Civil Rights Dept. v. Space Exploration Technologies

California Court of Appeal·Decided September 9, 2026·No. B346853·Published

Opinion

Filed 8/11/26; Certified for Partial Pub. 9/9/26 (order attached)

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION THREE

CIVIL RIGHTS B346853 DEPARTMENT, Los Angeles County

Plaintiff and Respondent, Super. Ct. No.

25STCP01327

v.

SPACE EXPLORATION TECHNOLOGIES CORP.,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Los Angeles County, Maureen Duffy-Lewis, Judge. Affirmed.

Morgan, Lewis & Bockius, Jennifer B. Zargarof, Joseph Bias, Thomas M. Peterson; Horvitz & Levy and Jeremy B. Rosen for Defendant and Appellant.

Rob Bonta, Attorney General, Michael L. Newman, Assistant Attorney General, William H. Downer, Lucia J. Choi and Jennifer M. Soliman, Deputy Attorneys General, for Plaintiff and Respondent.

Space Exploration Technologies Corp. (SpaceX) appeals an order compelling it to comply with the California Civil Rights Department’s (CRD) investigatory subpoena. CRD issued the subpoena after receiving an administrative complaint from a former SpaceX employee alleging violations of California’s Fair Employment and Housing Act (FEHA, Gov. Code, § 12900 et. seq.).1 SpaceX argues the federal constitution, the presumption against extraterritorial application of laws, and FEHA precluded CRD from investigating the complaint because it alleges conduct outside FEHA’s territorial reach. We conclude SpaceX has not met its burden to show error on any of these grounds. Accordingly, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND 1. The administrative complaint In April 2024, a former SpaceX employee (the Employee)

filed a complaint with CRD alleging the company discriminated and retaliated against her in violation of FEHA. The Employee listed a California address for SpaceX. She alleged SpaceX paid her less than a male employee hired around the same time and passed her over for a promotion in favor of a less experienced male employee. The Employee asserted SpaceX eventually increased her and another female employee’s salary, without giving any reason for doing so. The Employee also alleged SpaceX terminated her in retaliation for her participation in drafting and circulating an open letter criticizing the company and its CEO for creating a hostile work environment and engaging in sexual harassment and gender discrimination.

1 Undesignated statutory references are to the Government Code.

2. The investigation After receiving the complaint, CRD served on SpaceX interrogatories and a subpoena duces tecum seeking information related to the Employee and her allegations. SpaceX objected to all the requests on the ground that CRD lacked jurisdiction over the claims because the Employee was a resident of Washington and FEHA does not apply outside California. Notwithstanding that objection, SpaceX agreed to produce the Employee’s resume and application, as well as records of her badge swipes.

In response to SpaceX’s objection, CRD agreed to focus its investigation on the jurisdictional questions before deciding whether to investigate the merits of the Employee’s claims. CRD identified 14 discovery requests seeking information related to the location where the conduct giving rise to the claims took place, and it asked SpaceX to respond to those specific requests.

SpaceX eventually provided supplemental responses.

Based on those responses, CRD determined it had jurisdiction over the retaliation claim. However, CRD concluded SpaceX had not provided enough information for it to determine whether it had jurisdiction over the discrimination claims. CRD asked SpaceX to respond to discovery requests related to the merits of the retaliation claim and provide more information related to its jurisdiction over the discrimination claims. SpaceX apparently declined to do so. 3. The petition In April 2025, CRD filed a petition in the superior court seeking an order compelling SpaceX to comply with its subpoena. CRD asked the court specifically to compel SpaceX to produce documents that would help it to evaluate the merits of the

Employee’s retaliation claim and the jurisdictional issue concerning her discrimination claims.

CRD acknowledged SpaceX hired the Employee to work in its Redmond, Washington office. However, CRD stated the law requires it to investigate the allegations and determine whether the conduct has a substantial connection to California. CRD argued FEHA applies to non-California residents if the discriminatory conduct occurred in California. Therefore, it needed to investigate whether SpaceX’s alleged discriminatory conduct occurred or was ratified in California, where SpaceX was headquartered at the time. 4. SpaceX’s opposition SpaceX opposed the petition. It argued, because the employee lived and worked in Washington, CRD’s assertion of jurisdiction violates the United States Constitution and California law. According to SpaceX, Washington-based managers determined the Employee’s compensation, position, and promotion opportunities. SpaceX argued its company-wide policies were “entirely irrelevant” to CRD’s jurisdiction, and the Employee’s employment was governed solely by Washington law. SpaceX asserted that the mere possibility the discriminatory conduct may have occurred or been ratified in California was too speculative.

In support of its opposition, SpaceX submitted a declaration from its Director of Human Resources for the Redmond, Washington office, Theresa Roncari. Roncari stated the Employee was hired to work in Washington, assigned to work in Washington, and lived in Washington during the relevant times.

Roncari asserted Redmond-based managers—who have discretion and are the ultimate decisionmakers for compensation and promotion—were “primarily responsible” for determining the employee’s compensation, position, and promotion opportunities. Roncai said SpaceX’s Senior Director of Human Resources, Lindsay Chapman, flew to Washington and interviewed the employee as part of an investigation into the open letter. Chapman made the decision to terminate the employee while in Washington. Two days after the interview, Chapman called the employee at her residence in Washington to notify her of the termination. Roncari asserted SpaceX terminated the Employee for violating its policy against leaking confidential company information and dishonesty during an internal investigation. 5. CRD’s reply In its reply, CRD asked the court to take judicial notice of a complaint the Employee and seven other former SpaceX employees filed in superior court. The complaint listed the Employee’s connections to California, including that she “reported up to” a SpaceX vice president located in California, her “direct manager” since September 2021 was located in California, her pay statements were issued from California and listed a California facility as her employer, and her new-hire paperwork contained documents related to California employment law. 6. The order and appeal The court held a hearing on May 23, 2025 and granted the petition.2 The court did not state its reasons for doing so. SpaceX timely appealed.

2 After granting the petition, the court set a hearing to consider the scope of CRD’s requests. The court ordered the

DISCUSSION

SpaceX challenges the superior court’s order compelling it to comply with CRD’s subpoena. SpaceX argues the court should have denied the petition because CRD “cannot plausibly establish jurisdiction to issue the subpoena.” As we understand its arguments, SpaceX contends the federal constitution, the presumption against extraterritorial application of laws, and FEHA precluded CRD from investigating the complaint because it alleges conduct outside FEHA’s territorial reach.

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