Hill v. Workday, Inc.

Background

Anthony C. Hill sued Workday, Inc., Susan Dahm, Lisa McFall, and Katie Hauck in connection with his employment at Workday. The complaint asserted twelve causes of action, including claims under California’s Fair Employment and Housing Act, the California Family Rights Act, California Labor Code section 1102.5, California fraud and tort law, the Confidentiality of Medical Information Act, and the California Constitution’s privacy provision.

According to the allegations described in the opinion, Hill is a Maryland resident and worked remotely for Workday as in-house counsel. Workday was described as a Delaware corporation organized to do business in California, with an office in Pleasanton, California. Hauck, Hill’s direct supervisor, was alleged to reside and work remotely from New York. Dahm and McFall were alleged to be California residents.

Hill alleged that he was denied promotions and workplace resources, demoted, subjected to race-related and disability-related treatment, denied an accommodation, and subjected to conduct involving his medical leave. He also alleged that Workday arranged a police “Wellness Check” at his Maryland home while he was hospitalized in Maryland. The court treated these facts as allegations from the complaint, not established facts.

Procedural History and Standard

Hill filed the action in California state court on December 11, 2023. Workday, Dahm, and Hauck and McFall separately moved to dismiss. The court heard oral argument on May 3, 2024. At the hearing, Hill’s counsel acknowledged that some factual assertions in the opposition briefs were not included in the original complaint and indicated that amendment was necessary.

The court applied the Rule 12(b)(6) standard, which asks whether a complaint alleges enough facts to state a legally plausible claim for relief. The court also separately considered Hauck’s motion under the rules governing personal jurisdiction, meaning the court’s authority over a particular defendant.

Reasons for Dismissal

California-law claims and conduct outside California

The court explained that California law is generally presumed not to apply to events occurring outside California unless the statute or its purpose shows otherwise. For the FEHA and CFRA claims—the first through seventh causes of action—the court considered the location of Hill’s employment and the location of the material events supporting the claims.

The court found the complaint deficient on both points. It concluded that Hill was a remote employee living and working from Maryland and that he had spent only one week in California for work. It also found that the complaint did not identify a substantial connection between California and the material events underlying the claims. The court stated that the complaint relied mainly on a short California business trip and did not allege a significant group of relevant events occurring or being approved in California.

The court therefore granted the motions to dismiss the first through seventh causes of action, to the extent they were based on the FEHA and CFRA, without prejudice, and granted leave to amend.

For the eighth cause of action under California Labor Code section 1102.5, the court likewise found that Hill had not alleged enough facts to overcome the presumption against applying California law outside the state. The court granted Workday’s motion to dismiss that claim without prejudice and granted leave to amend.

For the ninth cause of action for promissory fraud, the court found that the complaint did not allege that the conduct giving rise to liability occurred in California. It rejected the allegation that the employment contract was formed under California law as sufficient, and found that the California business trip was not connected to the conduct supporting the promissory-fraud claim. The court granted the motions to dismiss the ninth cause of action without prejudice and denied Hill’s request for additional briefing as moot.

For the tenth cause of action for intentional infliction of emotional distress, the court required a recognizable connection between the alleged harm and California. It found that the main allegations concerned a virtual meeting attended by Hill from Maryland, the Maryland police visit, and conduct during a California meeting. The court concluded that the complaint did not sufficiently establish the required connection to California and granted the motions to dismiss that claim without prejudice.

For the eleventh cause of action under California’s Confidentiality of Medical Information Act, the court found that the alleged medical-information events concerned the Maryland police visit, communications about Hill’s medical condition, and comments by unidentified Workday employees. The court concluded that the complaint did not adequately connect those events to California and granted the motions to dismiss the CMIA claim without prejudice.

For the twelfth cause of action under the California Constitution’s privacy provision, the court found both that the complaint did not sufficiently connect the alleged conduct to California and that Hill had not requested the type of relief available for that claim. The court stated that the claim supported injunctive relief but not damages, while Hill’s requested injunctive relief addressed other alleged employment discrimination and retaliation rather than the privacy claim. The court granted the motions to dismiss the twelfth cause of action. The opinion states that Hill’s amended complaint no longer asserted that cause of action.

Personal jurisdiction over Hauck

Hauck separately argued that the court lacked personal jurisdiction over her. The court applied the specific-personal-jurisdiction test, which asks whether the defendant purposefully acted toward the forum, whether the claims arise from those forum-related actions, and whether exercising jurisdiction would be fair and reasonable.

The court found that the complaint did not adequately allege that Hauck’s actions occurred in California or were directed toward California. It emphasized that Hill worked from Maryland, Hauck lived and worked remotely from New York, and the complaint did not show that Hauck purposefully conducted activities in California or invoked the benefits of California law. The court also found that exercising jurisdiction over Hauck would not be reasonable based on the allegations. It therefore granted Hauck’s motion to dismiss all claims asserted against her as an individually named defendant. The opinion states that Hill’s amended complaint no longer named Hauck as an individual defendant.

Disposition

The court’s conclusion states that Defendants’ motions to dismiss—Docket Nos. 12, 23, and 35—were granted without prejudice. Hill was granted leave to amend by May 24, 2024. The opinion states that he had already filed an amended complaint. The written order does not identify the magistrate judge by name.