Watts v. Gateway Public Schools

Background

Ashli Watts sued her former employer, Gateway Public Schools. She alleged retaliation and termination connected to her pregnancy leave and complaints about race and pregnancy discrimination, under state and federal law. She also sought punitive damages.

Gateway is described in the opinion as a public charter school and a nonprofit public-benefit corporation. Gateway moved to dismiss Watts’s claim for wrongful termination in violation of public policy, known under California law as a Tameny claim, and her request for punitive damages. Watts agreed that those claims were not legally available if Gateway was a public entity, but argued that Gateway was not one.

Court’s Analysis

The court explained that California law does not allow public entities to be liable for Tameny wrongful-termination claims or punitive damages. The parties did not dispute the relevant facts, so the motion turned on whether Watts’s legal theory was legally available.

The court concluded that Gateway is a public entity under California law. California statutes state that charter schools are part of the public-school system, are under that system’s jurisdiction and the exclusive control of public-school officers, and are entitled to public funding. The court also considered decisions involving nonprofit public-benefit corporations and charter schools. It found those decisions persuasive, while noting that one cited case involving a corporation wholly owned by a city did not control the result here.

The court rejected Watts’s reliance on cases that treated charter schools as having some private characteristics or addressed different legal issues. It concluded that the statutory control over charter schools, along with the factors discussed in the cited decisions, supported treating Gateway as a public entity.

Ruling

Judge Laurel Beeler granted Gateway’s motion to dismiss claim eight, the Tameny wrongful-termination claim, and the request for punitive damages. Because the court found the legal theory was not legally available, it dismissed both with prejudice. The opinion does not state the disposition of Watts’s other claims.