Judge: Lee W. Tsao, Case: 22NWCV00509, Date: 2023-08-24 Tentative Ruling

Case Number: 22NWCV00509    Hearing Date: August 24, 2023    Dept: C

ACEVEDO-COSIO v. PIH HEALTH HOSPITAL WHITTIER

CASE NO.: 22NWCV00509

HEARING:  08/24/23

 

#9

 

Defendant PIH HEALTH WHITTIER HOSPITAL’s Motion for Summary Judgment is DENIED. The alternative Motion for Summary Adjudication is GRANTED in part as to the first through fifth causes of action; and DENIED in part as to the sixth cause of action.  

 

Moving Party to give notice.

 

This wrongful termination action was filed by Plaintiff LILIA ACEVEDO-COSIO (“Plaintiff”) on June 23, 2022.

 

Plaintiff was employed by Defendant PIH HEALTH WHITTIER HOSPITAL (“Defendant” or “PIH”) as a nurse. (Complaint ¶7.) On or around September of 2021, PIH established a COVID-19 policy requiring all employees to be vaccinated against COVID-19 (the ‘Vaccine Mandate’). (Complaint ¶20.) “Plaintiff is a lifelong Christian who believes that her body is a vessel for the Holy Spirit of God, and that the forced injection of an unknown, untested, experimental, and potentially harmful substance into her body is contrary to the Christian mandate to treat the body like a ‘temple.’ Accordingly, Plaintiff did not want to receive a COVID-19 vaccine. Hence, on August 18, 2021, Plaintiff applied for a religious exemption to the COVID-19 vaccine (the ‘Religious Exemption’). (Complaint ¶22.) “The prospect of being forced to inject the COVID-19 vaccination per the Vaccine Mandate, as well as the pressure to get vaccinated which PIH constantly exerted, caused Plaintiff to experience heart palpitations and anxiety attacks. As a direct result of the stress that PIH caused Plaintiff, Plaintiff applied for and was granted medical leave on August 19, 2021.” (Complaint ¶23.) “On or about August 23, 2021, PIH sent Plaintiff an email stating that her Religious Exemption had been approved with respect to vaccination, however, PIH still required Plaintiff to submit to biweekly COVID-19 testing.” (Complaint ¶24.) Plaintiff was allegedly informed that “[t]here were no exemptions offered for testing. None.” (Complaint ¶26.) Plaintiff returned to work from medical leave on or about September 30, 2021. (Complaint ¶30.) On her first day back, “Ms. Boyer asked Plaintiff repeatedly whether Plaintiff had tested. Plaintiff requested that Ms. Boyer provide her question in writing so that Plaintiff could respond in writing. Ms. Boyer became enraged and started yelling at Plaintiff that she needed to answer the question of whether Plaintiff had tested.” (Complaint ¶31.) “Plaintiff received an email informing her that she was being put on unpaid administrative leave.” (Complaint ¶22.) “On or about November 15, 2021, PIH terminated Plaintiff’s employment.” (FAC ¶36.)

 

Plaintiff’s Complaint asserts the following causes of action: (1) Discrimination in Violation of Gov’t Code §§12940, et seq.; (2) Retaliation in Violation of Gov. Code §§12940 et seq.; (3) Failure to Prevent Discrimination and Retaliation in Violation of Gov. Code §§12940(k); (4) Wrongful Termination in Violation of Public Policy; (5) Declaratory Judgment; and (6) Failure to Inspect Personnel and Payroll Records.

 

Defendant PIH HEALTH WHITTIER HOSPITAL (“Defendant” or “PIH”) moves for summary judgment, or alternatively, summary adjudication of the following issues:

·        As to Plaintiff’s First Cause of Action

o   Plaintiff’s first cause of action for religious discrimination fails as a matter of law because Plaintiff cannot demonstrate she suffered an adverse employment action;

o   Plaintiff’s first cause of action for religious discrimination fails because Plaintiff cannot demonstrate that she could have performed the essential job functions of her position without submitting to COVID-19 testing and PIH could not accommodate her request to continue to work in her position without testing because it would have been an undue burden on PIH;

o   Plaintiff’s first cause of action for religious discrimination fails as a matter of law because PIH fully engaged in an interactive process with Plaintiff and she was provided reasonable accommodations, which Plaintiff declined;

o   Plaintiff’s first cause of action for religious discrimination fails because PIH had a legitimate, non-discriminatory reason for the institution of its COVID-19 testing mandate and Plaintiff cannot produce substantial responsive evidence demonstrating such reasons were pretextual.

