. LEXIS 435;  A.B.C. Home &  Real  
        Estate Inspector v. Plummer, (Ind. App. 1986) 500 N.E.2d  
        1257;  Edwards v. Lee (Wis. App. 1988) 437 N.W.2d 236;  Baker  
        v. Haas (Md. App. 1993) 629 A.2d 1317.   

            Since the home inspection industry has blossomed only in  
        the last decade, most of these cases have been decided in  
        the last few years.  There is no reason to believe that  
        California courts will not follow suit when such cases reach  
        them. 

            Although it does not appear necessary to statutorily  
        clarify that home inspectors owe a duty of care, it is  
        probably not harmful to do so.  Placing the duty in statute  
        might produce more consistent case law interpretations than  
        would be the case without statutory guidance.

    b)       Should the standard of care be that of a reasonably  
        prudent  home inspector?

            In determining whether a defendant is negligent, courts  
        determine whether the person has exercised the degree of  
        care which would have been exercised by a reasonably prudent  


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        person would under the same or similar circumstances.  If  
        the defendant possesses special skills or knowledge, courts  
        look at the degree of care which would be exercised by a  
        reasonably prudent person possessing that 








































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    special skill or knowledge.  See Witkin, 6  Summary of  California  
    Law, Sec. 750,  et.  seq; and Prosser,  Law of  Torts, Sec. 32.   

            If the defendant is a professional, courts generally  
        apply a higher standard of care -- they determine if the  
        person has exercised the degree of care exercised by the  
        average member of that profession in good standing, although  
        courts have employed a myriad of different formulations of  
        both this standard, and the standard for non-professionals.   
        Courts generally hold that it is necessary to produce  
        evidence from expert witnesses to establish whether  
        particular conduct breached a professional standard of care.  
         See Witkin,  supra, at Secs. 774 and 804; and Prosser,  supra  
        at Sec. 32.   

            The sponsors of this measure have borrowed language from  
        the laws governing real estate licensees which impose on  
        such licensees a duty to exercise the degree of care that a  
        "reasonably prudent real estate licensee would exercise," as  
        measured by the statutory requirements for such licensees.  
        (Civil Code Section 2079.2.)  This is essentially a  
        professional standard of care.   
            
            At least one court has rejected applying a professional  
        standard of care to home inspectors, and to requiring expert  
        testimony concerning the standard of care.  In  Blumm  v.  
        Housemaster of America 1992 Conn. Super. LEXIS 703, the  
        court held that, because the home inspector defendant was  
        not a licensed professional, and had only undergone a  
        one-week home inspection training program, the professional  
        standard of care was inappropriate.  

            Instead, the court held that the appropriate standard of  
        care was that "of a reasonably prudent person in the  
        business of housing inspection identifying what the  
        defendants held themselves out as capable of identifying and  
        reporting on."  The court held that the inspector had failed  
        to meet this standard of care.

            It may not be appropriate for a professional standard of  
        care to be applied to unlicensed home inspectors.   
        Professional standards of care assume that there is a  


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        well-established set of high standards to which members of  
        the profession hold themselves.  Although the sponsors claim  
        that the standards of conduct set by the two trade  
        organizations referenced in the bill constitute such  
        professional standards, this has been disputed by the  
        engineering groups opposed to this bill. (See comment "1c"  
        below.)  

            Although professional standards of care are ordinarily  
        considered to be more demanding standards, if the profession  
        has not set high standards for itself, the professional  
        standard may be less rigorous than the general reasonably  
        prudent person standard.  In other words, it is possible for  
        an entire profession to act negligently.

            In the end, the difference between the various possible  
        formulations of the standard of care may be no more than  
        semantics.  

    c.       Legislative intent that courts consider standards set by  
         home inspector trade groups

            Prior to the latest set of amendments, the most  
        controversial provision of this bill was the one stating  
        that the reasonably prudent home inspector standard of care  
        shall be "measured by the degree of knowledge, education,  
        experience, and examination required to obtain qualification  
        as a home inspector" by either of two home inspector trade  
        association.          

            The latest amendments delete this provision, and instead  
        state in legislative intent language that courts may  
        consider the standards set by these trade organizations in  
        determining the standard of care.

            The opponents of this bill have argued that these home  
        inspector industry groups have imposed "no educational  
        requirements or meaningful experience prerequisites for  
        receiving certification", and that the groups do not have  
        any disciplinary system. 
     
