Retaliation

Retaliation in the context of wrongful termination and employment law in California is a significant legal issue that can lead to complex legal consequences. It involves an employer taking adverse action against an employee for engaging in legally protected activities. Understanding the nuances of retaliation laws is crucial for both employers and employees in California.

Legal Framework

1. Federal and State Laws: Both federal laws, like Title VII of the Civil Rights Act of 1964, and state laws, specifically the California Fair Employment and Housing Act (FEHA), protect employees from retaliation.
2. Protected Activities: These include filing a complaint, participating in an investigation, or opposing discriminatory practices.
3. Adverse Employment Actions: Actions by an employer that negatively affect the employee’s job status or work environment. This includes termination, demotion, salary reduction, or any other form of penalization.
4. Burden of Proof: The employee must first establish a prima facie case of retaliation by showing participation in a protected activity, subsequent adverse employment action, and a causal link between them. The burden then shifts to the employer to articulate a legitimate, non-retaliatory reason for the action.

Legal Consequences

• Lawsuits and Damages: Employees can file lawsuits for retaliation, potentially leading to reinstatement, back pay, compensatory and punitive damages, and attorney’s fees.
• Reputational Harm: Employers may suffer reputational damage, impacting their public image and business relationships.
• Regulatory Penalties: Regulatory bodies may impose penalties or sanctions on the employer.

Potential Problems and Examples

1. Termination after Complaint: An employee files a sexual harassment complaint and is subsequently terminated. If the timing suggests a causal link, this could be seen as retaliation.
2. Demotion after Testifying: An employee who testifies in a colleague’s discrimination case and then faces demotion could argue that the demotion is retaliatory.
3. Change in Job Responsibilities: Subtle forms of retaliation, like significantly changing job responsibilities or workplace isolation after engaging in protected activities, can also be problematic.
4. Performance Reviews: Negative performance reviews following protected activities, especially if previous reviews were positive, can be indicative of retaliation.

Reasoning and Logic

• Causation Challenge: Establishing a direct causal link between the protected activity and adverse action is challenging. Employers may argue that the adverse action was due to legitimate business reasons.
• Timing and Evidence: The timing of the adverse action relative to the protected activity can be a strong indicator of retaliation. However, employers might provide documentation to justify their actions as non-retaliatory.
• Subtlety of Actions: Some retaliatory actions are subtle and harder to prove. They may not directly affect job status but can significantly impact work conditions or future career prospects.
• Legal Ambiguities: The legal interpretation of what constitutes a ‘protected activity’ and an ‘adverse action’ can vary, leading to complexities in establishing a retaliation claim.

Conclusion

Retaliation in the context of California employment law represents a critical area where both employees and employers must tread carefully. For employees, it’s about understanding their rights and recognizing when those rights are being violated. For employers, it’s about ensuring that any employment action, especially following an employee’s engagement in protected activities, is well-documented and justified by legitimate business reasons. Navigating these issues requires a comprehensive understanding of both federal and state laws and careful consideration of the specific circumstances of each case.

_______________________

Call 310-312-1100 Now to schedule a time to discuss your matter with Attorney John Michael Jensen.

Additional Information

Retaliation in the context of wrongful termination and employment law in the state of California is a critical and complex legal issue.

1. Retaliation Laws in California:California has robust employment laws that protect employees from retaliation by their employers. Retaliation occurs when an employer takes adverse action against an employee in response to that employee engaging in legally protected activities, such as reporting workplace misconduct, discrimination, harassment, or participating in whistleblowing. Some key laws and statutes relevant to retaliation in California include:

• California Fair Employment and Housing Act (FEHA): Under FEHA, it’s illegal for employers to retaliate against employees for engaging in protected activities, such as reporting workplace discrimination or harassment.Whistleblower Protection: California Labor Code Section 1102.5 protects employees who report violations of law, such as fraud, safety violations, or other illegal activities, from retaliation by their employers.Public Policy Exceptions: California recognizes a public policy exception to the at-will employment doctrine. This means that an employer may not terminate an employee if it violates a fundamental public policy, which includes retaliatory terminations.

2. Examples of Retaliation:a. Wrongful Termination: If an employee is fired for reporting workplace harassment, unsafe conditions, or illegal activities, and the termination can be linked to the protected activity, it may be considered retaliatory.b. Demotion or Negative Employment Actions: Retaliation can take various forms, such as demotion, reduction in pay, transfer to a less favorable position, or denial of promotions based on an employee’s engagement in protected activities.c. Hostile Work Environment: Creating a hostile work environment as retaliation, such as subjecting an employee to increased scrutiny, unfounded disciplinary actions, or harassment, can also be considered retaliation.