·        As to Plaintiff’s Second Cause of Action

o   Plaintiff’s second cause of action for retaliation fails as a matter of law because Plaintiff cannot demonstrate that she suffered an adverse employment action;

o   Plaintiff’s second cause of action for retaliation fails as a matter of law because there is no causal link between any “protected activity” and PIH’s decision to place her on administrative leave or deem that Plaintiff was resigning from her position.

·        As to Plaintiff’s Third Cause of Action

o   Plaintiff’s third cause of action for failure to prevent discrimination and retaliation fails as a matter of law because Plaintiff cannot demonstrate that any discrimination or retaliation occurred.

·        As to Plaintiff’s Fourth Cause of Action

o   Plaintiff’s fourth cause of action for wrongful termination in violation of public policy fails as a matter of law because she was not subjected to any actionable discrimination or retaliation.

·        As to Plaintiff’s Fifth Cause of Action

o   Plaintiff’s fifth cause of action for declaratory relief fails because Plaintiff is seeking redress for alleged past wrongs and there is no present or probable future controversy between Plaintiff and Defendant to warrant declaratory relief. In addition, Plaintiff was not subjected to any actionable discrimination or retaliation.

·        As to Plaintiff’s Sixth Cause of Action

o   Plaintiff’s sixth cause of action for failure to inspect personnel and payroll records because PIH produced the required documents in a timely fashion.

·        As to Plaintiff’s Prayer for Punitive Damages

o   Plaintiff’s prayer for punitive damages fails as a matter of law because Plaintiff cannot establish by clear and convincing evidence that she was subjected to discrimination or retaliation and there is no clear and convincing evidence of oppression, fraud or malice.

 

In Opposition, Plaintiff argues that summary judgment/adjudication should be denied because there are a number of material issues of disputed facts.

 

First Cause of Action – Religious Discrimination

To prove a claim of religious discrimination, Plaintiff has the initial burden of making a prima facie showing of each of the following elements: (1) she was a member of a protected class (based on “religious creed”); (2) she was performing competently in the job she held; (3) she suffered an adverse employment action, including but not necessarily limited to termination; and (4) the circumstances suggest a discriminatory motivation for the adverse employment action. (Guz v. Bechtel Nat., Inc. (2000) 24 Cal.4th 317, 355.)

 

Once Plaintiff makes a prima facie case, then a presumption of religious discrimination arises, and the burden shifts to Defendant to rebut the presumption by proving by a preponderance of the evidence that the adverse employment action was not motivated by religious discrimination, but by a legitimate business reason. (Id. at 355-356.) If Defendant makes that showing, then the burden shifts back to Plaintiff to prove by a preponderance of the evidence that the reason given by Defendant is a pretext for actual discriminatory intent. (Id. at 356.)

 

          Prima Facie Showing of Discrimination

In support of its Motion, PIH argues that Plaintiff: (1) cannot demonstrate that she suffered an adverse employment action because she was not terminated; and (2) cannot demonstrate that could perform the essential functions of her job. PIH relies on the following evidence to support its arguments:

·        “Based on the fact that Plaintiff rejected the accommodations provided to her and given there was no other fully-remote positions for Plaintiff, PIH believed that it had no reasonable choice but to deem her as having resigned from her position.” (SS No. 61.)

·        “On August 5, 2021, the CDPH issued a public health order, which required all health facilities licensed by CDPH to implement by September 20, 2021, a mandatory COVID vaccine program for all health care workers, unless the employee qualified for a medical or religious exemption” (SS No. 10.)

·        “Under the August 5, 2021, order, employees who received a medical or religious exemption from the vaccine requirement were still required to undergo regular COVID testing. The CDPH did not recognize any exemption from the testing requirement either for medical or religious reasons.” (SS No. 11.)

 

In Opposition, Plaintiff disputes that any legitimate religious accommodation offer was made to her, and disputes that a fully-remote position was the only option open to PIH. Plaintiff also maintains that she did not resign. (Response to SS No. 61.) Moreover, Plaintiff objects to PIH’s reliance on the CDPH (California Department of Public Health) public health order as hearsay.

 

The Court finds that Plaintiff has raised triable issues as to whether or not she suffered an “adverse employment action”—i.e., whether or not Plaintiff was terminated at PIH’s sole discretion.

