Bailey v. San Francisco District Attorney's Office CA1/1

CourtCalifornia Court of Appeal
DecidedJanuary 22, 2025
DocketA153520A
StatusUnpublished

This text of Bailey v. San Francisco District Attorney's Office CA1/1 (Bailey v. San Francisco District Attorney's Office CA1/1) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bailey v. San Francisco District Attorney's Office CA1/1, (Cal. Ct. App. 2025).

Opinion

Filed 1/22/25 Bailey v. San Francisco District Attorney’s Office CA1/1 Opinion on remand from Supreme Court NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION ONE

TWANDA BAILEY, Plaintiff and Respondent, A153520 v. SAN FRANCISCO DISTRICT ATTORNEY’S OFFICE et al., (San Francisco City & County Super. Ct. No. CGC-15-549675) Defendants and Respondents.

This case is before us on remand after our Supreme Court clarified issues pertaining to race harassment and retaliation claims actionable under the California Fair Employment and Housing Act (FEHA).1 The high court’s principal ruling was that a coworker’s one-time use of a racial epithet can create a “hostile work environment” and whether it does so, requires an examination of “the totality of the circumstances” viewed from the “ ‘perspective of a reasonable person belonging to the racial or ethnic group of the plaintiff.’ ” (Bailey v. San Francisco District Attorney’s Office (2024) 16 Cal.5th 611, 629–630, 634 (Bailey).) The court further ruled there are triable issues as to (1) whether plaintiff Twanda Bailey’s coworker’s “one- time use of the N-word was, under the totality of the circumstances,

Government Code section 12900, et seq. All further statutory 1

references are to the Government Code, unless otherwise indicated. 1 sufficiently severe so as to create a hostile work environment” supporting a harassment claim (id. at p. 634) and (2) whether Bailey “suffered an adverse employment action” at the hands of the City and County of San Francisco supporting a retaliation claim.2 (Id. at pp. 634, 641.) The Supreme Court also directed that we reconsider two issues. The first is whether there is a triable issue as to the City’s liability for harassment if Bailey’s coworker’s racial slur is found to have created a hostile work environment. The City’s liability turns on whether it took “immediate and appropriate corrective action” upon learning of the coworker’s use of the N-word. (Id. at pp. 635–636.) We conclude there is a triable issue as to whether the City took such action, and therefore there is a triable issue as to whether the City is liable for harassment should the trier of fact find the coworker’s racial epithet created a hostile work environment. The second issue is whether, given the Supreme Court’s rulings, Bailey’s claims against the City for “discrimination” and for “failure to prevent discrimination” have been revived. (Bailey, supra, 16 Cal.5th at p. 642, fn. 10.) We conclude the answer is, in part, yes. DISCUSSION3 Immediate and Appropriate Corrective Action As the Supreme Court explained in Bailey, “ ‘When the harasser is a supervisor, the employer is strictly liable for the supervisor’s actions.’ (Roby [v. McKesson Corp. (2009)] 47 Cal.4th [686,] 707 [(Roby)].) ‘When the harasser is a nonsupervisory employee, employer liability turns on a showing of negligence. . . .’ (Ibid.) Specifically, ‘[h]arassment of an employee . . . by an

2 We collectively refer to defendants as the City. 3Because the parties are fully conversant with the factual and procedural background, we do not repeat it here.

2 employee, other than an agent or supervisor, shall be unlawful if the entity, or its agents or supervisors, knows or should have known of this conduct and fails to take immediate and appropriate corrective action.’ (§ 12940, subd. (j)(1).)” (Bailey, supra, 16 Cal.5th at p. 635.) Observing it had “not previously had occasion to evaluate whether an employer’s response to harassment constitutes ‘immediate and appropriate corrective action[]’ (§ 12940, subd. (j)(1)),” the high court stated that “[i]n the analogous context of [title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq. (Title VII)] claims, the federal courts ask whether an employer has taken ‘ “adequate remedial measures” ’ that are ‘ “ ‘reasonably calculated to end the harassment.’ ” ’ ” (Bailey, supra, 16 Cal.5th at p. 635, quoting Nichols v. Azteca Restaurant Enterprises, Inc. (9th Cir. 2001) 256 F.3d 864, 875 (Nichols).) More specifically, “[t]he reasonableness of the remedy depends on its ability to stop the current harassment and deter future harassment.” (Bailey, at p. 635.) “Our state appellate courts have applied this same standard in assessing claims arising under FEHA.” (Ibid.) Federal cases, however, differ somewhat in their application of the Title VII adequate-remedial-measures reasonably-calculated-to-end-the- harassment standard. The City relies on cases taking the view that if the alleged harassment stops after the employer takes some action, the employer is not liable. (E.g., Adler v. Wal-Mart Stores, Inc. (10th Cir. 1998) 144 F.3d 664, 676 [“A stoppage of harassment shows effectiveness, which in turn evidences . . . reasonable calculation.”]; see E.E.O.C. v. Xerxes Corp. (4th Cir. 2011) 639 F.3d 658, 670 [“ ‘A remedial action that effectively stops the harassment will be deemed

3 adequate as a matter of law.’ ”]; see also Andreoli v. Gates (3d Cir. 2007) 482 F.3d 641, 644, fn. 2 [same].)4 Hostetler v. Quality Dining, Inc. (7th Cir. 2000) 218 F.3d 798 (Hostetler), explains the rationale underlying this view. In that case, the plaintiff, a supervisor at a fast-food restaurant, claimed she was sexually harassed and assaulted by a coworker. (Id. at p. 802.) She eventually reported the conduct to her superiors and met with them. (Id. at pp. 802– 803.) What was said during the meeting was sharply disputed. The plaintiff claimed the district manager seemed to suggest she was the problem, rather than the coworker, who denied the plaintiff’s claims. (Ibid.) The supervisors claimed they had assured the plaintiff sexual harassment was not tolerated and that an investigation would be commenced immediately. (Id. at p. 803, fns. 2 & 3.) According to them, an investigation was commenced, and supervisors promptly spoke with the coworker, apprising him of the company’s policy on sexual harassment, telling him if the alleged conduct had occurred it constituted sexual harassment, and warning him if it happened again, it would result in disciplinary action. (Id. at p. 803, fn. 3.) Before the investigation was completed, the coworker quit. (Ibid.) The plaintiff was thereafter transferred to another location, resulting in her working evening and night hours and having a longer commute. (Id. at p. 804.) She claimed it was in retaliation for her complaint. (Ibid.) The defendants asserted otherwise. (Ibid.) The district court granted summary judgment to the defendants on the ground the alleged harassment did not rise to the level of creating a hostile work environment (id. at p. 805) and the employer, in any case, took prompt and reasonable corrective action. (Id. at p. 806.) The

4 While the City did not cite the latter two cases, they are also illustrative of the view the City takes. 4 circuit court reversed, ruling there were triable issues as to whether the coworker’s alleged conduct created a hostile work environment (id. at pp. 807–809) and, given the plaintiff’s transfer, whether the employer had taken appropriate corrective action. (Id. at p.

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Bailey v. San Francisco District Attorney's Office CA1/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bailey-v-san-francisco-district-attorneys-office-ca11-calctapp-2025.