Judge: Mark C. Kim, Case: 21LBCV00427, Date: 2022-12-20 Tentative Ruling

Case Number: 21LBCV00427    Hearing Date: December 20, 2022    Dept: S27

1.     Background Facts

Plaintiff, Nora Salinas Macias filed this action against Defendant, Super Center Concepts, Inc., Superior Grocers, and Superior Super Warehouse for disability discrimination, retaliation, failure to prevent discrimination, harassment, and retaliation, failure to provide reasonable accommodations, failure to engage in the good faith interactive process, wrongful termination, IIED, and declaratory judgment. 

 

Plaintiff alleges Defendants hired her in 2004 to work as a non-exempt cashier.  She alleges she reported a work injury in May of 2019 and noticed her hours were significantly reduced beginning in June of 2019.  She alleges a co-worker told her hours had been decreased because the store manager, Lisa Case, wanted her to quit; Case also allegedly refused to allow her to take her ten-minute break to rest her injured knee. 

Plaintiff alleges she filed a workers’ compensation claim in June of 2019, and started leave on 7/01/19.  She alleges she submitted doctor’s notes to Defendants monthly to extend her medical leave.  She alleges she updated her address with Defendants on 7/07/19.  On 9/17/19, Defendants mailed a notification to Plaintiff’s old address asking for documentation to extend medical leave.  Plaintiff did not receive the notification, and called on 9/25/19 to check on her employment status, at which time she was told she had been terminated.  She explained that she never received any notice, and that she remained on medical leave as certified by her doctor. 

 

Plaintiff filed her complaint on 8/11/21.  She dismissed Superior Grocers and Superior Super Warehouse on 10/26/21. 

 

2.     Motion for Summary Judgment/Adjudication    

  1. Burdens on Summary Judgment

Summary judgment is proper “if all the papers submitted 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.”  (Code Civ. Proc. §437c(c).)  Where a defendant seeks summary judgment or adjudication, he must show that either “one or more elements of the cause of action, even if not separately pleaded, cannot be established, or that there is a complete defense to that cause of action.”  (Id. at §437c(o)(2).)  A defendant may satisfy this burden by showing that the claim “cannot be established” because of the lack of evidence on some essential element of the claim.  (Union Bank v. Superior Court (1995) 31 Cal.App.4th 574, 590.)  Once the defendant meets this burden, the burden shifts to the plaintiff to show that a “triable issue of one or more material facts exists as to that cause of action or defense thereto.”  (Ibid.) 

 

The moving party bears the initial burden of production to make a prima facie showing that there are no triable issues of material fact.  (Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 850.)  A defendant moving for summary judgment must show either (1) that one or more elements of the cause of action cannot be established or (2) that there is a complete defense to that cause of action.  (Id. at §437c(p).)  A defendant may discharge this burden by furnishing either (1) affirmative evidence of the required facts or (2) discovery responses conceding that the plaintiff lacks evidence to establish an essential element of the plaintiff's case. If a defendant chooses the latter option he or she must present evidence “and not simply point out that plaintiff does not possess and cannot reasonably obtain needed evidence….” Aguilar, supra, 25 Cal.4th at 865-66,

[A] defendant may simply show the plaintiff cannot establish an essential element of the cause of action “by showing that the plaintiff does not possess, and cannot reasonably obtain, needed evidence.” (Id. at p. 854.)  Thus, rather than affirmatively disproving or negating an element (e.g., causation), a defendant moving for summary judgment has the option of presenting evidence reflecting the plaintiff does not possess evidence to prove that element. “The defendant may, but need not, present evidence that conclusively negates an element of the plaintiff's cause of action. The defendant may also present evidence that the plaintiff does not possess, and cannot reasonably obtain, needed evidence—as through admissions by the plaintiff following extensive discovery to the effect that he has discovered nothing” to support an essential element of his case. (Aguilar, supra, at p. 855.) Under the latter approach, a defendant's initial evidentiary showing may “consist of the deposition testimony of the plaintiff's witnesses, the plaintiff's factually devoid discovery responses, or admissions by the plaintiff in deposition or in response to requests for admission that he or she has not discovered anything that supports an essential element of the cause of action.” (Lona v. Citibank, N.A., supra, 202 Cal.App.4th at p. 110.)  In other words, a defendant may show the plaintiff does not possess evidence to support an element of the cause of action by means of presenting the plaintiff's factually devoid discovery responses from which an absence of evidence may be reasonably inferred. (Scheiding v. Dinwiddie Construction Co. (1999) 69 Cal.App.4th 64, 83.)