            Even without the intent language in this bill, courts  


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        would probably consider these trade organization standards.   
        In  Eblin,  supra, the West Virginia Supreme Court upheld a  
        directed verdict in favor of a home inspector because the  
        inspector had complied with ASHI standards.  See also  
         Freeman,  supra.  However, in  Edwards,  supra, a Maryland  
        state appellate court found a home inspector to be negligent  
        despite the fact that he had conducted the inspection in  
        accordance with ASHI standards.  In  Blumm,  supra, the court  
        seem to indicate that, because the defendant home inspector  
        was not a member of ASHI, his conduct should not be measured  
        by the ASHI standards.

            Specific statutory reference to the ASHI and CREIA  
        standards, even in intent language, could be interpreted by  
        courts to require them to give special deference to these  
        standards, rather than merely considering them, which they  
        would do without any statute.  

2.   Limiting standing to intended beneficiaries of the report

    Having established that home inspectors owe a legal duty to act  
    like reasonably prudent home inspectors, the bill next addresses  
    the question of  to whom this duty is owed.  Under the bill, this  
    duty would be owed only to parties ordering or paying for the  
    report, and to named or intended beneficiaries of the report.  

    This duty limitation was inserted into this bill at the request  
    of the home inspector organizations which support the bill.  The  
    limitation is designed to address the following situation:  
    prospective buyer #1 hires a home inspector, and the report is  
    delivered to both prospective buyer #1 and the seller.   
    Prospective buyer #1 backs out of deal, and seller gives a copy  
    of report to prospective buyer #2.  The home inspectors do not  
    want to be held liable to prospective buyer #2, because they  
    don't want people to rely on reports without paying for them.  

    To determine how this bill's duty limitation compares to  
    existing law, one must analyze each of the different causes of  
    action which could be brought against a home inspector, because  
    the limitation would apply to any action arising from a home  
    inspection report. 



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    It is settled law that breach of contract actions may only be  
    brought by parties to the contract or by third parties who were  
    intended beneficiaries of the performance to be rendered under  
    the contract.  See Corbin,  Contracts, Sec. 776.  
    
    Likewise, a negligent misrepresentation, or constructive fraud,  
    action may be brought only by persons whom the defendant  
    intended to have rely upon the misrepresentation. See  
     Christiansen v. Roddy (1986) 186 Cal.App.3d 780.

    Intentional misrepresentation or fraud actions, however, can  
    generally be brought by any person who could have foreseeably  
    been injured by the fraudulent statement.  See  Bily v. Arthur  
     Young (1992) 3 Cal.4th 370; and  Wice v, Schilling,  supra.

    In causes of action for ordinary negligence arising out of  
    breach contract, like the action created by this bill, the  
    traditional common law rule was that liability was limited to  
    parties to the contract.  Even intended beneficiaries were  
    excluded.  However, this "privity" rule, which had been eroding  
    since the beginning of the century, was overturned by the  
    California Supreme Court case of  Biankanja v. Irving (1958) 49  
    Cal.2d 647.  The court held that:

    "The determination whether in a specific case the defendant will  
    be held liable to a third person not in privity is a matter of  
    policy and involves the balancing of various factors, among  
    which are the extent to which the transaction was intended to  
    affect the plaintiff, the foreseeability of harm to him, the  
    degree of certainty that the plaintiff suffered injury, the  
    closeness of the connection between the defendant's conduct and  
    the injury suffered, the moral blame attached to the defendant's  
    conduct, and the policy of preventing future harm."  Id. at p.  
    650.                                                            

    Under  Biankanja, whether the plaintiff is an intended  
    beneficiary of the contract is only one of the factors to be  
    considered in determining if the plaintiff is owed a duty by the  
    defendant.  For example, in  M. Miller,  Co. v. Dames & Moore  
    (1961) 198 Cal.App.2d 305, the court held that, under the  
     Biankanja factors, an engineering firm which had contracted with  
    a sanitation district to prepare a soils report owed a duty to a  


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    contractor which bid on the district's project.   

    Long after the privity rule was abandoned by California and  
    other states, it remained the rule in one special type of cases:  
     for certified public accountants conducting financial audit  
    reports.  In  Bily v. Arthur Young,  supra, the California Supreme  
    Court reaffirmed that there are special duty limitations for  
    such cases, and held that there are three different rules,  
    depending upon the cause of action. If the cause of action is  
    ordinary negligence, the accountant can only be held liable to  
    parties to the contract.  If the cause of action is negligent  
    misrepresentation, the accountant can only be held liable to  
    specifically intended beneficiaries of the contract. If the  
    cause of action is for intentional fraud, the accountant may be  
                                                                          held liable to any foreseeable plaintiff. 