3. Legal Consequences of Retaliation:Employers who engage in retaliation in California can face serious legal consequences, including:a. Civil Lawsuits: Employees who believe they have been subjected to retaliation can file lawsuits against their employers seeking damages, including back pay, front pay, emotional distress damages, and attorney’s fees.b. Penalties: Employers found guilty of retaliation may be subject to civil penalties, which can be substantial.c. Reinstatement or Rehiring: Courts may order the reinstatement or rehiring of the affected employee.d. Injunctions: Courts can issue injunctions prohibiting employers from engaging in further retaliatory conduct.

4. Problems that Could Arise:While retaliation laws in California are designed to protect employees, several problems can arise in practice:a. Proving Retaliation: It can be challenging to establish a direct link between the protected activity and the adverse employment action. Employers may argue legitimate reasons for termination or other actions, making it difficult for employees to prove retaliation.b. Subjectivity: Retaliation cases often involve subjective elements, such as the intent of the employer. This can lead to disputes over the true motives behind employment decisions.c. Burden of Proof: Employees have the burden of proving retaliation, which can be an arduous task, requiring evidence and witnesses to support their claims.d. Confidentiality Concerns: Whistleblowers may fear retaliation and not report illegal activities or unsafe conditions due to concerns about confidentiality and potential consequences.In conclusion, retaliation in the context of wrongful termination and employment law in California is a complex issue with significant legal consequences. Employers must be aware of their obligations under state law, while employees should be informed of their rights and protections. The potential problems in proving retaliation underline the importance of consulting with experienced employment law attorneys when facing such issues. It’s essential to navigate these legal matters carefully to ensure that both employees’ rights and employers’ interests are appropriately balanced within the boundaries of California employment law.

_____________________

Call 310-312-1100 Now to schedule a time to discuss your matter with Attorney John Michael Jensen.

2505. Retaliation—Essential Factual Elements (Gov. Code, § 12940(h))

[Name of plaintiff] claims that [name of defendant] retaliated against [him/ her/nonbinary pronoun] for [describe activity protected by the FEHA]. To establish this claim, [name of plaintiff] must prove all of the following:

1. That [name of plaintiff] [describe protected activity];
2. [That [name of defendant] [discharged/demoted/[specify other adverse employment action]] [name of plaintiff];]

[or]

[That [name of defendant] subjected [name of plaintiff] to an adverse employment action;]

[or]

[That [name of plaintiff] was constructively discharged;]

• That [name of plaintiff]’s [describe protected activity] was a substantial motivating reason for [name of defendant]’s [decision to [discharge/demote/[specify other adverse employment action]]

[name of plaintiff]/conduct];

• That [name of plaintiff] was harmed; and
• That [name of defendant]’s decision to [discharge/demote/[specify other adverse employment action]] [name of plaintiff] was a substantial factor in causing [him/her/nonbinary pronoun] harm.

[[Name of plaintiff] does not have to prove [discrimination/harassment] in order to be protected from retaliation. If [he/she/nonbinary pronoun] [reasonably believed that [name of defendant]’s conduct was unlawful/ requested a [disability/religious] accommodation], [he/she/nonbinary pronoun] may prevail on a retaliation claim even if [he/she/nonbinary pronoun] does not present, or prevail on, a separate claim for [discrimination/harassment/[other]].]

New September 2003; Revised August 2007, April 2008, October 2008, April 2009,

June 2010, June 2012, December 2012, June 2013, June 2014, June 2016,

December 2016

Directions for Use

In elements 1 and 3, describe the protected activity in question. Government Code section 12940(h) provides that it is unlawful to retaliate against a person “because the person has opposed any practices forbidden under [Government Code sections

12900 through 12966] or because the person has filed a complaint, testified, or assisted in any proceeding under [the FEHA].” It is also unlawful to retaliate or otherwise discriminate against a person for requesting an accommodation for religious practice or disability, regardless of whether the request was granted. (Gov. Code, § 12940(l)(4) [religious practice], (m)(2) [disability].)