 

However, Plaintiff is unable to establish a prima facie case of religious discrimination because she cannot demonstrate that she is able to perform the essential duties of her position without endangering herself or others. “The essential functions of a job are ‘the fundamental…duties of the employment position the individual with a disability holds or desires,’ not including ‘the marginal functions of the position.’ Cal. Gov. Code §12926(f)…. However, other relevant evidence that may be considered in determining the essential functions of a job includes the actual work experience of current or past employees in the job, the amount of time spent performing a function, and the consequences of not requiring that an employee perform a function. [Citations Omitted.]” (Bezzina v. United Airlines, Inc. (2022 WL 878921, at *6.) “With respect to essential functions of a position ‘consideration shall be given to the employer’s judgment… and, if an employer has prepared a written description… for the claimant’s job, this description shall be considered evidence of the essential functions of the job.” (Richardson v. Honda Mfg. of Alabama (2009) 635 F. Supp.2d 1261, 1275-1276.) Here, PIH’s COVID mandate (instituted by the CDPH) made either vaccination or submitting to COVID testing an essential duty.  It is undisputed that Plaintiff returned to work on September 30, 2021 without testing for COVID.  (UMF, ¶38.)  By not getting vaccinated or tested, Plaintiff could not perform the essential duties of her job without endangering herself or others.

 

PIH further argues that, even in the event that Plaintiff could establish a prima facie case, it would have caused an undue burden to allow Plaintiff to work on hospital grounds while untested (and unvaccinated). PIH’s burden would be to show that it reasonably accommodated Plaintiff’s religious beliefs, or that no accommodation was possible without producing undue hardship. (Soldinger v. Northwest Airlines, Inc. (1996) 51 Cal.App.4th 345, 370.) Plaintiff fails to sufficiently raise a triable issue of material fact. It is undisputed that PIH is licensed by the CDPH, and that PIH’s failure to comply with CDPH’s COVID mandates would result in a loss of licensure. Moreover, given the circumstances surrounding the global COVID-19 pandemic at the time, permitting Plaintiff to work on the hospital premises while unvaccinated and untested would have caused an undue burden to PIH, its staff members, and patients.

 

          Legitimate and Non-Discriminatory Reason/Pretext

“An employer moving for summary judgment on a FEHA cause of action may satisfy its initial burden of proving a cause of action has no merit by showing either that one or more elements of the prima facie case is lacking, or that the adverse employment action was based on legitimate nondiscriminatory factors.” (Soria v. Univision Radio Los Angeles, Inc. (2016) 5 Cal.App.5th 570, 591.) “Once the employer sets forth a nondiscriminatory reason for the decision, the burden shifts to the plaintiff to produce substantial responsive evidence that the employer’s showing was untrue or pretextual.” (Id.) “An employer is entitled to summary judgment if, considering the employer’s innocent explanation for its actions, the evidence as a whole is insufficient to permit a rational interference that the employer’s actual motive was discriminatory.” (Id.) To defeat summary adjudication, Plaintiff must produce “substantial responsive evidence that the employer’s showing was untrue or pretextual.” (Hersant v. California Dept. of Social Svcs. (1997) 57 Cal.App.4th 997, 1004-1005.) The employee cannot meet her burden of establishing pretext by simply showing that the employer’s reason was wrong or mistaken, because the issue is not the wisdom of the decision, but whether it was discriminatory. (Wills v. Sup. Ct. (2011) 195 Cal.App.4th 143, 159-160.) “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 fact finder could rationally find them ‘unworthy of credence.’… and hence infer ‘that the employer did not act for the [asserted] nondiscriminatory reasons.” (Sandell v. Taylor-Listug, Inc. (2010) 188 Cal.App.4th 297, 314.)

 

Even assuming that Plaintiff established a prima facie case for discrimination, PIH has shown that its actions were legitimate and non-discriminatory based on the issuance of the CDPH’s mandate. (SS Nos. 10-11.)

 

The burden shifts back to Plaintiff to show that PIH’s nondiscriminatory reasons are pretextual. “If the employer sustains this burden, the presumption of discrimination disappears. The plaintiff must then have the opportunity to attack the employer’s proffered reasons as pretexts for discrimination, or to offer any other evidence of discriminatory motive.” (Guz v. Bechtel National, Inc. (2000) 24 Cal.4th 315, 355.) “At least three types of evidence can be used to show pretext: (1) direct evidence of retaliation, such as statements or admissions, (2) comparative evidence, and (3) statistics.” (Iwekaogwu v. City of Los Angeles (1999) 75 Cal.App.4th 803, 816.) “Direct evidence is evidence which, if believed, proves the fact [of discriminatory animus’ without inference or presumption.’ [Citation.]” (Godwin v. Hunt  Wesson, Inc. (9th Cir. 1998) 150 F.3d 1217, 1221.) Here, Plaintiff offers no evidence of pretext. The CDPH instituted a neutral policy requiring mandatory COVID vaccination or testing for all healthcare workers. There was no exemption for submitting to COVID testing, regardless of religious affiliation.

