Judge: Joseph Lipner, Case: 22STCV05818, Date: 2024-11-07 Tentative Ruling



Case Number: 22STCV05818    Hearing Date: November 7, 2024    Dept: 72

SUPERIOR COURT OF CALIFORNIA

COUNTY OF LOS ANGELES

 

DEPARTMENT 72

 

TENTATIVE RULING

 

MICHELLE CASTILLO,

 

                                  Plaintiff,

 

         v.

 

 

INTERVENTIONAL ANASTHESIA & PAIN MANAGEMENT CLINIC INC.,

 

                                  Defendant.

 

 Case No:  22STCV05818

 

 

 

 

 

 Hearing Date:  November 7, 2024

 Calendar Number:  4

 

 

 

Plaintiff Michelle Castillo (“Plaintiff”) moves for summary judgment against Defendant Interventional Anesthesia & Pain Management Clinic Inc. (“Defendant”) on her Complaint.

 

The Court DENIES the motion for summary judgment.

 

The Court DENIES the motion for summary adjudication.

 

Background

 

This is an employment case. The following facts are taken from the parties’ separate statements. Except where otherwise noted, Court resolves disputes of fact in favor of the nonmoving party.

 

On October 26, 2020, Plaintiff was hired to work for Defendant as a front and back-office assistant. (Undisputed Fact (“UF”) 1; Response to Undisputed Fact (“RUF”) 1.) Plaintiff’s superiors at the office were Soroya Malek and Dr. Sabri Malek. (UF 6.)

 

Plaintiff contends that she was a loyal employee and performed her job duties competently. (UF 2-3.) Defendant contends that Plaintiff “did not follow directions and argued with her superiors and patients. [Citing Soroya Malek Decl. ¶ 5.] [Plaintiff] was disloyal, disruptive, unproductive[,] and sloppy at best. She was not a team player, spread gossip[,] and caused discord with other employees. [Citing Sabri Malek Decl. ¶ 3.]” (RUF 2.)

 

According to Plaintiff, Defendant’s office was chronically understaffed, and employees were given more work than they could reasonably handle. (UF 4.)  Plaintiff contends that one of the Maleks (she does not specify who) pressured her to work without proper breaks. (UF 26.) Plaintiff contends that this pressure and understaffing let to consistently late lunches and missed rest periods altogether. (UF 27.) Plaintiff contends that throughout her employment, her wage statements did not include premium pay for her meal and rest breaks. (UF 28.) Defendants contend that Plaintiff always took her lunch and rest breaks on time and was never interrupted. (RUF 25-27.)

 

Plaintiff contends that Defendants consistently failed to provide her with timely wage statements. (UF 29; see also Castillo Decl., Ex. 3.) Defendants contend that Plaintiff was paid on time. (RUF 29.) Plaintiff contends that Exhibit 3 to her declaration shows pay stubs with consistent delays in payment; however, the pay stubs in Exhibit 3 show at most a delay of two to three days after the end of the pay period. (Castillo Decl., Ex. 3.)

 

On November 9, 2020, Plaintiff found out that she was pregnant. (UF 5.) Although Plaintiff contends that she promptly informed Soroya and Sabri Malek about her pregnancy (UF 6), Soroya Malek declares that Plaintiff did not inform the Maleks of her pregnancy until November 27, 2020, when Plaintiff requested time off for an ultrasound. (RUF 6.)

 

Plaintiff contends that the Maleks began treating her differently right after Plaintiff told the Maleks that she was pregnant. (UF 7-12.) Plaintiff contends that the Maleks began treating her negatively and making it clear that they were unhappy with her pregnancy. (UF 8.) Plaintiff contends that the Maleks became aggressive and threatening to her. (UF 10.) Plaintiff contends that when she informed the Maleks that she would need time off during the eighth month of her pregnancy, one of the Maleks (who she does not identify) yelled at her, “If you are not happy here, then you can leave or we might alter and reduce your pay.” (UF 11.) Defendants deny that this incident happened (RUF 11) and generally deny that they treated Plaintiff negatively after finding out that she was pregnant. (RUF 7-12.)

