Howe v. Mendocino County

CourtDistrict Court, N.D. California
DecidedJuly 8, 2020
Docket3:20-cv-02622
StatusUnknown

This text of Howe v. Mendocino County (Howe v. Mendocino County) 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
Howe v. Mendocino County, (N.D. Cal. 2020).

Opinion

1 2 3 4 5 6 7 8 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 12 BARBARA HOWE, et al., Case No. 20-cv-02622-SI

13 Plaintiffs, ORDER RE DEFENDANTS’ MOTION 14 v. TO DISMISS

15 MENDOCINO COUNTY, et al., Re: Dkt. No. 9 16 Defendants.

17 18 On May 5, 2020, defendants County of Mendocino, Tammy Moss Chandler, and William 19 Schurtz (collectively, “defendants”) filed the instant motion to dismiss all 22 claims in plaintiff’s 20 complaint. Dkt. No. 9 (Mtn. to Dismiss). The motion is GRANTED in part and DENIED in part. 21 22 BACKGROUND 23 Plaintiffs Barbara Howe and Jani Sheppard filed a 130+ page complaint that, despite its 24 volume, says surprisingly little. Ms. Howe and Ms. Sheppard worked together at Mendocino 25 County’s Health and Human Services Agency (“HHSA”). Ms. Howe, a heterosexual female over 26 the age of 40, is the former Assistant HHSA Director and was allegedly terminated on May 30, 27 2019. Dkt. No. 1 ⁋⁋ 22 and 43. Ms. Sheppard, an African-American heterosexual female over the 1 Defendants are: (1) Mendocino County, (2) Tammy Moss Chandler, the current Director of 2 HHSA, and (3) William Schurtz, Mendocino County’s current Director of Human Resources. Id. 3 ⁋⁋ 25, 29, 30. Ms. Chandler and Mr. Schurtz are sued in their individual capacity. Dkt. No. 1 at 1.1 4 5 I. Facts Alleged Concerning Plaintiff Barbara Howe 6 From approximately October 16, 2017 to May 30, 2019, Ms. Howe was employed by 7 Mendocino County as HHSA Assistant Director. Dkt. No. 1 at ⁋ 48. In late April of 2019, Ms. 8 Howe learned about impending PG&E power shutoffs in anticipation of fire season. Id. ⁋ 79. As 9 Assistant Director of HHSA, Ms. Howe was charged with ensuring public health staff were prepared 10 for the power shutoffs. Id. ⁋⁋ 80-81. This included overseeing logistics and communication between 11 Public Health staff and PG&E,, as well as preparing plans to procure generators for hospitals to use 12 during the power shutoffs as necessary. Id. ⁋⁋ 87-91. Ms. Howe’s plan coalesced during a May 15, 13 2019 meeting. Id. ⁋⁋ 82-91. The complaint alleges Ms. Howe “planned to discuss and obtain buy- 14 in from” defendant Tammy Chandler regarding the generators at the next scheduled meeting on May 15 24, 2019. Id. ⁋ 97. However, on May 24, 2019, Ms. Chandler and the then Director of Human 16 Resources, Heidi Dunham, allegedly “worked for their own personal interests to terminate Ms. 17 Howe without any due process.” Id. ⁋ 98. The complaint alleges Ms. Chandler “dictated or drafted 18 a one sentence resignation letter with Heidi Dunham … cornered Ms. Howe in her office during a 19 regularly scheduled meeting and had Dunham introduce the resignation letter to [Ms. 20 Howe]…[who] reluctantly signed the one sentence resignation memo under the duress and menace 21 created illegally by [Ms. Chandler] and Heidi Dunham.” Id. ⁋⁋ 98 – 108. The complaint is silent 22 on what was said or done by Ms. Chandler or Ms. Dunham to create “menace,” “duress,” or 23 “illegality.” The complaint alleges defendants sought Ms. Howe’s termination essentially because 24 she was too good at her job and served the public too well, and because Ms. Howe’s “performance, 25 age, wisdom [and] sexual orientation … were a threat” to defendants. Id. ⁋⁋ 110-111, 26 At some point after Ms. Howe’s termination, the complaint alleges, Ms. Howe texted Ms. 27 1 Chandler “about the reason for [Ms. Howe’s] termination.” Id. ⁋ 168. The complaint does not 2 provide the full text sent by Ms. Chandler. Instead, the complaint alleges Ms. Howe stated in part 3 that Ms. Chandler “was going to be at ‘dis-ease’ for having implemented the wrongful termination 4 against her[.]” Id. ⁋ 169. The complaint alleges the term “dis-ease” meant stress that would be 5 brought on by Ms. Chandler’s alleged illegal and underhanded behavior. Id. ⁋ 170. The complaint 6 alleges Ms. Chandler expressed an irrational fear of the term “dis-ease” and construed it as Ms. 7 Howe making a threat to give Ms. Chandler a disease. Id. ⁋ 175.2 8 The complaint goes on to allege Katharine Elliot, the Mendocino County Counsel, was 9 enlisted by Ms. Chandler and Ms. Dunham in an “attempt to cover-up their illegal conduct and … 10 to further harm and damage Ms. Howe.” Id. ⁋ 113. Ms. Elliot allegedly filed for a restraining order3 11 against Ms. Howe in furtherance of a “plan to destroy” her “personally, professionally, [and] 12 maliciously.” Id. ⁋ 114. Presumably in connection with the restraining order, the complaint alleges 13 pictures of Ms. Howe were posted in county offices “to defame and slander her as if she were a 14 criminal… [and] to intimidate other county staff about the fate they would suffer at the hands of 15 defendants” Id. ⁋⁋ 130-131. It seems no restraining order was ever obtained. Id. ⁋ 138 (“civil 16 harassment case was dismissed because the COUNTY was not a proper petitioner”) (emphasis in 17 original). The complaint alleges that defendants have worked to “disappear” important witnesses, 18 such as Ms. Elliot and Ms. Dunham, to other states to impede Ms. Howe’s claims but give no further 19 explanation or details regarding the allegation. Id. ⁋ 146. 20 On August 27, 2019, Ms. Howe filed her Original Government Claim. Id. ⁋ 183. 21 22 II. Facts Alleged Concerning Plaintiff Jani Sheppard 23 Plaintiff Jani Sheppard began working for HHSA in May 2018 as a Senior Program 24 2 The complaint fails to provide any dates/chronology giving context to these events or 25 helping the reader to understand alleged cause and effect.

