California Court Says Employee’s Age Discrimination Case Should Proceed to Trial
In this blog post, we discuss a significant California employment law case where the plaintiff appealed a trial court’s granting of summary judgment in favor of his employer, the Permanente Medical Group, Inc. The case underscores key aspects of California’s Fair Employment and Housing Act (FEHA) in addressing age discrimination and workplace rights.
The plaintiff worked for Permanente for over 26 years. In 2011, the plaintiff was promoted to Director of Strategic Business and Development. His performance evaluations were consistently positive until 2016, when Monica A. became his supervisor. Monica A.’s review marked a stark negative shift in the plaintiff’s performance assessments.
Key Events: In 2017, the plaintiff was demoted and given a new title, “Practice Specialist,” with a reduced salary and prestige. He was replaced by a significantly younger and less experienced employee, which led him to believe that his demotion was due to age discrimination. Upset by his recent demotion, the plaintiff resigned a few months later, feeling as though he was being forced out.
The plaintiff filed a lawsuit against Permanente and Monica A., bringing multiple claims, including age discrimination, failure to prevent discrimination, harassment, and wrongful termination. The trial court initially granted a summary judgment in favor of the defendants, but upon appeal, the appellate court reversed this decision in part.
The Appellate Court’s Holding
The appellate court reversed the trial court’s granting of summary judgment to the defendant on the plaintiff’s age discrimination claim. More specifically, the court held that the change in the plaintiff’s employment position was considered an adverse action, affecting his career prospects. The court noted discrepancies in performance evaluations before and after Monica A.’s supervision, suggesting potential bias.
The reversal also extended to the claim of failure to prevent age discrimination. The court explained employers have a proactive duty to prevent discriminatory practices, and because the plaintiff’s age discrimination claims survived summary judgment, so too did this claim.
The court also reversed the decision on the plaintiff’s request for punitive damages, finding sufficient grounds to consider this claim based on the actions of Monica A.
However, the court affirmed the summary judgment on the plaintiff’s claims of harassment and constructive discharge, suggesting that the circumstances did not meet the “severe or pervasive” requirement for these claims.
This case illustrates the complexities of employment law and the robust protections offered under FEHA against age discrimination. It also highlights the importance of performance evaluations and the need for employers to be aware of the potential for bias in managerial decisions.
Have You Been Fired or Demoted for an Unfair Reason?
If you were recently demoted or fired for reasons that seem questionable, your employer may have violated your rights under the Fair Employment and Housing Act. If so, you may be entitled to damages designed to put you back in the position you would be in had your employer not engaged in unlawful employment discrimination. At the Hardin Law Group, we proudly represent Los Angeles employees in all types of employment law cases, including those involving discrimination, harassment, wage and hour violations and wrongful termination. To learn more, and to schedule a free consultation with Attorney Hardin today, call (310) 606-2122 or connect with us through our secure online contact form.