Carbajal v. Hayes Management Services, Inc.
24-2870
9th Cir.Apr 14, 2025Background
- Maria Angelica Carbajal worked at Hayes Management Services, Inc. (HMS) and alleged sexual harassment and retaliation by owner Chris Hayes before being terminated.
- Carbajal sued HMS under Title VII and the Idaho Human Rights Act, later adding Hayes individually under an alter ego theory after HMS sold assets to another Hayes company during litigation.
- The district court sanctioned HMS and Hayes for discovery abuses, including withholding key evidence and misrepresenting facts about the asset sale.
- Carbajal prevailed at trial, receiving damages, attorneys’ fees, and costs.
- HMS and Hayes appealed numerous adverse pretrial, evidentiary, and post-trial decisions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of Title VII (employee numerosity) | HMS met Title VII threshold; seasonal workers counted as employees | Seasonal workers not employees; no contract | Sufficient evidence for jury; summary judgment properly denied |
| Discovery sanction (training attendance sheet) | Late discovery justified sanction; key to numerosity | Sanction too severe; not willful | Sanction appropriate and within discretion |
| Alter ego liability and constructive trust | Hayes responsible due to misconduct and improper transfer | No wrongdoing in asset sale or document withholding | Imposing liability and trust was not abuse of discretion |
| Denial of motion to compel psychosexual exam | Request untimely, irrelevant, and improper under evidentiary rules | Relevant to damages; should be compelled | Motion properly denied; no error in awarding fees |
| Exclusion of Hayes' prior conviction evidence | N/A (Defendants failed to argue on appeal) | Should be excluded | Issue waived for lack of argument |
| Exclusion of IHRC finding of no probable cause | Agency no cause findings heavily prejudicial and not per se admissible | Finding is admissible and relevant | Exclusion was appropriate |
| Personal jurisdiction/timeliness for Hayes | Claims independent of Title VII limitations | Not timely; 90-day rule applies | 90-day rule not jurisdictional; alter ego claim timely |
| Sufficiency of damages evidence | Compensatory and punitive damages supported by evidence | No supporting evidence for damages | Evidence sufficient; no appellate review for unrenewed motion |
| Attorneys’ fees and costs | Fees proper under contract counterclaim and clear records | Fee request technically deficient and excessive | Award of fees and reduction was not an abuse of discretion |
Key Cases Cited
- Escriba v. Foster Poultry Farms, Inc., 743 F.3d 1236 (9th Cir. 2014) (Denial of summary judgment generally not reviewable after trial where not based on legal error)
- Anheuser-Busch, Inc. v. Nat. Beverage Distribs., 69 F.3d 337 (9th Cir. 1995) (Factors for imposing discovery sanctions)
- Beachy v. Boise Cascade Corp., 191 F.3d 1010 (9th Cir. 1999) (Agency no cause findings not per se admissible)
- Ghahremani v. Gonzales, 498 F.3d 993 (9th Cir. 2007) (Arguments not raised in opening brief are waived)
- Ortiz v. Jordan, 562 U.S. 180 (2011) (Post-trial renewal of Rule 50 motion required for appellate review)