Thus, a moving defendant has two means by which to shift the burden of proof under the summary judgment statute: “The defendant may rely upon factually insufficient discovery responses by the plaintiff to show that the plaintiff cannot establish an essential element of the cause of action sued upon. [Citation.] [Or a]lternatively, the defendant may utilize the tried and true technique of negating (‘disproving’) an essential element of the plaintiff's cause of action.” (Brantly v. Pisaro (1996) 42 Cal.App.4th 1591, 1598.)

Leyva v. Garcia (2018) 20 Cal.App.5th 1095, 1103.

 

Until the moving defendant has discharged its burden of proof, the opposing plaintiff has no burden to come forward with any evidence. Once the moving defendant has discharged its burden as to a particular cause of action, however, the plaintiff may defeat the motion by producing evidence showing that a triable issue of one or more material facts exists as to that cause of action.  (Id. at §437c(p)(2).)  On a motion for summary judgment, the moving party's supporting documents are strictly construed and those of his opponent liberally construed, and doubts as to the propriety of summary judgment should be resolved against granting the motion.  (D’Amico v. Board of Medical Examiners (1974) 11 Cal.3d 1, 21.)

 

  1. Evidentiary Objections

Plaintiff submitted evidentiary objections with her opposition papers.  Defendant filed a response to those objections with its reply papers.  Plaintiff objects to the entirety of the Montes and Bonilla Declarations on various grounds.  There are, at minimum, portions of both declarations that are not subject to objection.  The objections are therefore overruled. 

 

Defendant submitted objections with its reply papers.  Defendant objects to Plaintiff’s entire declaration on the ground that Plaintiff only speaks Spanish and there is no declaration concerning translation.  The Court lacks personal knowledge concerning what language Plaintiff speaks, and the objection cites no evidence to support the conclusion that she only speaks Spanish.  Additionally, at most the Court would sustain this objection and permit Plaintiff to cure the defect.  The Court has considered the declaration.

 

The remaining objections are also overruled.

 

  1. Termination-Related Claims

i.              Parties’ Positions

Defendant argues the Court should summarily adjudication all of Plaintiff’s termination-related claims because it had a legitimate, non-pretextual reason to terminate Plaintiff’s employment, and Plaintiff cannot raise a triable issue of material fact concerning pretext. 

 

Plaintiff argues there is evidence of pretext, such that summary adjudication must be denied.

 

ii.             Relevant Law

When an employer moves for summary adjudication of a discrimination/wrongful termination claim, the employer must carry the burden of showing the employee's action has no merit (CCP §437c(p)(2)). It may do so by evidence either:

— negating an essential element of the employee's claim; or

— showing some legitimate, nondiscriminatory reason for the action taken against the employee.  Caldwell v. Paramount Unified School Dist. (1995) 41 Cal.App.4th 189, 202-203.

If the employer meets this initial burden, to avoid summary judgment the employee must produce “substantial responsive evidence that the employer's showing was untrue or pretextual,” thereby raising at least an inference of discrimination.  Hersant v. California Dept. of Social Services (1997) 57 Cal.App.4th 997, 1004-1005.  A plaintiff's “suspicions of improper motives … primarily based on conjecture and speculation” are clearly not sufficient to raise a triable issue of fact to withstand summary judgment.  Kerr v. Rose (1990) 216 Cal.App.3d 1551, 1564.  Evidence showing facts inconsistent with the employer's claimed reasons tends to prove the employer's discriminatory intent.  Martin v. Lockheed Missiles & Space Co. (1994) 29 Cal.App.4th 1718, 1735.

