Williams v. Redwood Toxicology Laboratory

Background

Everline Williams sued Redwood Toxicology Laboratory in a First Amended Complaint. The opinion identifies seven claims:

Williams began working for Redwood as a Clinical Laboratory Scientist on January 8, 2018. She alleged that a coworker made one sexual remark, that coworkers bullied her, and that two coworkers called her “old” several times. She reported back pain, shoulder pain, and a sprained ankle. Her physician restricted her activities, and Redwood accommodated those restrictions. Redwood denied her request for an additional 30 days of leave because her physician had not taken her off work. The opinion also states that Williams requested a printer at her desk, although Redwood had no record of that request.

Williams resigned in May 2018 but later withdrew that resignation after discussing her concerns with her supervisor. During her employment, Redwood issued her verbal and written warnings concerning alleged inappropriate conduct and performance problems. Williams resigned again on September 27, 2018. Redwood accepted that resignation and refused her request two days later to withdraw it again.

Summary-judgment procedure

Redwood moved for summary judgment. Williams initially missed the deadline to oppose the motion. The court then ordered her to explain why the motion should not be granted because she had not responded. Williams filed an initial response and later filed an opposition after the court advised her that she needed to submit a substantive response.

The court noted that Williams’s opposition contained factual assertions without specific record citations and exceeded the local page limit. The court also stated that materials referenced as exhibits were not attached or supported by a declaration. Under the summary-judgment rules, a party opposing the motion must identify specific evidence showing a genuine dispute over a material fact. The court considered the facts that Williams did not properly support to be undisputed for purposes of the motion.

Court’s analysis and rulings

The court held that Williams had not shown a triable issue of fact—a factual dispute that would require a trial—on any claim.

Claim 1: Disability discrimination and harassment. For the discrimination claim, the court found that Williams had not identified evidence showing that she was disabled, performed her job competently, suffered an adverse employment action, or faced circumstances suggesting discriminatory intent. The court also found that Redwood had presented substantial evidence that it refused to let Williams withdraw her resignation for legitimate, nondiscriminatory reasons tied to her recent performance problems and the way she submitted her resignations. Williams did not identify evidence that those reasons were a pretext for discrimination.

For the harassment portion of Claim 1, the court found that Williams had not identified evidence showing unwelcome harassment based on a protected characteristic that was sufficiently severe or pervasive to change the conditions of employment and create an abusive work environment. The court held that Redwood was entitled to judgment as a matter of law on Claim 1.

Claim 2: Failure to accommodate. The court found that Williams had not identified evidence creating a factual dispute about whether she was disabled, qualified to perform the essential functions of her position, or denied a reasonable accommodation. The court held that Redwood was entitled to judgment as a matter of law on Claim 2.

Claim 3: Failure to engage in the interactive process. The court found that Williams had not identified evidence showing that Redwood failed to engage in a timely, good-faith process to explore accommodation options. The court held that Redwood was entitled to judgment as a matter of law on Claim 3.

Claim 4: Retaliation. For the Fair Employment and Housing Act retaliation theory, the court found no evidence sufficient to create a factual dispute about whether Williams engaged in protected activity, suffered an adverse employment action, or had a causal link between protected activity and an adverse action. The court also found that Williams had not shown that Redwood’s stated reasons for refusing to withdraw her resignation were a pretext for retaliation.

For the California whistleblower theory under Labor Code § 1102.5(b), the court found no evidence sufficient to create a factual dispute about whether Williams engaged in whistleblowing, experienced an adverse employment action, or whether protected whistleblowing contributed to an adverse action. The court further found that Redwood had shown by clear and convincing evidence that it refused to rescind the resignation for legitimate, independent reasons. The court held that Redwood was entitled to judgment as a matter of law on Claim 4.

Claim 5: Wrongful termination. The court agreed that Williams’s wrongful-termination claim was derivative of her disability-discrimination claim and failed for the same reasons. The court also found that Williams had not identified evidence sufficient to create a factual dispute on this claim. The court held that Redwood was entitled to judgment as a matter of law on Claim 5.

Claim 6: Breach of contract. The court found that Williams had not identified evidence sufficient to create a factual dispute about whether a contract existed, whether she performed or had an excuse for nonperformance, whether Redwood breached the contract, or whether she suffered damages. The court held that Redwood was entitled to judgment as a matter of law on Claim 6.

Claim 7: Unfair business practices. The court found that Williams had not identified evidence sufficient to create a factual dispute about whether Redwood committed an act falling within California’s definition of unfair competition. The court held that Redwood was entitled to judgment as a matter of law on Claim 7.

Disposition

Judge Haywood S. Gilliam, Jr. granted Redwood’s motion for summary judgment. The court directed the clerk to enter judgment in favor of Redwood, vacate further proceedings, and close the file. The court also terminated the pending motions listed in the order.