“The dilemma faced by any health care reform proposal in California is this: If it proposes an employer mandate, it risks running afoul of ERISA,” said Allan Zaremberg, president of the California Chamber of Commerce. “If it contains a payroll tax alternative to address the ERISA issue, it requires a two-thirds vote in the Legislature under Proposition 13 — and still might violate ERISA given the recent Maryland ruling.” Read More. (The Sacramento Bee 01/31/07)