 

Plaintiff had to use the restroom more frequently when she became pregnant. (UF 13.) Plaintiff contends that Soroya Malek mocked Plaintiff for taking frequent restroom breaks, stating “Oh, you used the restroom again!” (RUF 13-14.) Soroya Malek declares that she was concerned about Plaintiff’s health and thought that Plaintiff might have an infection. (UF 13-14.)

 

Plaintiff scheduled an appointment with her OB-GYN for November 28, 2020. (UF 15.) Plaintiff contends that Sabri Malek became angry when she informed him of the appointment, and did not allow her to take time off work for the appointment. (UF 16.) Defendant contends that this was because Plaintiff did not mention the appointment until November 27, 2020, the day before the appointment, and that Plaintiff was informed to give notice farther in advance. (RUF 16.) Defendant disputes that Sabri Malek became angry with Plaintiff. Defendant does not dispute that Plaintiff was not permitted time off for the November 28, 2024 appointment. (RUF 17.)

 

On December 18, 2020, Plaintiff tested positive for Covid-19. (UF 18.) Defendant contends that Plaintiff did not inform Defendant of her positive test until December 21, 2020. (UF 18; see also Castillo Decl., Ex. 1.) Defendant contends that Plaintiff came to work on December 16, 2020, prior to her positive test, without wearing a mask. (RUF 18.) Although Soroya Malek declares that Plaintiff came in contact with others while positive for Covid-19 (Soroya Malek Decl. ¶14), it is not clear when this happened. Soroya Malek instructed Plaintiff to quarantine on December 21, 2020, when she was notified (UF 19), and Plaintiff was subsequently terminated before she returned to work. (UF 21.) Soroya Malek additionally declares that Plaintiff came into contact with others while being exposed to her boyfriend, who tested positive for Covid-19. (Soroya Malek Decl. ¶ 16.) Plaintiff does not contradict this statement. Defendant contends that Castillo’s coworkers were upset that Castillo came to work after being exposed to Covid-19. (RUF 22.)

 

On January 4, Plaintiff informed Soroya Malek that she had tested negative for Covid-19 and was ready to return to work. (UF 20.)

 

On January 5, 2021, Soroya Malek terminated Plaintiff’s employment via a text message. (UF 21.) The text message stated as follows:

 

Good morning Michelle, due to covid-19 crisis and your critical situation and your pregnancy, and the sensitivity of the radiation equipments we use in the clinic. We will regretfully have to lay you off. We will hire an MA.

 

If you choose to apply for an unemployment we will support your application. Let us know if we could help.

 

Thank you and good luck.

 

(UF 22; Castillo Decl., Ex. 2.)

 

Defendant contends that by working at Defendant without notifying them of her pregnancy, Plaintiff exposed her fetus to risk of harm from exposure to x-ray radiation. (RUF 5, 20, 23.)

 

Defendant did not issue Plaintiff’s final paycheck on her last day of employment. (UF 30.) Defendant contends that Plaintiff’s paycheck was mailed to her at her request because she was in quarantine. (RUF 30, 32.) However, Defendant does not contradict Plaintiff’s statement that she told Soroya Malek on January 4, 2024, the day before her termination, that she had tested negative and no longer needed to quarantine. (UF 20; RUF 20.)

 

Plaintiff filed this action on February 15, 2022. The Complaint raises claims for (1) failure to furnish compliant wage statements; (2) failure to pay wages in a timely manner; (3) failure to pay earned wages; (4) failure to pay meal and rest period compensation; (5) wrongful termination in violation of public policy; (6) wrongful termination and retaliation; (7) wrongful termination and harassment; (8) wrongful termination and discrimination; (9) failure to engage in interactive process; (10) waiting time penalties; and (11) unfair competition.

 

On August 20, 2024, Plaintiff moved for summary judgment. Defendant filed an opposition and Plaintiff filed a reply.

