California employment case index

The Fourth District reversed summary judgment for the County, holding that a deputy district attorney's internal warnings that a murder prosecution lacked probable cause were protected disclosures under Labor Code section 1102.5 — no express citation of law required, job duties notwithstanding — and that months of testing for a suspected neurological disease raised a triable issue of FEHA disability.

UPS accommodated drivers hurt on the job, drivers with ADA disabilities, and drivers who lost their DOT certifications — but told pregnant driver Peggy Young she could not work under a 20-pound lifting restriction. The Supreme Court vacated summary judgment and built the governing framework for PDA accommodation claims: show the employer accommodated others similar in ability to work, and a jury may infer discrimination if the policies significantly burden pregnant workers and the employer’s reasons are not strong enough to justify it. In California, where the PDLL and FEHA impose affirmative accommodation duties, Young is the federal floor — essential in pure Title VII postures, rarely the lead theory at home.

Satyadi v. West Contra Costa Healthcare DistrictAn employee need not exhaust the Labor Commissioner’s administrative remedy before bringing a civil whistleblower-retaliation action; the 2013 enactment of Labor Code sections 244 and 98.7, subdivision (g), merely clarified existing law.Satyadi v. West Contra Costa Healthcare District (2014) 232 Cal.App.4th 1022Parallel citation: 182 Cal.Rptr.3d 21. Court of Appeal […]

A school-district maintenance supervisor, fired after a sustained pattern of insubordination, computer misuse, and retaliation against co-workers, claimed his discharge was really payback for whistleblowing about District construction projects. The Third District affirmed the denial of his mandamus petition, applying the Supreme Court's then-new decision in Harris v. City of Santa Monica to hold that an employer may invoke the same-decision showing without conceding mixed motives, and that untainted misconduct alone justified termination — making the protected-activity question unnecessary to decide.

The Supreme Court held 5-4 that an employee is a “supervisor” for Title VII vicarious-liability purposes only if empowered to take tangible employment actions — hire, fire, demote, promote, transfer, or discipline. An employee who merely directs daily work is a co-worker, so the employer is liable only for negligence. The decision does not govern California’s FEHA, which defines “supervisor” more broadly and imposes strict liability for supervisor harassment.

A Recology supervisor who reported CRV weight-tag fraud to police and the company's board survived summary judgment: the Court of Appeal held Labor Code section 1102.5 protects reports of illegal conduct by fellow employees and third parties — not just the employer's own violations — and revived his False Claims Act and Tameny claims.

The First District reversed a defense verdict for instructional error, holding a whistleblower's motive irrelevant and reasonable-belief reports of unlawful policies protected even where debatable — but its further rule that reporting “publicly known” information is not a disclosure was later rejected by the Supreme Court in Kolla's, and the article maps what survives.

Jaramillo v. County of Orange A peace officer’s warnings to his own boss about the boss’s illegal conduct are protected whistleblowing under Labor Code section 1102.5; blanket POBRA waivers are invalid; and after-acquired evidence of unrelated crimes does not retroactively defeat a wrongful-discharge backpay award. Jaramillo v. County of Orange (2011) 200 Cal.App.4th 811 Parallel […]

The Supreme Court’s foundational “cat’s paw” decision: an employer is liable when a biased supervisor performs an act intended to cause an adverse employment action that is a proximate cause of the ultimate decision — even if the formal decisionmaker had no discriminatory animus. A decisionmaker’s “independent investigation” does not automatically break the causal chain, especially when it credits the biased actor’s report without independently confirming the action was justified.