Michelle Lee Flores and Marissa Hurwitz Alguire wrote an article titled, “The carrot and/or stick approach to workplace smoking program,” for the Daily Journal, in which they analyze whether employers in California can legally encourage employees to quit smoking, or penalize them if they don’t.

“The bottom line is that perhaps a more trouble-free route to encouraging employees to quit smoking is for California employers to use their words of encouragement, and, without tying participation to any wellness program, pay for the services to help employees try to quit using tobacco products,” Flores and Alguire wrote.