Gibson v. Al Jazeera International (USA) LLC

CourtDistrict Court, N.D. California
DecidedNovember 14, 2022
Docket3:22-cv-04153
StatusUnknown

This text of Gibson v. Al Jazeera International (USA) LLC (Gibson v. Al Jazeera International (USA) LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gibson v. Al Jazeera International (USA) LLC, (N.D. Cal. 2022).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 San Francisco Division 11 EMILY GIBSON, Case No. 22-cv-04153-LB

12 Plaintiff, ORDER GRANTING MOTION TO 13 v. DISMISS IN PART

14 AL JAZEERA INTERNATIONAL (USA) Re: ECF No. 9 LLC, 15 Defendant. 16 17 INTRODUCTION 18 The plaintiff in this employment-discrimination action alleges that her former employer, the 19 news outlet Al Jazeera International, discriminated against her because she is a woman.1 The 20 plaintiff contends that the defendant paid her less than male employees, tolerated harassment by 21 male employees, placed her in an “acting” position to avoid providing fair pay and credit, and then 22 retaliated by retracting a promotion after she raised these issues internally.2 The plaintiff 23 ultimately resigned.3 The defendant moved to dismiss some of the claims: the fraud claims, the 24 claim for intentional infliction of emotional distress (IIED), and the claim for constructive 25

26 1 Compl. – ECF No. 1-2. Citations refer to material in the Electronic Case File (ECF); pinpoint citations are to the ECF-generated page numbers at the top of documents. 27 2 Id. at 5–20 (¶¶ 10–20, 25–49, 54–103). 1 wrongful discharge.4 The court dismisses, with leave to amend, the fraud claims, which were 2 asserted under California Civil Code § 1710, because the plaintiff’s allegations do not satisfy the 3 heightened pleading standards under Rule 9(b). The court also dismisses, with leave to amend, the 4 claim for IIED because the allegations describing the distress the plaintiff experienced, which 5 mainly arose from personnel decisions, are insufficient to state an IIED claim. 6 But the plaintiff’s constructive wrongful-discharge claim survives. The plaintiff based that 7 claim on more than the defendant’s failure to promote her. Instead, she alleged that the defendant 8 required her to perform more work than it paid or credited her and then forced her to remain silent 9 about the situation. These allegations are sufficient for a constructive-discharge claim. 10 11 STATEMENT 12 The plaintiff started working as a contract video producer for the defendant in 2015.5 She 13 immediately and repeatedly experienced gender discrimination, including unequal pay, until she 14 resigned in 2020.6 The defendant initially paid her $23 an hour, while it paid a male colleague — 15 who started the same day as her with nearly identical experience — $35 an hour.7 And, when the 16 defendant promoted her in 2016 to a full-time role as a producer, it paid her less than her male 17 counterparts.8 The plaintiff and other female producers were routinely responsible for a 18 disproportionate workload compared to male producers.9 For example, the plaintiff frequently 19 worked as an “acting” senior producer and had senior producer responsibilities without 20 correspondingly higher pay.10 21 22 23 4 Mot. – ECF No. 9-1. 24 5 Compl. – ECF No. 1-2 at 5 (¶ 8). 25 6 Id. at 5–21 (¶¶ 10–106). 26 7 Id. at 5–6 (¶¶ 10–12). 8 Id. at 7 (¶ 20). 27 9 Id. at 14–15 (¶ 70). 1 Aside from pay disparities, the plaintiff cites instances where a male coworker “yelled” at her 2 and other women, expressed hatred against women, viewed pornography at work, and discussed 3 his familiarity with guns.11 When female employees brought formal complaints concerning the 4 coworker, the company dismissed their concerns without serious investigation.12 5 The plaintiff raised these issues internally. In addition to lodging complaints, she participated 6 in the defendant’s Gender Working Group, a committee formed in 2019 to “discuss women’s 7 concerns” at the company.13 While the complaint is silent as to who formed the group and whether 8 the defendant sanctioned it, the plaintiff participated in meetings and responded to multiple 9 surveys.14 The defendant’s management, including the “Head of [Al Jazeera International] 10 English,” Moeed Ahmad, received notes about the meetings and the results of the surveys.15 11 Despite the alleged discrimination, the plaintiff was among the highest-performing producers 12 at the company. She won numerous industry awards, as did projects she worked on.16 For her 13 work in 2019, management rated her as “Distinguished,” the highest performance rating at the 14 company.17 Recognizing these accomplishments, an executive producer told the plaintiff in 15 October 2019 that the executive wanted to promote her to senior producer, which came with 16 increased compensation and managerial responsibility.18 Soon after, she began performing duties 17 as a senior producer on two separate shows.19 She was added to an internal-messaging group 18 reserved for managers, and the company arranged for her to receive management training in 19 Washington, D.C., in January 2020.20 20

