Talamantes v. Costco Wholesale Corporation

CourtDistrict Court, N.D. California
DecidedJune 27, 2025
Docket3:24-cv-00789
StatusUnknown

This text of Talamantes v. Costco Wholesale Corporation (Talamantes v. Costco Wholesale Corporation) 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
Talamantes v. Costco Wholesale Corporation, (N.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 AARON TALAMANTES, 10 Case No. 24-cv-00789-RS Plaintiff, 11 v. ORDER GRANTING IN PART, 12 DENYING IN PART MOTION FOR COSTCO WHOLESALE CORPORATION, SUMMARY JUDGMENT 13 Defendant. 14

15 I. INTRODUCTION 16 This case centers on an employment dispute in which Plaintiff Aaron Talamantes claims 17 Defendant Costco Wholesale Corp. unlawfully mistreated him due to certain disabilities and 18 related requests for accommodations. Defendant moves for summary judgment, arguing Plaintiff 19 fails to prove any disabilities or accommodation requests caused the averred misconduct. For the 20 reasons explained below, the motion is denied in all respects except as to Plaintiff’s bid for 21 punitive damages, for which the motion is granted. 22 II. BACKGROUND 23 A. Plaintiff Starts Working for Defendant 24 Costco hired Plaintiff to work as a probationary front-end assistant at one of its warehouses 25 in Sonoma County, California, on July 6, 2023. According to Plaintiff’s deposition testimony, he 26 pulled his manager Paul Trombley aside during an orientation held that same day to discuss his 27 prior diagnoses with Post Traumatic Stress Disorder (“PTSD”) and anxiety, as well as an ankle 1 had broken my ankle, so I do have some weight limits that I can lift, but there are plenty of things 2 that I can do, considering that’s why I applied for a front-end position, not a stocking position 3 because it’s less weight I need to lift.” Alvarez Decl., Dkt. No. 30-1, Ex. A (“Ex. A”) at 10; see 4 also id. at 13 (Plaintiff stating he told Trombley about having a plate with nine screws in his ankle 5 and then showed him a picture of the X-ray). As to his mental health, Plaintiff testified that he 6 told Trombley he would need the accommodation of being able to take short breaks during panic 7 attacks caused by his PTSD. Trombley responded to the news by saying “thank you for your 8 service.” Id. at 9–10. Plaintiff then explained that he was not in the military; his PTSD stemmed 9 from early childhood trauma. Id. at 10–11. Plaintiff claims Trombley told him “[n]ot to tell 10 anybody in upper management” and “to talk to him directly” if he had any problems. Id. at 11. 11 Plaintiff offered to provide medical documentation of his disabilities, but Trombley allegedly told 12 him that it was unnecessary. Id. at 12. 13 Defendant disputes that this entire conversation occurred. Trombley denies that Plaintiff 14 told him about the ankle or the PTSD on the day he was hired. See Alvarez Decl., Dkt. No. 30-1, 15 Ex. B (“Ex. B”) at 87–88 (Trombley stating that Plaintiff “never told me that he had PTSD in my 16 time working with him” and swearing “I would not have said” to not tell anyone else); see also id. 17 at 98 (Trombley describing when he learned about the ankle injury). According to Trombley, 18 Plaintiff only revealed the ankle injury after re-injuring it in late August and that Plaintiff only 19 revealed the PTSD in late September, after the decision to terminate him had already been 20 reached. Id. at 99, 88. 21 Whatever happened on July 6, both sides agree that date marks the start of Plaintiff’s time 22 at Costco, during which he worked at both the “front end,” helping to box up purchased items and 23 gather carts in the parking lots, and in the tire shop, checking pressures and handling rotations. 24 Plaintiff asserts that his supervisor in the tire shop was named Will, and that his supervisors in the 25 front end included another person also named Will as well as a person named Noella. Trombley 26 agrees that the tire shop supervisor was Will Taylor, but he testified that no front end supervisor 27 named Will worked at Costco during Plaintiff’s employment. 