 

Evidentiary Issues

 

Plaintiff appears to contend that the Court should disregard the declarations submitted by Defendant as insufficient to raise genuine issues of fact. Plaintiff argues that “ ‘[t]he [general] rule is ... that averments in the movant’s affidavits which depend upon written documents are incompetent and can not be considered unless there are annexed thereto the original documents or certified or authenticated copies of such instruments, or excuse for nonproduction thereof is shown.’ ” (Dugar v. Happy Tiger Records, Inc. (1974) 41 Cal.App.3d 811, 815–816 [emphasis added].) However, “ ‘[i]n order to succeed the moving party must present a competent showing regardless of weakness in the opposing affidavits and this is a matter which cannot be waived.’ ” (Miller & Lux, Inc. v. Bank of America (1963) 212 Cal.App.2d 719, 725.) Further, Plaintiff has not provided reasons for the Court to find that the declarations that Defendant submits are broadly unreliable or self-serving.

 

Legal Standard

 

The purpose of a motion for summary judgment or summary adjudication “is to provide courts with a mechanism to cut through the parties’ pleadings in order to determine whether, despite their allegations, trial is in fact necessary to resolve their dispute.” (Aguilar v. Atlantic Richfield Co., supra, 25 Cal.4th at p. 843.) “Code of Civil Procedure section 437c, subdivision (c), requires the trial judge to grant summary judgment if all the evidence submitted, and ‘all inferences reasonably deducible from the evidence’ and uncontradicted by other inferences or evidence, show that there is no triable issue as to any material fact and that the moving party is entitled to judgment as a matter of law.” (Adler v. Manor Healthcare Corp. (1992) 7 Cal.App.4th 1110, 1119.) 

 

“In ruling on the motion, the court must consider all of the evidence and all of the inferences reasonably drawn therefrom [citation] and must view such evidence [citations] and such inferences [citations] in the light most favorable to the opposing party.” (Aguilar, supra, at pp. 844-845 [quotation marks omitted].) 

 

“On a motion for summary judgment, the initial burden is always on the moving party to make a prima facie showing that there are no triable issues of material fact.” (Scalf v. D. B. Log Homes, Inc. (2005) 128 Cal.App.4th 1510, 1519.) 

 

“A plaintiff or cross-complainant has met his or her burden of showing that there is no defense to a cause of action if that party has proved each element of the cause of action entitling the party to judgment on the cause of action. Once the plaintiff or cross-complainant has met that burden, the burden shifts to the defendant or cross-defendant to show that a triable issue of one or more material facts exists as to the cause of action or a defense thereto. The defendant or cross-defendant shall not rely upon the allegations or denials of its pleadings to show that a triable issue of material fact exists but, instead, shall set forth the specific facts showing that a triable issue of material fact exists as to the cause of action or a defense thereto.” (Code Civ. Proc. § 437c, subd. (p)(1).)

 

To establish a triable issue of material fact, the party opposing the motion must produce substantial responsive evidence. (Sangster v. Paetkau (1998) 68 Cal.App.4th 151, 166.) “If the [opposing party] cannot do so, summary judgment should be granted.” (Avivi v. Centro Medico Urgente Medical Center (2008) 159 Cal.App.4th 463, 467.)

 

Discussion

 

(1) Failure to furnish compliant wage statements

 

Plaintiff states that this claim will be dismissed. (Motion at pp. 20:27-21:1.)

 

(2) Failure to pay wages in a timely manner

 

It is well-settled policy in California that all of an employee’s earned wages must be fully and promptly paid. (Smith v. Superior Court (2006) 39 Cal.4th 77, 82.) Failure to promptly pay wages results in a waiting time penalty whereby the wages continue to accrue up to a maximum of 30 days. (Lab. Code § 203.)