Read the first option for element 2 if there is no dispute as to whether the employer’s acts constituted an adverse employment action. Read the second option and also give CACI No. 2509, “Adverse Employment Action” Explained, if whether there was an adverse employment action is a question of fact for the jury. For example, the case may involve a pattern of employer harassment consisting of acts that might not individually be sufficient to constitute retaliation, but taken as a whole establish prohibited conduct. (See Yanowitz v. L’Oreal USA, Inc. (2005) 36 Cal.4th 1028, 1052–1056 [32 Cal.Rptr.3d 436, 116 P.3d 1123].) Give both the first and second options if the employee presents evidence supporting liability under both a sufficient-single-act theory or a pattern-of-harassment theory. (See, e.g., Wysinger

v. Automobile Club of Southern California (2007) 157 Cal.App.4th 413, 423–424 [69 Cal.Rptr.3d 1].) Also select “conduct” in element 3 if the second option or both the first and second options are included for element 2.

Retaliation in violation of the FEHA may be established by constructive discharge; that is, that the employer intentionally created or knowingly permitted working conditions to exist that were so intolerable that a reasonable person in the employee’s position would have had no reasonable alternative other than to resign. (See Steele v. Youthful Offender Parole Bd. (2008) 162 Cal.App.4th 1241, 1253 [76 Cal.Rptr.3d 632].) If constructive discharge is alleged, give the third option for element 2 and also give CACI No. 2510, “Constructive Discharge” Explained. Also select “conduct” in element 3 if the third option is included for element 2.

Element 3 requires that the protected activity be a substantial motivating reason for the retaliatory acts. (See Harris v. City of Santa Monica (2013) 56 Cal.4th 203, 232 [152 Cal.Rptr.3d 392, 294 P.3d 49]; Alamo v. Practice Management Information

Corp. (2013) 219 Cal.App.4th 466, 479 [161 Cal.Rptr.3d 758]; see also CACI No. 2507, “Substantial Motivating Reason” Explained.)

Note that there are two causation elements. There must be a causal link between the retaliatory animus and the adverse action (see element 3), and there must be a causal link between the adverse action and damages (see element 5). (See Mamou v. Trendwest Resorts, Inc. (2008) 165 Cal.App.4th 686, 713 [81 Cal.Rptr.3d 406].)

This instruction has been criticized in dictum because it is alleged that there is no element requiring retaliatory intent. (See Joaquin v. City of Los Angeles (2012) 202 Cal.App.4th 1207, 1229–1231 [136 Cal.Rptr.3d 472].) The court urged the Judicial Council to redraft the instruction and the corresponding special verdict form so as to clearly state that retaliatory intent is a necessary element of a retaliation claim under FEHA.

The jury in the case was instructed per element 3 “that Richard Joaquin’s reporting that he had been sexually harassed was a motivating reason for the City of Los

Angeles’ decision to terminate Richard Joaquin’s employment or deny Richard Joaquin promotion to the rank of sergeant.” The committee believes that the instruction as given is correct for the intent element in a retaliation case. (Cf. Wallace v. County of Stanislaus (2016) 245 Cal.App.4th 109, 127–132 [199 Cal.Rptr.3d 462] [for disability discrimination, “substantial motivating reason” is only language required to express intent].) However, in cases such as Joaquin that involve allegations of a prohibited motivating reason (based on a report of sexual harassment) and a permitted motivating reason (based on a good faith belief that the report was falsified), the instruction may need to be modified to make it clear that plaintiff must prove that defendant acted based on the prohibited motivating reason and not the permitted motivating reason.

