Yesterday, I attended my client’s mediation at EEOC (Equal Employment Opportunity Commission) office in San Francisco. In many ways, the proceedings were very similar to a typical private mediation of an employment case. However, I thought there were a few important advantages, at least in this particular case, over private mediation.

1. The EEOC mediation service is free. Mediation can be an expensive proceeding. Some of the mediators in the Bay Area who are know to be effective in resolving employment cases charge between $5,000 and $7,000 per day for their services. While paying half of this fee may be worthwhile for the Plaintiff, some employers use this expense as an additional way to pressure Plaintiff into settlement. They realize that consciously or subconsciously, the employee and his/her counsel who are naturally are not as well funded as the employer will want to make their expense worthwhile and would be more frustrated if the case doesn’t settle at the end of the day, which means the aggrieved employee and his/her lawyer will likely be more flexible and amenable to a lower settlement. When the mediation is free, Plaintiff is under no pressure to accept settlement offer which seems to be clearly not fair.

2. At least some EEOC mediators seem to insist on a joint session before separating the parties into different rooms. Many private mediators believe that traditional join sessions, where both parties, their counsel and the mediator sit together and talk about the case are counter-productive and are more likely to hurt and help the process. While this might be true, especially if either of the parties or both or angry and each other and have a hard time communicating with each other without losing their temper, if respectful discussion is possible and the employee can keep his emotions under control, joint session should definitely be taken advantage of. First, it saves a lot of time, allowing both parties to nail down the main issues in their case and immediately see where the opposite side stands on the same issue. Some of the factual disputes, discrepancies and misunderstandings about the events that lead to the EEOC complaint can be resolved right then and there. Further, if the employer is represented by someone who has never met the aggrieved employee, it shows both parties the actual “human” side of the opposing party. This is especially helpful if the employer’s representative and the employee are calm and likable people, who are able to respect the difference in opinion when looking at the same issue from a different angle, which is very common in most motive-related cases, such as discrimination and retaliation.

The recent Silguero v. Creteguard, Inc., appellate decision from the Second Appellate district (Los Angeles County) is instructive on a less common issue arising out of the attempt by an employer to follow a non-compete agreement that the subject claimant signed with his former employer. In that case, shortly after claimant was terminated by his first employer, with whom he signed the non-compete agreement, she found employment with the defendant company. The first employer contacted the defendant and requested “cooperation” in enforcing the non-compete. As a result, claimant’s employment was terminated by the defendant.

While the new employer had the best intentions of acting honestly and ethically toward the other company (previous employer) and trying to do the right thing, even though they suspected that the non-compete agreement might be unenforceable in California, the court still found that the future employer was liable for wrongful termination. The court’s analysis largely relied on a very significant, and long standing public policy in California that protects the important legal right of persons to engage in businesses and occupations of their choosing and discourages circumvention of freedom to seek employment anywhere in the state.

The Court of Appeal further reminded the defendant-employer that a competitor may solicit another competitor’s employees if they do use unlawful means or engage in acts of unfair competition. Thus, no actionable wrong is committed by a competitor who hires away his competitor’s employees who are not under contract, as long as the inducement to leave the first employer is not accompanied by unlawful conduct.

Yesterday, I met with a client – a very pleasant lady in her mid thirties who was forced to quit from the SFMOMA (San Francisco Museum of Modern Arts) due to what appeared to be egregious violations of California disability laws at workplace. The former SFMOMA employee has been suffering from fairly severe scoliosis in her back and accompanying PTSD for several years. She submitted doctors’ letters to her employer requesting the museum to provide her with reasonable accommodations, but they systematically ignored it for several years, openly accusing the employee of making her symptoms up and also telling her that unless she is crippled or has a terminal illness, she is not considered disabled and will not receive any special treatment. The accommodations requested were minimal – to allow the employee to take a few hours off per month to see her doctor in order to relief her back pain symptoms.

Out of curiosity, I asked my client to stand up and show me the curvature of her back, and I was surprised to find how noticeable the degenerative changes in her back were. I wonder if her employer ever bothered to look at her back…

This unprecedented ignorance of the disability laws at workplace that employs several hundreds of employees and that has been a distinguished establishment with national recognition for many years is unacceptable and should be changed. I am not sure if it’s a wrong termination lawsuit or some involvement from the management that will trigger the change in the human resources management in that museum, but it seems to me that it’s only a matter of time until such systematic disregard for disability laws will lead to significant liability on the part of the San Francisco’s premier museum.