Summary adjudication of the first cause of action is GRANTED.

 

Second Cause of Action – Retaliation (Gov. Code §12940(h).)

Gov. Code §12940(h) makes it an unlawful business practice “[f]or any employer… to discharge, expel, or otherwise discriminate against any person because the person has opposed any practices forbidden under this part or because the person has filed a complaint, testified, or assisted in any proceeding under this part.” “To establish a prima facie case of retaliation under 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. [Citations.]” (Nealy v. City of Santa Monica (2015) 234 Cal.App.4th 359, 380.)

 

Summary adjudication is GRANTED.

 

Plaintiff fails to submit sufficient evidence to show that the proffered reasons for her termination were a pretext for a retaliatory motive. Plaintiff relies on the following facts: PIH engaged in unlawful retaliation by placing her on unpaid leave for remaining unvaccinated, and then eventually terminating her because of her refusal to get vaccinated and/or submit to COVID testing. Plaintiff argues that there is a causal link between her religious objection and the adverse employment action.

 

Plaintiff is unable to establish a prima facie case of retaliation because the alleged adverse employment actions (either being placed on unpaid leave or getting fired) are unconnected to Plaintiff’s accommodation requests. The vaccine/testing policies existed before Plaintiff opposed the testing requirement/was placed on administrative leave. “[I]t is not reasonable to infer that there was a causal connection between her criticism of the policy and her termination.”  (Lundstrom v. Contra Costa Health Svcs. (2022 WL 17330842, at *7)

 

Third Cause of Action – Failure to Prevent Religious Harassment, Discrimination, and Retaliation

Gov. Code §12940(k) makes it an independent tort for employers “to fail to take all reasonable steps necessary to prevent discrimination and harassment from occurring.” A successful claim for Failure to Prevent Harassment, Discrimination, and Retaliation depends on whether Plaintiff has adequately alleged claims for  for Harassment, Discrimination, or Retaliation. As indicated above, Plaintiff has not successfully alleged a claim for Religion-Based Discrimination sufficient to withstand summary adjudication.

 

Accordingly, summary adjudication of the third cause of action is GRANTED.

 

Fourth Cause of Action – Wrongful Termination

Plaintiff’s fourth cause of action is for wrongful termination in violation of public policy. In moving for summary adjudication on Plaintiff’s Tameny claim, PIH essentially repeats all of the material facts asserted in connection with other causes of action. Because Plaintiff has not successfully alleged her underlying  claims for Religion-Based Discrimination or Retaliation, summary adjudication is GRANTED.

 

Fifth Cause of Action – Declaratory Relief

Plaintiff seeks a judicial declaration that her religion/engagement in protected activity was a substantial motivating factor in an adverse employment action being taken against her by PIH.

 

PIH argues that it is entitled to summary adjudication of this claim because an actual, present controversy has not been established. Plaintiff no longer works for PIH, and declaratory relief is not available to redress past wrongs. This argument lacks merit. “Declaratory relief, where appropriate, may serve to reaffirm the plaintiff’s equal standing among her coworkers and community, and to condemn discriminatory employment policies or practices.” (Harris v. Santa Monica (2013) 56 Cal.4th 203, 234.)

 

Notwithstanding, PIH additionally argues that this claim is essentially derivative of all of Plaintiff’s other claims. As summary adjudication of those claims is appropriate for reasons articulated above, it follows that summary adjudication of Plaintiff’s claim for declaratory relief is also warranted. Summary adjudication is GRANTED.

 

Sixth Cause of Action – Failure to Inspect Personnel and Payroll Records

“An employer who receives a written or oral request to inspect or receive a copy of records pursuant to subdivision (b) pertaining to a current or former employee shall comply with the request as soon as practicable, but not later than 21 calendar days form the date of the request.” (Cal. Labor Code §226(c).)

 

Plaintiff requested employment records on October 18, 2021. 21 days from October 18, 2021 is November 8, 2021. Records were provided to Plaintiff’s counsel on November 4 and 12, 2021. Thus, Plaintiff maintains that the November 12, 2021 production is untimely and that summary adjudication must be denied.

