Falsafi v. AutoNation CA4/3

CourtCalifornia Court of Appeal
DecidedMarch 5, 2026
DocketG064033
StatusUnpublished

This text of Falsafi v. AutoNation CA4/3 (Falsafi v. AutoNation CA4/3) 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
Falsafi v. AutoNation CA4/3, (Cal. Ct. App. 2026).

Opinion

Filed 3/5/26 Falsafi v. AutoNation CA4/3

NOT TO BE PUBLISHED IN OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

FOURTH APPELLATE DISTRICT

DIVISION THREE

BASTAN FALSAFI,

Plaintiff and Appellant, G064033

v. (Super. Ct. No. 30-2021- 01179367) AUTONATION, INC. et al., OPINION Defendants and Respondents.

Appeal from a judgment of the Superior Court of Orange County, Deborah C. Servino, Judge. Affirmed. Workplace Justice Advocates and Tamara S. Freeze for Plaintiff and Appellant. Kolar & Associates, Elizabeth L. Kolar, Tami S. Crosby, Jon C. Abramson and Chad G. Chapman for Defendants and Respondents. After his employment was terminated by defendant House of Imports Inc. (HOI), plaintiff Bastan Falsafi sued HOI and its holding 1 company, AutoNation Inc., for whistleblower retaliation under the Sarbanes- Oxley Act of 2002 (Sarbanes-Oxley; 18 U.S.C. § 1514A) and the Consumer Financial Protection Act (CFPA; 29 C.F.R. § 1985.102 et seq.) The trial court granted AutoNation’s motion for nonsuit at the close of the defense case, finding the evidence was insufficient to establish it was plaintiff’s employer or joint employer. As to HOI, the jury found plaintiff had engaged in whistleblower activity and HOI was aware of that activity, but it found the evidence was insufficient to raise an inference that plaintiff’s whistleblower activity was a contributing factor to his termination—one of the elements of plaintiff’s case in chief. The jury never reached the issue of HOI’s affirmative defense that it would have fired plaintiff based on wholly legitimate reasons regardless of any protected activity. On appeal, plaintiff contends (1) the trial court abused its discretion by prohibiting plaintiff from introducing so-called “comparator” evidence at trial, (2) there was evidence of juror misconduct sufficient to mandate a new trial, and (3) the trial court erred by granting nonsuit in favor of AutoNation. We find no reversible error and affirm the judgment. FACTS AND PROCEDURAL HISTORY Plaintiff worked as a finance manager at HOI’s Mercedes-Benz dealership in Buena Park for approximately a year, beginning in October 2018 and continuing through November 11, 2019, when the company terminated his employment. Plaintiff’s job duties included finalizing car

1 AutoNation, Inc. is referred to in this opinion as AutoNation.

Collectively, AutoNation and HOI are referred to as defendants.

2 sales, ensuring all paperwork was legally compliant, selling further financial products to customers, obtaining lender approval, and ensuring the necessary documents were sent to the necessary institutions so the transactions could be completed. Plaintiff filed his complaint in this action on January 15, 2021, against both HOI and AutoNation. After the case was removed to federal court and then remanded, plaintiff limited his claims to whistleblower retaliation under Sarbanes-Oxley and the CFPA, claiming defendants engaged in consumer and bank fraud by forging customers’ signatures and falsifying customers’ income. Defendants filed a joint answer to the complaint on September 24, 2021. The jury trial began in early December 2023. On December 20, 2023, at the close of the defense case, AutoNation made an oral motion for nonsuit on the ground the evidence presented was insufficient to show AutoNation was plaintiff’s employer or joint employer. AutoNation contended the evidence showed it did not have any employees, it had no control over plaintiff’s hiring and termination, it did not employ plaintiff, plaintiff did not make any complaints to AutoNation, the term “AutoNation” is used solely for branding purposes, and AutoNation is merely a holding company. The trial court granted the motion, and the case went to the jury only on plaintiff’s claims against HOI. On January 3, 2024, the jury returned a verdict in favor of HOI. The jury found plaintiff had engaged in a protected activity under both Sarbanes-Oxley and the CFPA and that the HOI decision maker who authorized plaintiff’s termination knew about the protected activity. Nevertheless, the jury found the circumstances were not “sufficient to raise

3 an inference that [plaintiff’s] protected activity was a contributing factor to his termination.” The court entered judgment in favor of HOI and AutoNation on January 23, 2024. On February 15, 2024, plaintiff filed a motion for new trial and for judgment notwithstanding the verdict. Defendants opposed the motion. The court denied the motion on March 27, 2024. Plaintiff timely appealed. DISCUSSION I. EVIDENTIARY RULINGS Plaintiff contends the trial court made a series of evidentiary rulings at trial that handicapped plaintiff’s ability to prove his whistleblower complaints were a contributing factor in his termination, including prohibiting plaintiff from introducing evidence of similar conduct by other employees who were not terminated—i.e., comparator evidence—and prohibiting plaintiff from introducing evidence of defendants’ fraudulent conduct. We find no prejudicial error in the court’s evidentiary rulings. A. Standard of Review We review the trial court’s ruling on the admissibility of evidence for abuse of discretion. (People v. Mataele (2022) 13 Cal.5th 372, 413.) A ruling on the admissibility of evidence “‘“‘will not be disturbed unless . . . the trial court acted in an arbitrary, capricious, or absurd manner resulting in a miscarriage of justice.’”’” (Id. at p. 414.) We may not reverse a judgment or decision “by reason of the erroneous exclusion of evidence” unless there has

4 2 been a miscarriage of justice. (Evid. Code, § 354 [“A verdict or finding shall not be set aside, nor shall the judgment or decision based thereon be reversed, by reason of the erroneous exclusion of evidence unless the court which passes upon the effect of the error or errors is of the opinion that the error or errors complained of resulted in a miscarriage of justice . . . .”].)

B. Plaintiff Failed to Show Prejudice as a Result of the Court’s Exclusion of Comparator Evidence Plaintiff contends the trial court prejudicially restricted his ability to show that other finance managers at HOI engaged in the same conduct that HOI cited as the reason for terminating plaintiff’s employment, but were not disciplined or terminated, thereby raising an inference plaintiff’s whistleblower activity was a contributing factor leading to his termination. Specifically, to rebut defendant’s extensive evidence that plaintiff was terminated because he had repeatedly violated company policies and customers repeatedly had complained about him—and not because of any whistleblower activity—plaintiff attempted to introduce evidence that customers had complained about other finance managers and that other finance managers had engaged in the same or similar alleged violations of company policy without being disciplined.3 We begin our analysis by describing the elements of plaintiff’s two whistleblower claims and the parties’ respective burdens of proof, which are materially the same as to both claims.

2 All further undesignated statutory references are to the Evidence Code.

3 Plaintiff’s direct supervisor had a team of five or six finance managers under her supervision.

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Falsafi v. AutoNation CA4/3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/falsafi-v-autonation-ca43-calctapp-2026.