In Murray v. Oceanside Unified School Dist. (2000) 79 Cal.App.4th 1338, the court held that "because of the statement in the Legislative Counsel's Digest (Stats. 1999, ch. 592, 1; 12920), that 'any conduct that would have been a violation of Section 1102.1 . . ., as it read on December 1, 1999, shall be deemed a violation of this act,' we believe it is clear that the basic nature of Murray's statutory allegations for discrimination based upon sexual orientation is well within the scope of either or both of these statutory schemes, past and present." The court noted that there were no constitutional impairments to applying the amendments to conduct occurring before its enactment because the employer "had no vested right to conduct its employment affairs in a manner that violated established public policy. Nor did the provisions of the amendment substantially change the legal consequences of past events, so as to place any unfair new burdens on the . . . employer." ( Murray, supra, at p. 1354.) Murray thus determined that FEHA could be applied retroactively to claims arising prior to the amendment.