 

“Pretext” does not require proof that discrimination was the only reason for the employer's action. When there are mixed motives for the employer's action, it is enough that discriminatory intent was a substantial motivating factor in the employer's decision to take the adverse action. Harris v. City of Santa Monica (2013) 56 Cal.4th 203, 232. 

 

An employee may also avoid summary judgment by attacking the credibility of the employer's declarations; i.e., by demonstrating “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 discriminatory intent.  Hersant v. California Dept. of Social Services (1997) 57 Cal.App.4th 997, 1005.  However, though “disbelief of an Employer's stated reason for a termination gives rise to a compelling inference that the Employer had a different, unstated motivation, … it does not, without more, reasonably give rise to an inference that the motivation was a prohibited one.”  McGrory v. Applied Signal Technology, Inc. (2013) 212 Cal.App.4th 1510, 1531-1532. 

 

Notably, it is not enough for the employee to raise triable issues of fact concerning whether the employer's reasons for taking the adverse action were sound (e.g., refuting claims of poor job performance): “The employee cannot simply show that the employer's decision was wrong or mistaken, since the factual dispute at issue is whether discriminatory animus motivated the employer, not whether the employer is wise, shrewd, prudent or competent.”  Hersant, supra at 1005.

iii.            Moving Burden

Defendant provides evidence that it received doctor’s notes extending Plaintiff’s leave through the end of August, but did not ever receive a note in September.  See, specifically, fact 28.  It provides evidence that it terminated her for being away from work while not on a medical leave of absence thereafter.  See fact 29.  This is sufficient to meet the moving burden.

 

iv.            Triable Issues of Material Fact

Plaintiff adequately presents triable issues of material fact concerning whether Defendant’s stated reason for her termination was a mere pretext.  Specifically, Plaintiff provides evidence that, on 9/02/19, she attempted to call Defendant re: a new note, but the call was not returned.  She then called Tina Lopez, a manager for Defendant, who told her she did not need to bring in a new note because the dispute was between her workers’ compensation lawyer and her job. 

 

Plaintiff admits she gave Defendant a change of address form very late.  She gave Defendant the form, however, by Defendant’s own admission, in July of 2019, well before any of the events that form the basis of her termination.  Defendant admits the form was properly lodged, but did not make its way into Defendant’s computer system.  Fact 32.  It sent a return to work letter on 9/10/19 (fact 33), and Plaintiff did not respond because she did not receive the letter (fact 34).  On 9/17/19, Defendant sent a second return to work letter, also to the old address (Plaintiff had moved again, but was still receiving mail at the address updated in the system).  Plaintiff also did not receive this letter.  Plaintiff provides evidence that leads to a reasonable conclusion that Defendant knew she did not receive the letters; specifically, she provides evidence that she called on 9/25/19 and talked to Laura Bonilla in HR, who told her to write down the tracking numbers for the letters and pick them up at the post office.  Plaintiff’s additional fact 38.

 

Plaintiff relies on Alejandro v. ST Micro Electronics, Inc., 129 F.Supp.3d 898, 912 (2015) to support her position that Defendant’s obligation to engage in the interactive process continued even after Plaintiff’s termination, once Defendant learned of the true facts showing the termination was disability-related.  Alejandro is a federal district court case.  Additionally, while it briefly mentions a refusal to reconsider the termination after learning of the disability, that is only one part of the process that it entirely determined was sufficiently alleged to defeat demurrer. 