    In parts of the  Bily opinion, the court uses general language  
    which implies that these special rules would apply to any  
    allegation of negligence or negligent misrepresentation related  
    to the preparation of a report by a professional.  However, the  
    court's stated reasons for creating special limitations are  
    specific to financial audits.  The court was concerned about the  
    large number of potential investors who could rely upon an  
    audit, and the resulting disproportionate liability of the  
    accountant.  The court also cited that sophistication of  
    investors who rely on audits.

    These justifications for a specially limited duty do not appear  
    to apply to home inspection reports:  it is not likely that  
    there will be more than a few prospective purchasers who would  
    rely on a report which was not intended for their benefit.   
    Likewise, a negligently prepared home inspection report does not  
    have consequences like affecting multi-million dollar investment  
    decisions.  In addition, prospective home buyers are not  
    analogous to sophisticated investors who can be assumed to be  
    able to protect themselves.
       
    In limiting intentional fraud actions to plaintiffs who were  
    intended beneficiaries of the contract, this bill would be  
    unprecedented.  In limiting negligence actions to intended  
    beneficiaries, this bill would be applying a rule which was  
    created for a special situation involving potential crushing  


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    liability to a situation in which such concerns do not seem to  
    be applicable. 
 
    IS THIS BILL'S DUTY LIMITATION APPROPRIATE?

3.   Restricting contractual limitations on liability

    a)       Rationale for restricting liability limitation clauses 

            According to the sponsors, one of the most widespread  
        abuses in the home inspection industry is the insertion into  
        contracts of a clause limiting the liability of the  
        inspector to the price paid for the home inspection report. 

            Therefore, this bill declares that contractual  
        provisions that purport to waive the duty created by this  
        bill or that otherwise unreasonably limit a home inspector's  
        liability, such as limiting liability to the cost of the  
        report, are contrary to public policy and invalid.

            In  Tunkl v. Regents of University of California (1963)  
        60 Cal.2d 92, the California Supreme Court enumerated  
        various factors which must be considered in determining  
        whether a liability limitation provision is valid.  These  
        factors are a combination of the factors which have been  
        employed traditionally under the doctrines of  
        unconscionability and public policy.
            
            In  Baker v. Haas,  supra, a Maryland state appeals court  
        cited  Tunkl, and applied its factors to uphold a clause in a  
        home inspection contract which limited the liability of the  
        home inspector to the cost of the report.  Given the  Baker  
        case, it is possible that California courts also would  
        uphold a home inspector's liability limitation clause,  
        unless the legislature expressly prohibits such clauses in  
        this or similar legislation.

            Last year, the legislature declared in uncodified intent  
        language that the duty of real estate brokers and agents to  
        disclose the results of their reasonably diligent inspection  
        cannot be waived by contract.  This language expressed  
        disapproval of a contrary holding in  Loughrin v.  Superior  


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        Court (1993) 15 Cal.App.4th 1188.  This year, AB 530  
        (Weggeland) seeks to codify this intent language.

            If the liability of real estate agents to conduct a  
        reasonably diligent inspection cannot be waived by contract,  
        it seems logical that the closely related duty of home  
        inspectors which would be created by this bill should also  
        not be waived by contract.

    b)       Effect of amendments

            In the previous version, the bill only prohibited  
        limiting liability to the cost of the report.  However, the  
        author indicated at the last committee hearing that this  
        previous language provided less restriction against  
        liability limitation clauses than he intended.  As a result,  
        the author has amended the bill to specify that the duty of  
        care cannot be waived, and that other  unreasonable  
        limitations of liability, such as limiting liability to the  
        cost of the report, are invalid. 

            The bill as amended is more restrictive than the  
        previous version, but it does grant courts considerable  
        discretion in reviewing liability limitation clauses.  The  
        bill grants courts less discretion than they would have  
        under present law, since it clearly provides statutory  
        guidance that certain types of waivers are invalid, and  
        there is no such guidance in present law.  However, the  
        committee may wish to consider if it is ever "reasonable" to  
        limit liability, and whether a prohibition which draws a  
        brighter line would be more appropriate. 

            IS IT APPROPRIATE TO ALLOW "REASONABLE" LIMITATIONS ON  
        LIABILITY?    

4.   Unfair business practices

    According to the sponsors, it is necessary to prohibit the  
    "unfair business practices" listed in this bill in order to  
    assure prospective buyers that "the inspection will be untainted  
    by an inspector's interest in kickbacks from agents, financial  
    interests in the property, or repair work generated by the  


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    inspection."