 

It is undisputed that PIH untimely produced Plaintiff’s records on November 12, 2021- beyond 21 days of Plaintiff’s written request. (See SS No. 65 and Response to SS No. 65.) Summary adjudication is DENIED.

 

Punitive Damages

A claim for punitive damages is properly the subject of a motion for summary adjudication. Summary adjudication may only be granted when an entire claim for punitive damages is eliminated. (Catalano v. Sup. Ct. (2000) 82 Cal.App.4th 91, 92.)

 

Pursuant to Cal. Civ. Code §3294(b), “[a]n employer shall not be liable for damages…based upon acts of an employee of the employer, unless the employer had advance knowledge of the unfitness of the employee and employed him or her with a conscious disregard of the rights or safety of others or authorized or ratified the wrongful conduct for which the damages are awarded or was personally guilty of oppression, fraud, or malice. With respect to a corporate employer, the advance knowledge and conscious disregard, authorization, ratification or act or oppression, fraud, or malice must be on the part of an officer, director, or managing agent of the corporation.” (Id.) “ ‘Malice’ means conduct which is intended by the defendant to cause injury to the plaintiff or despicable conduct which is carried on by the defendant with a willful and conscious disregard for the rights and safety of others.” (Cal. Civ. Code §3294(c)(1).) Oppression “means despicable conduct that subjects a person to cruel and unjust hardship in conscious disregard of that person’s rights.” (Cal. Civ. Code §3294(c)(2).) Fraud “means an intentional misrepresentation, deceit, or concealment of a material fact known to the defendant with the intention on the part of the defendant of thereby depriving a person or property or legal rights or otherwise causing injury.” (Cal. Civ. Code §3294(c)(3).) Summary adjudication on a punitive damages claim is properly granted when a plaintiff fails to present clear and convincing evidence of tortious conduct that was malicious, fraudulent or in blatant violation of law or policy. (Food Pro International, Inc. v. Farmers Ins. Exchange (2008) 169 Cal.App.4th 976, 995.)

 

“[A]n unlawful termination, without more, is insufficient. In general, ‘[p]unitive damages are proper only when the tortious conduct rises to levels of extreme indifference to the plaintiff’s rights, a level which decent citizens should not have to tolerate.’ [Citation.] Thus, ‘[s]omething more than the mere commission of a tort is always required for punitive damages. There must be circumstances of aggravation or outrage, such as spite or ‘malice,’ or a fraudulent or evil motive on the part of the defendant, or such a conscious and deliberate disregard of the interests of others that his conduct may be called willful or wanton.’” (Ocampo v. HeiTech Services, Inc. (2020) (N.D. Cal., Sept. 16, 2020) 2020 WL 5545286, at *7.)

 

Punitive damages are not warranted here because, “the only evidence of wrongful conduct directed towards [the plaintiff] was her termination for an improper reason. [Citation.]” (Id.) This is not enough to support a claim for punitive damages.

 

Summary adjudication of Plaintiff’s claim for punitive damages against is GRANTED.

 

Given the Court’s ruling as to the sixth cause of action, the Motion for Summary Judgment is DENIED.

 

Plaintiff’s Evidentiary Objections

1.    Sustained

2.    Overruled

3.    Overruled

4.    Overruled

5.    Overruled

6.    Sustained

7.    Sustained

8.    Sustained

9.    Sustained

10.  Sustained

11.  Sustained

12.  Sustained

13.  Sustained

14.  Sustained

15.  Sustained

16.  Sustained

17.  Overruled

18.  Overruled

19.  Overruled

20.  Overruled

21.  Overruled

22.  Overruled

23.  Sustained

24.  Sustained

25.  Overruled

26.  Overruled

27.  Overruled

28.  Overruled

29.  Overruled

30.  Overruled

31.  Overruled

32.  Overruled

33.  Overruled

34.  Overruled

35.  Overruled

36.  Overruled

37.  Overruled

38.  Overruled

39.  Overruled

40.  Overruled

41.  Overruled

42.  Overruled

43.  Overruled

44.  Overruled

45.  Overruled

46.  Overruled

47.  Overruled

48.  Overruled

 

Defendant’s Evidentiary Objections

Nos. 1-24. Overruled

 

Defendant’s Objections to Exhibits Attached to Declaration of Lilia Acevedo-Cosio

Overruled as to Exs. 3, 5, and 6; Sustained as to Ex. 15.