Williams v. Redwood Toxicology Laboratory

Background

Redwood Toxicology Laboratory hired Everline Williams as a Clinical Lab Scientist in January 2018. Williams resigned in October 2018. She alleged that a coworker sexually harassed her during training, that Redwood did not follow up after she reported the harassment and assigned her non-Clinical Lab Scientist tasks, and that Redwood did not properly accommodate her after she suffered a herniated-disc injury at work. Her complaint asserted several claims, including wrongful termination under the California Fair Employment and Housing Act, breach of contract, unfair business practices under California’s Unfair Competition Law, and invasion of privacy.

Redwood moved under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. The court accepted the complaint’s factual allegations as true for purposes of the motion but required enough facts to make each claim plausible.

Judicial notice

The court took judicial notice of Williams’s California Department of Fair Employment and Housing right-to-sue letter and her Equal Employment Opportunity Commission right-to-sue letter. It also took judicial notice that Williams appeared before the State Workers’ Compensation Board, but not disputed assertions in the related document about whether Redwood paid the full value of her injury or whether Williams incurred attorneys’ fees.

Wrongful termination

Redwood argued that Williams’s California Fair Employment and Housing Act wrongful-termination claim was barred by a two-year filing deadline because her employment ended in October 2018 and she filed suit in June 2021. Williams did not dispute the timing but argued that the deadline was extended while she pursued administrative remedies.

The court held that Williams plausibly alleged equitable tolling, meaning an extension of the filing deadline when circumstances outside the filer’s control prevent use of the full filing period. The court relied on allegations that Williams filed with both state and federal employment agencies on July 16, 2019, that the federal agency investigated her allegations, and that she received a right-to-sue letter on March 12, 2021. The court also found that the relevant factors concerning notice, prejudice, and reasonable conduct were adequately alleged. It therefore denied Redwood’s motion as to the wrongful-termination claim.

Breach of contract

The court granted Redwood’s motion to dismiss the breach-of-contract claim. California employment is presumed to be at will, and Williams had not plausibly alleged an express or implied agreement that she could be terminated only for good cause. The court concluded that her allegations about an employment contract, her supervisor’s refusal to accept a resignation letter, and the supervisor’s statement that Williams was doing an “amazing job” did not overcome that presumption.

The court gave Williams leave to amend this claim because it was theoretically possible that additional facts could cure the pleading problem.

Unfair business practices

The court granted Redwood’s motion as to Williams’s claim under California’s Unfair Competition Law. The court found the allegations supporting the claim too vague and conclusory to satisfy federal pleading requirements. It also expressed doubts about whether Williams had alleged the required loss of money or property, complied with administrative-exhaustion requirements associated with the California Labor Code Private Attorneys General Act, or sought a form of restitution permitted under the Unfair Competition Law.

The court nevertheless gave Williams leave to amend because it could not definitively conclude that the claim could not be cured with additional facts.

Invasion of privacy

The court dismissed Williams’s “Fourth Amendment invasion of privacy” claim without leave to amend. It explained that the Fourth Amendment restricts government conduct, not private actors, and noted that the two individuals identified in that claim were not named as defendants in the case.

Disposition

The court granted in part and denied in part Redwood’s motion to dismiss. It dismissed the privacy claim without leave to amend and dismissed the breach-of-contract and unfair-business-practices claims with leave to amend. Any amended complaint had to be filed within 14 days and could not add new causes of action or defendants. The court also set a telephonic case-management conference for March 1, 2022.