26 3 While it seems likely that the grounds for the restraining order could have included Ms. Howe’s text to Ms. Chandler, this is not made clear in the complaint. Indeed, the complaint does 27 not provide specifics regarding the restraining order and the little information that is provided is 1 Specialist. Id. ⁋ 23. She was later promoted to Senior Program Manager, the title she currently 2 holds. Id. The complaint alleges Ms. Sheppard became a target for defendants because during Ms. 3 Howe’s tenure at HHSA, she supported Ms. Sheppard. Id. ⁋ 179. Therefore, defendants allegedly 4 viewed Ms. Sheppard as a “source and advocate for Ms. Howe and a threat” to defendants. Id. The 5 complaint alleges Ms. Chandler “enlisted Meredith Reinhard4 to make allegations of discriminatory 6 conduct by Ms. Sheppard”5 and “failed to correct insubordination by Ms. Sheppard’s direct reports.” 7 Id. ⁋⁋ 184, 191. The complaint alleges: “Ms. Sheppard commented to Carol Mordhorst6 that Ms. 8 Reinhart’s7 insubordination, [Ms. Chandler]’s failure to address the insubordination and the 9 statement8 that Ms. Sheppard was ‘just an angry black woman’ were discriminatory and racist.” Id. 10 ⁋ 192. The complaint further alleges that at some point the County hired an outside law firm to 11 conduct a discrimination investigation into Ms. Sheppard and that on March 4, 2020, Ms. Sheppard 12 “was cleared by [the law firm] of any wrongdoing.” Id. ⁋⁋ 195-197. However, the complaint goes 13 on to allege defendants 14 retaliated against Ms. Sheppard by implementing adverse employment actions, including reassignment consistent with a two-position demotion. Ms. Johnson told 15 Ms. Sheppard that she was there to watch over Ms. Sheppard and that [Ms. Chandler and other defendants] were very upset that the COUNTY had to spend $52,000 to 16 investigate claims of discrimination leveled at Ms. Sheppard and other individuals under her supervision… Ms. Sheppard was denied a position, for which she applied, 17 was qualified and was due a preference under the COUNTY’s ordinance and civil service rules … The open position was provided to Jody Johnson, a person who did 18 not have the basic requirements or other relevant experience to qualify for or perform the job. 19 Id. ⁋⁋ 202-206.9 The complaint goes on to allege that defendants 20

21 4 This is the complaint’s only mention of Ms. Reinhard.

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Bluebook (online)
Howe v. Mendocino County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/howe-v-mendocino-county-cand-2020.