21 11 Id. at 8–9 (¶¶ 26–33). 22 12 Id. at 9–10 (¶¶ 34–42). 23 13 Id. at 12–13 (¶¶ 52–53, 56–59). 14 Id. at 12 (¶¶ 52–53). 24 15 Id. at 12–13 (¶¶ 53, 56). 25 16 Id. at 11, 13, 16 (¶¶ 50–51, 61, 80). 26 17 Id. at 14 (¶ 64). 18 Id. at 12–14, 17 (¶¶ 54–55, 62–63, 66–68). 27 19 Id. at 14–15 (¶¶ 66, 72). 1 The plaintiff completed the management training on January 21.21 While at the training, she 2 heard “many complaints” from women about unequal pay, and she shared her own experiences of 3 gender discrimination with other employees.22 She also met with a higher-level manager to discuss 4 the Gender Working Group and share her experiences.23 A week later, on January 28, Mr. Ahmad 5 reached out directly to the plaintiff to request “additional information” about her promotion. The 6 plaintiff “immediately saw this as a red flag” because her supervisors had told her the promotion 7 had already been approved by management.24 On February 26, an executive producer informed the 8 plaintiff that “Mr. Ahmad no longer believed” that she was “qualified for the promotion.” The 9 defendant did not further explain the decision.25 At this point, the plaintiff had worked at Al 10 Jazeera for over four years, longer than any other full-time producer at the company.26 11 The plaintiff alleges that Mr. Ahmad’s retraction of her promotion was retaliation for her 12 advocacy and for the discussions she had with other employees during the management training.27 13 When she raised her concerns with her supervisor, she got the “sense” that she would never be 14 promoted because of her gender and outspokenness.28 The complaint also alleges that, hours 15 before a Gender Working Group meeting on April 7, the plaintiff “was told . . . that Mr. Ahmad 16 did not want” her to speak with other employees about her experiences with gender discrimination 17 at Al Jazeera.29 18 Meanwhile, despite the revocation of her promotion, the plaintiff’s assignments did not 19 change. The defendant still asked her to do the work of a senior producer for two separate shows, 20 21

22 21 Id. at 14 (¶ 69). 23 22 Id. at 15 (¶ 71). 23 Id. at 14–15 (¶ 70). 24 24 Id. at 15–16 (¶ 74). 25 25 Id. at 16 (¶ 79). 26 26 Id. (¶ 80). 27 Id. at 17 (¶ 81). 27 28 Id. at 18 (¶ 87). 1 which she considered an unsustainable “double workload.”30 The defendant’s managers, however, 2 were “careful” not to refer to her as a senior producer and instead referred to her as a “team 3 lead.”31 The plaintiff alleges she felt an “enormous amount of stress, anxiety, loss of sleep, as well 4 as financial concerns” because “she did not receive the promised promotion and increased 5 compensation.”32 On May 6, 2020, an executive producer told the plaintiff that she would 6 generally only receive credit based on her official title (meaning she would not receive senior- 7 producer credit irrespective of her work).33 On May 7 or 8, 2020, she informed HR and the 8 executive producer that she would resign at the end of that month. She resigned the next day.34 9 The plaintiff’s state-court complaint, which the defendant removed to this court, has the 10 following claims: (1) gender discrimination (Cal.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Cynthia Lawler v. Montblanc North America, LLC
704 F.3d 1235 (Ninth Circuit, 2013)
Kearns v. Ford Motor Co.
567 F.3d 1120 (Ninth Circuit, 2009)
Turner v. Anheuser-Busch, Inc.
876 P.2d 1022 (California Supreme Court, 1994)
Semore v. Pool
217 Cal. App. 3d 1087 (California Court of Appeal, 1990)
Janken v. GM Hughes Electronics
46 Cal. App. 4th 55 (California Court of Appeal, 1996)
Hughes v. Pair
209 P.3d 963 (California Supreme Court, 2009)
Dennis Woods v. US Bank
831 F.3d 1159 (Ninth Circuit, 2016)
The Depot, Inc. v. Caring for Montanans, Inc.
915 F.3d 643 (Ninth Circuit, 2019)
John Benavidez v. County of San Diego
993 F.3d 1134 (Ninth Circuit, 2021)
Billings v. Hall
7 Cal. 1 (California Supreme Court, 1857)

Cite This Page — Counsel Stack

Bluebook (online)
Gibson v. Al Jazeera International (USA) LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gibson-v-al-jazeera-international-usa-llc-cand-2022.