 

“ ‘Wages’ includes all amounts for labor performed by employees of every description, whether the amount is fixed or ascertained by the standard of time, task, piece, commission basis, or other method of calculation.” (Lab. Code, § 200.) Bonuses are treated as wages when the bonus is promised as part of compensation and the employee fulfills any agreed-to conditions for the bonus. (Neisendorf v. Levi Strauss & Co. (2006) 143 Cal.App.4th 509, 522.)

 

All earned wages are due and payable immediately upon an employee’s termination. (Lab. Code, § 201, subd. (a).)

 

            As discussed above, Plaintiff has not shown a substantial delay in her pay stubs during her employment. Although Defendant admits that Plaintiff’s final paycheck upon termination was delayed, Defendant has created a triable issue of fact that this was because Plaintiff requested that her check be mailed to her.

 

            The Court therefore denies summary adjudication on this claim. Because the Court denies summary adjudication on this claim, the Court also denies summary judgment.

 

(3) Failure to pay earned wages

 

            The only earned wages that Plaintiff appears to contend were not paid were her premium wages for alleged missed meal and rest breaks. Defendants have supported a triable issue that Plaintiff never missed any meal or rest breaks.

 

            The Court therefore denies summary adjudication on this claim.

 

(4) Failure to pay meal and rest period compensation

 

An employer must give its employees a 30-minute meal within the first 5 hours of their shift and rest breaks. (Lab. Code §§ 226.7(a), 512(a); IWC Wage Order No. 4-2001.) An employer satisfies this duty “if it relieves its employees of all duty, relinquishes control over their activities and permits them a reasonable opportunity to take an uninterrupted thirty-minute break, and does not impede or discourage them from doing so.” (Cleveland v. Groceryworks.com, LLC (N.D. Cal. 2016) 200 F.Supp.3d 924, 946.) As such, “an employee must show that he was forced to forego his meal [and rest] breaks as opposed to merely showing that he did not take them regardless of the reason.” (White v. Starbucks Corp. (N.D. Cal. 2007) 497 F.Supp.2d 1080, 1089.)

 

Defendants have supported a triable issue that Plaintiff never missed any meal or rest breaks.

 

            The Court therefore denies summary adjudication on this claim.

 

(5) Wrongful termination in violation of public policy

 

“The elements of a claim for wrongful discharge in violation of public policy are (1) an employer-employee relationship, (2) the employer terminated the plaintiff’s employment, (3) the termination was substantially motivated by a violation of public policy, and (4) the discharge caused the plaintiff harm.” (Nosal-Tabor v. Sharp Chula Vista Medical Center (2015) 239 Cal.App.4th 1224, 1234, citation omitted.)

 

            As should be clear from the background section, the parties present substantially differing accounts of what happened surrounding the employment and termination of Plaintiff.  This renders the discrimination and wrongful termination claims uniquely inappropriate for summary adjudication.

 

By way of example, Defendant has demonstrated viable issues relating to whether Defendant fired Plaintiff because Plaintiff was not competent, rather than because of her pregnancy. Defendant provides declarations stating that Plaintiff had behavior and performance problems and required repeated correction. While Plaintiff has identified some contradictions in Defendant’s separate statement (see RUF 24, contending that Plaintiff had a “joyous, relaxed, and happy all the time demeanor”), the Court is required to resolve disputes and ambiguities of fact in favor of the nonmoving party. Moreover, as discussed in more detail under Plaintiff’s eighth claim for wrongful termination and discrimination, Defendant has demonstrated a triable issue of fact as to whether the pregnancy itself was a substantial motivating factor in her termination. 

 

The Court denies summary adjudication on this claim.

 

(6) Wrongful termination and retaliation

 

“To establish a prima facie case of retaliation under the [Fair Employment and Housing Act] 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.” (Meeks v. Autozone, Inc. (2018) 24 Cal.App.5th 855, 878-879, brackets omitted.) “An ‘adverse employment action,’ which is a critical component of a retaliation claim, requires a substantial adverse change in the terms and conditions of the plaintiff’s employment.” (Holmes v. Petrovich Development Co., LLC (2011) 191 Cal.App.4th 1047, 1063, quotation marks omitted.)

