Baker v. County of San Mateo

Background

Catherine Baker sued the County of San Mateo, Janine Keller, and Dr. Loc Nguyen. She alleged that the defendants treated her improperly and discriminated against her because of disability, sex, and/or race. Her complaint asserted two causes of action: a state-law claim under California’s Fair Employment and Housing Act for harassment, discrimination, and failure to provide reasonable disability accommodations; and a claim under 42 U.S.C. § 1983 alleging employment discrimination based on disability, sex, and/or race.

Baker alleged that she began working for the County as a social worker in 2006 and later developed work-related symptoms of a congenital condition. Doctors allegedly concluded that she could return to work if she did not lift children. Baker claimed that the County did not provide reasonable accommodations, required her to exhaust medical leave and disability benefits, and later told her that she was permanently precluded from returning to work as a social worker. She applied for disability retirement in March 2017, and the retirement system determined in 2019 that she was entitled to disability retirement beginning in January 2016.

Motion and parties’ positions

The defendants filed a partial motion to dismiss Baker’s § 1983 claim under Federal Rule of Civil Procedure 12(b)(6), arguing that the claim was barred by the statute of limitations. Baker argued that her actual injury did not occur until 2019, when her disability-retirement application was approved. She also argued that equitable tolling should apply and that the defendants should be equitably estopped from asserting the time limit.

Court’s analysis

The court held that the applicable limitations period for Baker’s § 1983 employment-discrimination claim was one year. It ruled that the claim accrued when Baker knew or had reason to know of the injury underlying the claim. According to the court, Baker’s claim accrued on March 25, 2017, when the County notified her that she was permanently precluded from returning to work as a social worker. Because she filed her complaint on July 6, 2020, the court held that the § 1983 claim was untimely.

The court declined to apply equitable tolling, a doctrine that can pause a filing deadline in appropriate circumstances. Although the court did not dispute that Baker acted reasonably and in good faith, it found that her disability-retirement application did not give the defendants timely notice of her discrimination claim. The court also found that the defendants would be prejudiced by the delay because evidence could be lost and witnesses’ memories could fade.

The court also declined to apply equitable estoppel, which can prevent a defendant from asserting a filing deadline when the defendant’s conduct prevented the plaintiff from filing suit. The court found that Baker’s complaint did not allege that Keller or any defendant directed her to apply for disability retirement or told her to pursue that application instead of a discrimination claim.

Disposition

The court granted the defendants’ motion to dismiss and dismissed Baker’s second cause of action under § 1983. The order stated that it disposed of Docket No. 11. The opinion did not state a disposition for Baker’s separate claim under California’s Fair Employment and Housing Act. Judge Edward M. Chen signed the order.