 

Regardless, the Court finds there are triable issues of material fact re: whether Defendant knew Plaintiff had been out on disability, knew she was not receiving the letters being mailed, and/or told Plaintiff, through its agent, that she need not provide an additional documentation concerning her disability, and yet it still fired Plaintiff.  The foregoing, if proven true to a jury, could lead the jury to determine the stated reason for termination, failure to return to work at the completion of medical leave, was merely pretextual.  The motion for summary adjudication of the termination-related claims is therefore denied.

 

  1. Non-Termination Related Discrimination and Retaliation Claims

Defendant’s second argument, found at page 18 of its moving brief, is that Plaintiff’s non-termination related discrimination and retaliation claims fail as a matter of law.  Defendant fails to state which causes of action it is challenging by way of this section of its brief, and fails to indicate which of the fourteen purported issues on summary adjudication are relevant to this section of its brief.  Notably, at line 8 of page 18, it contends the claims are all based on termination and/or reduced hours. 

 

Defendant failed to show there are any causes of action in the complaint based solely on an alleged reduction in hours.  It therefore failed to show any cause of action can or should be summarily adjudicated on this basis.  The Court declines to determine whether it met its burden in regards to reduced work hours and/or whether there are triable issues of material fact concerning reduced work hours. 

 

  1. Failure to Provide Accommodations

Defendant’s argument re: failure to provide accommodations is substantially the same as its argument re: wrongful termination.  It argues it accommodated her each time she provided a doctor’s note seeking accommodation.  The accommodation at the heart of this case, however, is the accommodation of an extended leave of absence commencing in September of 2019 in lieu of termination.  Because there are triable issues of material fact concerning wrongful termination, there are necessarily triable issues of material fact concerning failure to provide this additional necessary accommodation.

 

  1. Failure to Engage in the Interactive Process

Defendant correctly notes that the failure to engage in the interactive process claim rises and falls with the other claims.  Because the motion for summary adjudication of the other claims fails, this motion also fails.

 

  1. Intentional Infliction of Emotional Distress

Defendant, in its separate statement in support of its request for summary adjudication of the IIED cause of action, merely incorporates facts 1-173 by reference.  Because there are triable issues of material fact concerning facts 1-173, as discussed above, the motion for summary adjudication of the IIED cause of action is also denied.

 

  1. Punitive Damages

Civil Code §3294 requires an act of oppression, fraud, or malice by an officer, director, or managing agent of the defendant.  Defendant argues that the only person Plaintiff accuses of such conduct, Liz Casas, is not an officer, director, or managing agent.  Declaration of Montes, ¶6. 

 

Plaintiff correctly notes, in opposition to the motion, that her complaint is not premised solely on the conduct of Casas.  Nothing in the complaint suggests only Casas’s actions subject Defendant to punitive damages.  Plaintiff merely alleges Defendant acted with fraud, malice, and/or oppression in connection with the acts giving rise to her wrongful termination.  Defendant’s moving papers do not attempt to negate this allegation. 

 

Additionally, Defendant’s separate statement, in connection with the punitive damages issue, incorporates facts 1-175 by reference and then provides evidence that Casas is not an officer, director, or managing agent.  By incorporating facts 1-175 by reference, Defendant admits those facts are all relevant.  There are, however, triable issues of material fact relating to facts 1-175, as discussed above. 

 

The motion for summary adjudication is therefore denied.

 

  1. Conclusion

Defendant’s motion for summary judgment is denied.  Its alternative motion for summary adjudication is also denied.

 

Defendant is ordered to give notice. 

 

Parties who intend to submit on this tentative must send an email to the court at gdcdepts27@lacourt.org indicating intention to submit on the tentative as directed by the instructions provided on the court website at www.lacourt.orgIf the department does not receive an email indicating the parties are submitting on the tentative and there are no appearances at the hearing, the motion may be placed off calendar.  If a party submits on the tentative, the party’s email must include the case number and must identify the party submitting on the tentative.  If the parties do not submit on the tentative, they should arrange to appear remotely.