Lee v. Rockstar Staffing CA2/4
B333855
Cal. Ct. App.Nov 15, 2024Background
- Danielle Lee, suffering from sickle cell anemia, was hired by Rockstar Staffing (a staffing agency) and assigned to work as a hostess at Malibu Beach Inn (Malibu).
- Lee was hospitalized due to a flare-up; while in the hospital, Rockstar informed her that Malibu no longer needed her.
- Lee sued Rockstar for wrongful termination in violation of public policy and disability discrimination (based on the Fair Employment and Housing Act, FEHA).
- The jury found in Lee’s favor on wrongful termination but not on disability discrimination; she was awarded $175,000.
- Rockstar appealed, challenging the sufficiency of the evidence and alleged legal errors in the jury instructions and motions’ rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Disability Discrimination (FEHA) | Lee claimed she was fired for her disability when reasonable accommodation was not provided. | Rockstar claimed jury instructions were incorrect and that there was insufficient evidence. | Judgment for Rockstar (on this claim); court found any alleged error was not prejudicial as Rockstar prevailed. |
| Wrongful Termination in Violation of Public Policy | Lee alleged her discharge was substantially motivated by her illness/disability. | Rockstar argued insufficient evidence that they were her employer or that illness motivated discharge. | Affirmed for Lee; Rockstar forfeited arguments by failing to provide an adequate record or relevant legal authority. |
| Employer-Employee Relationship | Lee said evidence showed Rockstar was her employer and thus liable. | Rockstar argued Lee was not its employee, citing payroll and hiring authority. | Sufficient evidence supported jury’s finding that Rockstar was Lee’s employer. |
| Denial of Post-Trial Motions | Lee argued denial was proper given sufficiency of evidence and procedural history. | Rockstar asserted motions for nonsuit, directed verdict, JNOV, and new trial were improperly denied. | Appeals court could not review; Rockstar failed to provide adequate record or properly notice appeal on all orders. |
Key Cases Cited
- Fladeboe v. American Isuzu Motors Inc., 150 Cal.App.4th 42 (presumption of correctness and appellant's record burden on appeal)
- Sanders v. Walsh, 219 Cal.App.4th 855 (failure to provide adequate appellate record prevents meaningful appellate review)
- Yau v. Allen, 229 Cal.App.4th 144 (elements of wrongful discharge in violation of public policy)
- Mathieu v. Norrell Corp., 115 Cal.App.4th 1174 (staffing agencies can be joint employers for FEHA purposes)
- Benach v. County of Los Angeles, 149 Cal.App.4th 836 (forfeiture for failure to provide arguments and authorities in appellate briefing)
- Kim v. TWA Construction, Inc., 78 Cal.App.5th 808 (requirement to acknowledge evidence supporting verdict when challenging on substantial evidence grounds)