Decisions concerning medical staff membership and privileges are made through a process of hospital peer review. Every licensed hospital is required to have an organized medical staff responsible for the adequacy and quality of the medical care rendered to patients in the hospital. Arnett v. Dal Cielo 14 Cal.4th 4, 10 (1996). The medical staff must adopt written bylaws which provide formal procedures for the evaluation of staff applications and credentials, appointments, re-appointments, assignment of clinical privileges, appeals mechanisms and such other conditions which the medical staff and governing body deem appropriate.

The medical staff acts mainly through peer review committees, which, among other things, investigate complaints about physicians and recommend whether staff privileges should be granted or renewed. California has codified the peer review process in Business and Professions Code section 809 et seq. The primary purpose of the peer review process is to protect the health and welfare of the people of the state by excluding through the peer review those medical practitioners who provide substandard care or who engage in professional misconduct. This process also allows hospitals to remove incompetent physicians from a hospital’s staff to reduce exposure to possible malpractice liability. Kibler v. Northern Inyo County Local Hospital Dist. 39 Cal.4th 192, 199 (2006). Another purpose which is equally important is to protect the employment and the rights of competent medical doctors from being barred from practical of medicine for arbitrary and discriminatory reasons. As one court noted, peer review that is not conducted fairly and results in the unwarranted loss of a qualified physician’s right or privilege to use a hospital’s facilities deprives the physician of a property interest directly connected to the physician’s livelihood. Anton v. San Antonio Community Hosp. 19 Cal.3d 802, 823 (1977).

peer review staff privilegesThe effect of denying staff privileges extends beyond reducing or eliminating a doctor’s access to the facility that denies the privileges. The same hospital is required by section 805(b) to report certain disciplinary actions to the Medical Board. A hospital considering whether to grant or renew a physician’s staff privileges must contact the Medical Board to learn if some other facility has reported a disciplinary action involving the physician as per section 805.5(a). A hospital is also usually required to report disciplinary actions to the National Practitioner Data Bank, established for the purpose of tracing the activities of incompetent physicians. 42 U.S.C. 11133(a). Thus, a hospital’s decision to deny staff privileges may have the effect of ending the physician’s career. Mileikowsky v. West Hills Hosp. and Medical Center (2009).

The most typical defense that city police departments assert when a terminated police officer files a lawsuit for wrongful termination, defamation, and related claims is governmental immunity. The good news for the aggrieved police officers and other public employees that might be in a similar situation is the fact that this immunity is available not nearly as often as the public employers believe.

One leading case on the issue is the California Supreme Court decision in Barner v. Leeds 24 Cal.4th 676 (2000). In that case, an innocent man who was wrongfully convicted of robbery, filed a legal malpractice action against his lawyer – public defender.

police-officers.jpg

Under California Tort Claims Act (Gov. Code section 810 et seq), public employees are liable for their torts unless a statute provides otherwise. One exception is immunity for discretionary acts performed within the scope of the public employee’s authority. The immunity, however, only applies to the basic public policy decisions and not the “operational” actions performed after the basic public policy function is performed. For instance, one court concluded that while deciding whether to provider a job reference is a policy decision that enjoys immunity, the contents of the reference itself is an operational action, which is not immune from liability that might result from its contents (i.e. – defamatory publications, containing slander/libel).

Recently, I had a chance to talk to one of the HR managers at Kaiser. I couldn’t help but ask him why is it that Kaiser tends to fight their terminated employees’ claims for unemployment benefits. Having had at least a dozen of clients who were terminated from Kaiser in the Sacramento area alone during the past six months, and who needed help reversing their denial of benefits, I couldn’t help but be curious. After talking to him, I realized that at least one of the major reasons that Kaiser tries to have their fired nurses and cna’s benefits denied is because they think that if they win in front of the Unemployment Appeals Board, the fired employee will be discouraged from taking any other legal action and will be less likely to sue for wrongful termination.

In reality, however, the exact opposite is often true. Managers don’t seem to realize that by trying to strangle a victim after shooting it, they only increase the chances of the employee getting angrier at them, more desperate for income, and thus having no other resort but at least try and bring a lawsuit against the employer. A terminated employee who feels that he was treated unfairly gets approved for unemployment benefits, might feel better in part because of having at least some income while he is looking for a new job. On the other hand, the same employee who has to fight to get his unemployment benefits will be much more likely to get even more angry at his employer and will be much more eager to sue.