1 2 B. Defendant Reviews Plaintiff’s Performance 3 On July 28, 2023, Plaintiff received his 30-day performance review and signed off on 4 having discussed it with Trombley. See Ex. A at 78–79 (“30-Day Review”). The review featured 5 positive feedback, including that Plaintiff “has good member service,” “doesn’t engage in idle 6 chatter,” “always remembers to comes [sic] to work dressed professionally and ready to help our 7 members,” “has good communication,” “has a good sense of teamwork,” “takes responsibility for 8 his actions,” “is respectful of Company property and is honest and has demonstrated good 9 judgment” and “responds well to flexibility.” Id. Negative feedback included the note that “he 10 may not fully understand what is expected of him. You must be constantly moving . . . Always 11 stay busy . . . Never just be standing at the register waiting for a member to come up,” and “We 12 would like to see him now start to show more of a will to learn, by beginning to seek out other 13 opportunities that may be available to him, such as cross training in another department.” Id. The 14 review also noted Plaintiff had one absence and two tardies. Id. Plaintiff apparently discussed 15 this review with coworkers and determined that many of their evaluations were nearly identical. 16 However, according to Katelin Lowell, a payroll clerk, the reviews are very tailored to the 17 individual employee. She described Plaintiff’s 30-day review as not objectively negative—“these 18 comments are to let the employee know what they could work better on.” Setyan Decl., Dkt. No. 19 31-1, Ex. 2 (“Lowell Tr.”) at 48. 20 A few weeks later, Will Taylor in the tire shop filled out a notice to document three 21 instances in which Plaintiff was tardy: 27 minutes late on July 18 (which predated the 30-day 22 review described supra), 6 minutes late on August 15, and 4 minutes late coming back from lunch 23 on that same day. Plaintiff and Taylor both signed the form to confirm that it was discussed. 24 Plaintiff received a 60-day performance review on August 26. Ex. A at 80–82 (“60-Day 25 Review”). Probationary employees only “rarely” receive such a review, Lowell testified, usually 26 in cases where their performance hasn’t improved. Like Plaintiff’s prior review, the 60-day 27 review detailed both positive and negative aspects of his work: he smiles and thanks the members, 1 but he needed “to focus on keeping conversations strictly business related.” Id. The review 2 advised Plaintiff to “always communicate with your team in a positive manner with your co- 3 workers and management team” and to “[w]ork on asking Will, and the tire shop supervisors on 4 what needs to be done daily.” Id. Plaintiff had by then expressed interest in cross training and 5 begun working in the tire shop, but the review stated he needed to improve his “sense of urgency.” 6 Id. The review also highlighted the counseling notice and stressed the importance of being on 7 time; it identified one absence and four tardies, though it is unclear if that is cumulative (i.e., 8 inclusive of the one absence and two tardies noted in the 30-day review). As with the 30-day 9 review, Plaintiff and Trombley signed the document to confirm their discussion. 10 According to Plaintiff, he worked full-time shifts of eight hours, five days a week despite 11 being only a temporary employee. Plaintiff also asserts that one of his tardies occurred after he 12 helped an elderly customer in the parking lot on his way into work. 13 C. Plaintiff Re-Injures Ankle On the Job And Receives Medical Leave 14 Two days after the 60-day review, on August 28, Plaintiff reinjured his ankle when an 15 assistant supervisor he identifies as Will required him to help lift a sectional couch. Setyan Decl., 16 Dkt. No. 31-1, Ex. 1 (“Talamantes Tr.”) at 70. Plaintiff claims he “kept explaining[,] [y]ou know, 17 I can’t do it . . . I have the plate and nine screws [in my ankle] . . . [but] the supervisor told me that 18 it was part of my job description and that I had to do it.” Id. Fearing he might lose his job, 19 Plaintiff acquiesced to the task and immediately “felt a compression, a shift in my foot.

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