    There does not appear to be any controversy about this  
    provision. 

5.   Exempting engineers, architects, and land surveyors

    The standard of care established by this bill applies only to  
    home inspectors who are not also licensed general contractors,  
    structural pest control operators, architects, or engineers.   
    This makes sense, because such licensed inspectors would all be  
    subject to their own professional standards of care, which would  
    probably be more demanding than that applicable to home  
    inspectors generally.

    However, this bill exempts engineers, architects, and land  
    surveyors who are acting pursuant to their professional  
    registration or license from all of the other provisions of the  
    bill as well. 

    According to the staff of the Senate Business and Professions  
    Committee, this exemption was important to the members of that  
    committee, who believe that these licensed professionals should  
    be governed only by the applicable provisions of their  
    professional licensing statutes, and by their licensing bodies. 



















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    The Board of Registration for Professional Engineers and Land  
    Surveyors shares this concern about any additional standards  
    being placed on their licensees.  However, staff from that board  
    acknowledge that this bill's prohibitions against listed unfair  
    business practices and against liability limitation clauses do  
    not duplicate any standards enforced by the Board.

    Although this bill is opposed by two small engineering  
    organizations, the major engineering organization in the state,  
    CELSOC, is neutral on the bill.  At the June 6th hearing, CELSOC  
    indicated that it would oppose the bill if this engineering  
    exemption is removed.

    There is some question about whether licensed engineers, etc.  
    are "acting pursuant to their license" when they conduct a home  
    inspection.  Woodframed dwellings with less than four units are  
    statutorily exempt from the engineering statutes, and, under  
    this bill, home inspectors could not perform activities which,  
    under the relevant statutes, must be performed by licensed  
    engineers, etc. 

    Therefore, when an engineer performs the same type of home  
    inspection a nonengineer may perform, he or she is probably not  
    acting as an engineer, and therefore would not be exempt from  
    the unfair business practice and liability limitation  
    prohibitions in this bill.      

    However, according to the staff of the Board of Registration, if  
    engineers represent themselves to be engineers when conducting  
    such a home inspection, they would be acting pursuant to their  
    registration.  In other words, if an engineer signed a home  
    inspection report, "John Smith, Professional Engineer," the  
    engineer could limit his liability to the cost of the report,  
    and could receive a kickback from the agent. 

    IS IT APPROPRIATE TO ALLOW ENGINEERS AND ARCHITECTS TO  
    MANIPULATE WHETHER THEY ARE SUBJECT TO THE PROHIBITIONS IN THIS  
    BILL?

6.   Relationship of bill to real estate disclosure requirements  
      
    Originally, this bill was part of a one-two punch by CAR to  


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SB 258 (O'Connell)
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    allow real estate agents and brokers to be relieved of their  
    duties to investigate defects by providing a report prepared by  
    a home inspector.  

    The original version of AB 530 (Weggeland), which was  
    double-joined to this bill, would have specified that home  
    inspectors are "experts" for the purposes of the "substitute  
    disclosure" provisions of Section 1102.4 of the Civil Code.   
    That provision was removed from AB 530 by the Assembly Judiciary  
    Committee.  This would have allowed realtors to shift some of  
    their disclosure liability to home inspectors by 

































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SB 258 (O'Connell)
Page 21

requiring home inspections in all of their transactions.  This is a  
much less expensive way of shifting liability than hiring a licensed  
engineer, etc. 

    It is possible that, under present law, a home inspector who was  
    not a licensed engineer, etc. could be considered by a court to  
    be an expert whose report could be used by a realtor to  
    substitute for the realtors' own investigation.  It is likely,  
    however, that most unlicensed home inspectors would not be  
    considered such an expert. 

    This bill is drafted so that it will not affect whether or not  
    certain home inspectors could be considered experts for these  
    purposes.  However, given the history with AB 530, it seems  
    clear that, if this bill passes, legislation will be introduced  
    in subsequent years to make home inspectors experts for the  
    purposes of the substitute disclosure law.  The argument would  
    be that the consumer protections and standard of care created by  
    this bill provide the safeguards necessary to allow home  
    inspectors to be considered to be experts.  


                                 
Support:     California Association of Realtors
             California Real Estate Inspection Association
             Los Angeles County District Attorneys Office
             Fennema Engineers, Inc.

Opposition:  Peninsula Chapter, California Society of Professional    
        Engineers
             National Academy of Building Inspection Engineers  
             Department of Real Estate  
Prior Legislation:  AB 2780 (O'Connell)

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