 

            Plaintiff contends that Defendant retaliated against her for requesting pregnancy or family leave. However, the facts do not clearly show that Plaintiff’s termination resulted from her leave requests or her doctor’s appointment. Plaintiff has therefore failed to carry her initial burden to show that there is no triable issue of fact.

 

            Accordingly, the Court denies summary adjudication on this claim.

 

(7) Wrongful termination and harassment

 

To establish a prima facie case of a hostile work environment, [the plaintiff] must show that (1) [plaintiff] is a member of a protected class; (2) [plaintiff] was subjected to unwelcome harassment; (3) the harassment was based on [plaintiff’s] protected status; (4) the harassment unreasonably interfered with [plaintiff’s] work performance by creating an intimidating, hostile, or offensive work environment; and (5) defendants are liable for the harassment.” (Ortiz v. Dameron Hospital Assn. (2019) 37 Cal.App.5th 568, 581.) 

 

“[T]he adjudicator’s inquiry should center, dominantly, on whether the discriminatory conduct has unreasonably interfered with the plaintiff’s work performance. To show such interference, ‘the plaintiff need not prove that his or her tangible productivity has declined as a result of the harassment.’ It suffices to prove that a reasonable person subjected to the discriminatory conduct would find, as the plaintiff did, that the harassment so altered working conditions as to ‘make it more difficult to do the job.’ ” (Harris v. Forklift Sys. (1993) 510 U.S. 17, 25, conc. opn. of Ginsburg, J.; see Gov. Code, § 12923, subd. (a) [endorsing this language as reflective of California law].) A single incident of harassment may be enough to constitute a hostile work environment if it “unreasonably interfered with the plaintiff’s work performance or created an intimidating, hostile, or offensive working environment.” (Gov. Code, § 12923, subd. (b).)¿The court shall use the totality of the circumstances to determine whether there exists a hostile work environment. (Gov. Code, § 12923, subd. (c).)¿

 

            Defendants dispute all of Plaintiff’s factual allegations of verbal harassment based on her pregnancy. (RUF 7-14.) Plaintiff has not provided a reason why this evidence should be disregarded. Thus, there is a triable issue of fact as to whether Plaintiff was harassed.

 

            The Court therefore denies summary adjudication on this claim.

 

(8) Wrongful termination and discrimination

 

To establish a claim for discrimination, a plaintiff must show “that (1) [the plaintiff] was a member of a protected class, (2) [the plaintiff] was qualified for the position [they] sought or was performing competently in the position [they] held, (3) [the plaintiff] suffered an adverse employment action, such as termination, demotion, or denial of an available job, and (4) some other circumstance suggests discriminatory motive.” (Guz v. Bechtel National Inc. (2000) 24 Cal.4th 317, 355.)

 

            FEHA prohibits discrimination based on, inter alia, sex, disability, or medical condition. (Gov. Code, § 12940, subd. (a).) The term “sex” is defined to include pregnancy or medical conditions relating to pregnancy. (Gov. Code, § 12926, subd. (r).)

 

First, Defendant has demonstrated a disputed issue of fact about whether Plaintiff was “performing competently in the position [they] held.” (Guz, supra performing competently.  Defendant has submitted evidence (disputed by Plaintiff) that “[Plaintiff’s] careless attitude towards her co-workers, patients and employers raised great concern to the point she was laid off (during her probationary period). Other factors were her poor work performance, her continuous taking advantage of using work time to do personal activities i.e. phone calls, browsing the web, taking extra breaks, and not completing assigned tasks.” (RUF 21.) While Plaintiff has identified some contradictions in Defendant’s separate statement (see RUF 24, contending that Plaintiff had a “joyous, relaxed, and happy all the time demeanor”), the Court is required to resolve disputes and ambiguities of fact in favor of the nonmoving party.