Sources and Authority

• Retaliation Prohibited Under Fair Employment and Housing Act. Government Code section 12940(h).
• Retaliation for Requesting Reasonable Accommodation for Religious Practice and Disability Prohibited. Government Code section 12940(l)(4), (m)(2).
• “Person” Defined Under Fair Employment and Housing Act. Government Code section 12925(d).
• Prohibited Retaliation. Title 2 California Code of Regulations section 11021.
• “[I]n order to establish a prima facie case of retaliation under the FEHA, a plaintiff must show (1) he or she engaged in a ‘protected activity,’ (2) the employer subjected the employee to an adverse employment action, and (3) a causal link existed between the protected activity and the employer’s action. Once an employee establishes a prima facie case, the employer is required to offer a legitimate, nonretaliatory reason for the adverse employment action. If the employer produces a legitimate reason for the adverse employment action, the presumption of retaliation ‘ “ ‘drops out of the picture,’ ” ’ and the burden shifts back to the employee to prove intentional retaliation.” (Yanowitz, supra, 36 Cal.4th at p. 1042, internal citations omitted.)
• “Actions for retaliation are ‘inherently fact-driven’; it is the jury, not the court, that is charged with determining the facts.” (McCoy v. Pacific Maritime Assn. (2013) 216 Cal.App.4th 283, 299 [156 Cal.Rptr.3d 851].)
• “It is well established that a plaintiff in a retaliation case need only prove that a retaliatory animus was at least a substantial or motivating factor in the adverse employment decision.” (George v. California Unemployment Ins. Appeals Bd. (2009) 179 Cal.App.4th 1475, 1492 [102 Cal.Rptr.3d 431].)
• “Retaliation claims are inherently fact-specific, and the impact of an employer’s action in a particular case must be evaluated in context. Accordingly, although an adverse employment action must materially affect the terms, conditions, or privileges of employment to be actionable, the determination of whether a particular action or course of conduct rises to the level of actionable conduct should take into account the unique circumstances of the affected employee as

well as the workplace context of the claim.” (Yanowitz, supra, 36 Cal.4th at p. 1052.)

• “Contrary to [defendant]’s assertion that it is improper to consider collectively the alleged retaliatory acts, there is no requirement that an employer’s retaliatory acts constitute one swift blow, rather than a series of subtle, yet damaging, injuries. Enforcing a requirement that each act separately constitute an adverse employment action would subvert the purpose and intent of the statute.” (Yanowitz, supra, 36 Cal.4th at pp. 1055–1056, internal citations omitted.)
• “[U]nder certain circumstances, a retaliation claim may be brought by an employee who has complained of or opposed conduct, even when a court or jury subsequently determines the conduct actually was not prohibited by the FEHA. Indeed, this precept is well settled. An employee is protected against retaliation if the employee reasonably and in good faith believed that what he or she was opposing constituted unlawful employer conduct such as sexual harassment or sexual discrimination.” (Miller v. Department of Corr. (2005) 36 Cal.4th 446, 473–474 [30 Cal.Rptr.3d 797, 115 P.3d 77], internal citations omitted.)
• “Clearly, section 12940, subdivision (h) encompasses a broad range of protected activity. An employee need not use specific legal terms or buzzwords in opposing discrimination. Nor is it necessary for an employee to file a formal charge. The protected activity element may be established by evidence that the plaintiff threatened to file a discrimination charge, by a showing that the plaintiff mistakenly, but reasonably and sincerely believed he was opposing discrimination, or by evidence an employer believed the plaintiff was a potential witness in another employee’s FEHA action.” (Rope v. Auto-Chlor System of Washington, Inc. (2013) 220 Cal.App.4th 635, 652 [163 Cal.Rptr.3d 392], internal citations and footnote omitted.)
• “ ‘Standing alone, an employee’s unarticulated belief that an employer is engaging in discrimination will not suffice to establish protected conduct for the purposes of establishing a prima facie case of retaliation, where there is no evidence the employer knew that the employee’s opposition was based upon a reasonable belief that the employer was engaging in discrimination.’ ‘[C]omplaints about personal grievances or vague or conclusory remarks that fail to put an employer on notice as to what conduct it should investigate will not suffice to establish protected conduct.’ [¶] But employees need not explicitly and directly inform their employer that they believe the employer’s conduct was discriminatory or otherwise forbidden by FEHA.” (Castro-Ramirez v. Dependable Highway Express, Inc. (2016) 2 Cal.App.5th 1028, 1046 [207 Cal.Rptr.3d 120], internal citation omitted.)
• “The relevant question . . . is not whether a formal accusation of discrimination is made but whether the employee’s communications to the employer sufficiently convey the employee’s reasonable concerns that the employer has acted or is acting in an unlawful discriminatory manner.” (Husman v. Toyota Motor Credit Corp. (2017) 12 Cal.App.5th 1168, 1193 [220 Cal.Rptr.3d 42].)
• “Notifying one’s employer of one’s medical status, even if such medical status

constitutes a ‘disability’ under FEHA, does not fall within the protected activity identified in subdivision (h) of section 12940—i.e., it does not constitute engaging in opposition to any practices forbidden under FEHA or the filing of a complaint, testifying, or assisting in any proceeding under FEHA.” (Moore v.