It’s important for both the employers and employees to remember that the outcome of the unemployment appeal hearing has no bearing on an employee’s legal claims and has marginal relevance at best to the employee’s ability to prove his claims in court. In other words, just because the employee is not eligible for unemployment benefits, doesn’t mean that he won’t win his case in court. The opposite is true as well – getting unemployment benefits awarded is no assurance to winning a lawsuit.

Besides other federal and California workplace anti-retaliation laws available to different groups of employees, nurses and other medical professionals working at hospital, clinics, and other healthcare facilities have additional law in California that protects them from retaliation. Under section 1278.5 of California Health and Safety Code, the employers may not prohibit against any employee who complains to an employer or a governmental agency about unsafe patient care or conditions.

Unfortunately, this kind of retaliation is not uncommon. The persons in charge who are afraid that the medical safety complaints are not only directed to them but they are also in part or in whole might be their responsibility will likely make it their first priority to terminate the complaining employee or otherwise shut him up.

nurses-retaliation-california.jpgIn Mendiondo v. Centinela Hospital Medical Center, 521 F.3d 1097 (2008), the employee complained about compromised patient care, including unnecessary catheterizations, refusing to use the safest drug for heart attacks because of cost reasons, and using outdated cardiac equipment, among other things. Her manager informed her outright that she should either stop complaining or she will be fired. The ninth circuit allowed the case to proceed forward after it was found to be improperly dismissed by the district court.

Most labor and employment attorneys know that their client’s deposition testimony is likely the most important part and stage of the case. Few aggrieved employees win a case just because they do well at a deposition, but many lose their case or substantially decrease the value of their case because of how they testify or how they present to the opposing counsel. This is exactly why it is so important that you understand how the deposition works and learn to do well.

depo-testimony.jpgIf your attorney does not plan to spend at least a few hours with you before your deposition because he doesn’t think it’s necessary or because he is too busy, request that your deposition be postponed, so your attorney can thoroughly prepare you for your testimony. Your attorney should explain to you the purpose of deposition, the basic rules, what to expect from the opposing side, and the common mistakes that deponents make that you should avoid.

My experience suggests that the most confident and calm people become very nervous during their deposition, especially if they testify for the first time. One of the best ways to eliminate the nervousness is for a client to see a video of a deposition, so he/she knows exactly what’s going on during those proceedings, and what kinds of questions are being asked.

I was glad to find out yesterday that yet one more of my clients won the appeal of the denial of unemployment benefits in Sacramento County. In that case, I represented a nurse who was an outstanding and dedicated employee for Kaiser for over 13 years before she was diagnosed with major depression that lead to her being late to work on occasions and seeking treatment.

My client was summarily terminated under the blanket absenteeism policy of Kaiser that completely disregards state and federal disability laws and obligations that employers have toward disabled workers. At a hearing, the employer represented by the managing nurse of the department admitted that she was aware of the claimant’s diagnosis for several years prior to her termination. Being a medical professional, the employer’s representative didn’t even dare to suggest that she did not know that some of the common symptoms of depression are anxiety, fatigue, inability to focus and thus – the resulting tardiness.

The administrative law judge ruled in my client’s favor as I expected, concluding that even though she violated the employer’s policy, because the violation was caused by the common symptoms of depression, she should not be disqualified from unemployment benefits under section 1256 of the unemployment insurance code.

For years, I believed that since the whole purpose of establishing and running non-profit companies in California is providing some kind of service for the public good and not for profit. As a result, I assume that working in non-profit organizations must be a fulfilling experience on more levels and that the relationships between employees and the way the employees are treated by their management is also superior to the for-profit sector.

However, a number of claims I worked on reflect a different reality. Workplace Retaliation in non-profit agencies is quite common. One of the more common forms of retaliation is against a mid-level managers. A manager might suspect or even witness how funds provided to the employer by the government agencies or through other fund raising efforts are mishandled or even embezzled. That manager makes an internal complaint to his boss. That superior manager might be involved directly or indirectly in the unlawful and unethical handling of the funds and thus he tries to push the issue under the rug or starts building a paper trail of unsubstantial allegations of performance issues or insubordination to “lawfully” terminate the whistleblower.

Such retaliation claims are not easy prove that the year certainly worth investigation, as with proper documentation and witnesses to both – the unlawful activity and the retaliation, such claims can result in both substantial settlement or trial verdicts and changes in the company that assure fair proper management of funds.

Contact Information