 

This and other facts demonstrate a dispute about discriminatory motive.  Plaintiff relies on Soroya Malek’s text message to Plaintiff which states that “due to covid-19 crisis and your critical situation and your pregnancy, and the sensitivity of the radiation equipments we use in the clinic. We will regretfully have to lay you off.”  (Castillo Decl., Ex. 2.)  Notwithstanding the listing of “your pregnancy” in this text, Defendant argues that in context of the full text and the other evidence Defendant provided, there was no discriminatory motive.  Defendant argues that the reference to pregnancy was coupled with the concern about radiation equipment, and provides evidence that Plaintiff was exposing herself to the radiation equipment in an unsafe manner without informing anyone.  (Sabri Malek Decl. ¶ 6.)

 

Whether Defendant has demonstrated disputed facts on this issue presents a close question.  However, given the Court’s obligation to consider facts in the light most favorable to the opposing party, the Court agrees that there is a disputed issue of fact on this point.  This is especially true in light of the parties’ sharply differing accounts of the circumstances of Plaintiff’s work and termination.

 

            Because Defendant has supported a triable issue as to whether Plaintiff was performing competently, along with the other facts discussed above, the Court denies summary adjudication on this claim.

 

(9) Failure to engage in interactive process

 

“FEHA requires an informal process with the employee to attempt to identify reasonable accommodations, not necessarily ritualized discussions.” (Nealy v. City of Santa Monica (2015) 234 Cal.App.4th 359, 379.)

 

Once initiated, the employer has a continuous obligation to engage in the interactive process in good faith. “Both employer and employee have the obligation ‘to keep communications open’ and neither has ‘a right to obstruct the process.’” [Citation.] Each party must participate in good faith, undertake reasonable efforts to communicate its concerns, and make available to the other information which is available, or more accessible, to one party. Liability hinges on the objective circumstances surrounding the parties’ breakdown in communication, and responsibility for the breakdown lies with the party who fails to participate in good faith. [Citation.] (Swanson v. Morongo Uni¿ed School Dist. (2014) 232 Cal.App.4th 954, 971–972.)

 

            Plaintiff contends that Defendant never engaged in an interactive process with Plaintiff regarding her pregnancy. It is not clear that Defendant never engaged in an interactive process. Although Defendant did not give Plaintiff time off when first requested for her doctor’s appointment, Defendant has provided evidence that this was because Plaintiff only requested the time off one day in advance, and it is not clear whether Plaintiff ever obtained time off to attend a rescheduled doctor’s appointment or not. Further, Defendant has provided evidence contesting Plaintiff’s evidence that her request for time off in her eighth month of pregnancy was met with hostility. The Court is therefore not prepared to find that Plaintiff has eliminated all triable issues of fact that Defendant failed to engage in an interactive process with her. The Court therefore finds that Plaintiff has not met her initial burden on summary adjudication.

 

            The Court denies summary adjudication on this claim.

 

(10) Waiting time penalties

 

As discussed above, Plaintiff has not shown a substantial delay in her pay stubs during her employment. Although Defendant admits that Plaintiff’s final paycheck upon termination was delayed, Defendant has created a triable issue of fact that this was because Plaintiff requested that her check be mailed to her.

 

The Court therefore denies summary adjudication on this claim.

 

(11) Unfair competition

 

To set forth a claim for a violation of Business and Professions Code section 17200 (“UCL”), Plaintiff must establish Defendant was engaged in an “unlawful, unfair or fraudulent business act or practice and unfair, deceptive, untrue or misleading advertising” and certain specific acts. (Bus. & Prof. Code, § 17200.) A cause of action for unfair competition “is not an all-purpose substitute for a tort or contract action.” (Cortez v. Purolator Air Filtration Products Co. (2000) 23 Cal.4th 163, 173.)

 

            Plaintiff contends that Defendant engaged in unfair business practices by failing to pay her meal and rest break premiums – both in general, and upon termination.

 

            Because this claim is founded in Plaintiff’s wage claims, for which the Court denies summary adjudication, the Court also denies summary adjudication for this claim.