Regents of University of California (2016) 248 Cal.App.4th 216, 247 [206

Cal.Rptr.3d 841].)

• “[Plaintiff]’s advocacy for the disabled community and opposition to elimination of programs that might benefit that community do not fall within the definition of protected activity. [Plaintiff] has not shown the [defendant]’s actions amounted to discrimination against disabled citizens, but even if they could be so construed, discrimination by an employer against members of the general public is not a prohibited employment practice under the FEHA.” (Dinslage v. City and County of San Francisco (2016) 5 Cal.App.5th 368, 383 [209 Cal.Rptr.3d 809], original italics.)
  • “Moreover, [defendant]’s actions had a substantial and material impact on the conditions of employment. The refusal to promote [plaintiff] is an adverse employment action under FEHA. There was also a pattern of conduct, the totality of which constitutes an adverse employment action. This includes undeserved negative job reviews, reductions in his staff, ignoring his health concerns and acts which caused him substantial psychological harm.” (Wysinger, supra, 157 Cal.App.4th at p. 424, internal citations omitted.)
  • “A long period between an employer’s adverse employment action and the employee’s earlier protected activity may lead to the inference that the two events are not causally connected. But if between these events the employer engages in a pattern of conduct consistent with a retaliatory intent, there may be a causal connection.” (Wysinger, supra, 157 Cal.App.4th at p. 421, internal citation omitted.)
  • “Both direct and circumstantial evidence can be used to show an employer’s intent to retaliate. ‘Direct evidence of retaliation may consist of remarks made by decisionmakers displaying a retaliatory motive.’ Circumstantial evidence typically relates to such factors as the plaintiff’s job performance, the timing of events, and how the plaintiff was treated in comparison to other workers.” (Colarossi v. Coty US Inc. (2002) 97 Cal.App.4th 1142, 1153 [119 Cal.Rptr.2d 131], internal citations omitted.)
  • “The retaliatory motive is ‘proved by showing that plaintiff engaged in protected activities, that his employer was aware of the protected activities, and that the adverse action followed within a relatively short time thereafter.’ ‘The causal link may be established by an inference derived from circumstantial evidence, “such as the employer’s knowledge that the [employee] engaged in protected activities and the proximity in time between the protected action and allegedly retaliatory employment decision.” ’ ” (Fisher v. San Pedro Peninsula Hospital (1989) 214 Cal.App.3d 590, 615 [262 Cal.Rptr. 842], internal citations omitted.)
  • “[A]n employer generally can be held liable for the retaliatory actions of its

supervisors.” (Wysinger, supra, 157 Cal.App.4th at p. 420.)

• “Plaintiff, although a partner, is a person whom section 12940, subdivision (h) protects from retaliation for opposing the partnership-employer’s harassment against those employees.” (Fitzsimons v. California Emergency Physicians Medical Group (2012) 205 Cal.App.4th 1423, 1429 [141 Cal.Rptr.3d 265].)
• “[A]n employer may be found to have engaged in an adverse employment action, and thus liable for retaliation under section 12940(h), ‘by permitting . . . fellow employees to punish [him] for invoking [his] rights.’ We therefore hold that an employer may be held liable for coworker retaliatory conduct if the employer knew or should have known of coworker retaliatory conduct and either participated and encouraged the conduct, or failed to take reasonable actions to end the retaliatory conduct.” (Kelley v. The Conco Cos. (2011) 196 Cal.App.4th 191, 213 [126 Cal.Rptr.3d 651], internal citation omitted.)
• “[T]he employer is liable for retaliation under section 12940, subdivision (h), but nonemployer individuals are not personally liable for their role in that retaliation.” (Jones v. The Lodge at Torrey Pines Partnership (2008) 42 Cal.4th 1158, 1173 [72 Cal.Rptr.3d 624, 177 P.3d 232].)
• “ ‘The legislative purpose underlying FEHA’s prohibition against retaliation is to prevent employers from deterring employees from asserting good faith discrimination complaints     ’ Employer retaliation against employees who are

believed to be prospective complainants or witnesses for complainants undermines this legislative purpose just as effectively as retaliation after the filing of a complaint. To limit FEHA in such a way would be to condone ‘an absurd result’ that is contrary to legislative intent. We agree with the trial court that FEHA protects employees against preemptive retaliation by the employer.” (Steele, supra, 162 Cal.App.4th at p. 1255, internal citations omitted.)

• “ ‘The plaintiff’s burden is to prove, by competent evidence, that the employer’s proffered justification is mere pretext; i.e., that the presumptively valid reason for the employer’s action was in fact a coverup.      In responding to the

employer’s showing of a legitimate reason for the complained-of action, the plaintiff cannot “ ‘simply show the employer’s decision was wrong, mistaken, or unwise. Rather, the employee ‘ “must demonstrate such weaknesses, implausibilities, inconsistencies, incoherencies, or contradictions in the employer’s proffered legitimate reasons for its action that a reasonable factfinder could rationally find them “unworthy of credence,”…………………………………………………………… and hence infer “that

the employer did not act for the [asserted] non-discriminatory reasons.” ’ ” ’ ” (Jumaane v. City of Los Angeles (2015) 241 Cal.App.4th 1390, 1409 [194

Cal.Rptr.3d 689].)

• “The showing of pretext, while it may indicate retaliatory intent or animus, is not the sole means of rebutting the employer’s evidence of nonretaliatory intent. ‘ “While ‘pretext’ is certainly a relevant issue in a case of this kind, making it a central or necessary issue is not sound. The central issue is and should remain whether the evidence as a whole supports a reasoned inference that the

challenged action was the product of discriminatory or retaliatory animus. The employer’s mere articulation of a legitimate reason for the action cannot answer this question; it can only dispel the presumption of improper motive that would otherwise entitle the employee to a judgment in his favor.” ’ ” (Light v.

Department of Parks & Recreation (2017) 14 Cal.App.5th 75, 94 [221 Cal.Rptr.3d 668], original italics.)

• “Government Code section 12940, subdivision (h), does not shield an employee against termination or lesser discipline for either lying or withholding information during an employer’s internal investigation of a discrimination claim. In other words, public policy does not protect deceptive activity during an internal investigation. Such conduct is a legitimate reason to terminate an at-will employee.” (McGrory v. Applied Signal Technology, Inc. (2013) 212 Cal.App.4th 1510, 1528 [152 Cal.Rptr.3d 154], footnotes omitted.)
  • “Although appellant does not argue she was constructively discharged, such a claim is not necessary to find unlawful retaliation.” (McCoy, supra, 216 Cal.App.4th at p. 301.)
  • “The phrase ‘because of’ [in Gov. Code, § 12940(a)] is ambiguous as to the type or level of intent (i.e., motivation) and the connection between that motivation and the decision to treat the disabled person differently. This ambiguity is closely related to [defendant]’s argument that it is liable only if motivated by discriminatory animus. [¶] The statutory ambiguity in the phrase ‘because of” was resolved by our Supreme Court about six months after the first jury trial [in Harris, supra, 56 Cal.4th at p. 203].” (Wallace, supra, 245 Cal.App.4th at p. 127.)
  • “ ‘[W]hile discrimination may be carried out by means of speech, such as a written notice of termination, and an illicit animus may be evidenced by speech, neither circumstance transforms a discrimination suit to one arising from speech. What gives rise to liability is not that the defendant spoke, but that the defendant denied the plaintiff a benefit, or subjected the plaintiff to a burden, on account of a discriminatory or retaliatory consideration.’ ” (Laker v. Board of Trustees of California State University (2019) 32 Cal.App.5th 745, 772 [244 Cal.Rptr.3d

238].)

Secondary Sources

8 Witkin, Summary of California Law (11th ed. 2017) Constitutional Law, §§ 1028, 1052–1054

Chin et al., California Practice Guide: Employment Litigation, Ch. 7-A, Title VII And The California Fair Employment And Housing Act, ¶¶ 7:121–7:205 (The Rutter Group)

1 Wrongful Employment Termination Practice (Cont.Ed.Bar 2d ed.) Discrimination Claims, §§ 2.83–2.88

2 Wilcox, California Employment Law, Ch. 41, Substantive Requirements Under Equal Employment Opportunity Laws, § 41.131 (Matthew Bender)

11 California Forms of Pleading and Practice, Ch. 115, Civil Rights: Employment

CACI No. 2505          FAIR EMPLOYMENT AND HOUSING ACT

Discrimination, §§ 115.37, 115.94 (Matthew Bender) California Civil Practice: Employment Litigation, §§ 2:74–2:75 (Thomson Reuters)

Call 310-312-1100 Now to schedule a time to discuss your matter with Attorney John Michael Jensen.

Additional Information