Rhodes v. Sutter Health
2013 U.S. Dist. LEXIS 14191
E.D. Cal.2013Background
- Rhodes sued SGMF, GMG, and Sutter Health for FEHA retaliation, gender harassment, sex discrimination, failure to prevent discrimination, constructive discharge, defamation, and IIED; SGMF moved for summary judgment on FEHA-related claims (4–9) and to strike a declaration; foundation model (Cal. Health & Safety Code §1206(1)) requires arm's-length relations between nonprofit SGMF and GMG; Rhodes previously identified GMG as her employer, with SGMF as a facilities/administrative partner; the court’s standing requires assessing joint-employer and integrated-enterprise liability theories; the court considers whether SGMF may be liable as Rhodes’ joint employer or through an integrated-enterprise framework; the court grants summary judgment on several FEHA claims and defamation against SGMF and discusses punitive damages/IIED later contingent on deposition of Frazier.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether SGMF is Rhodes’ joint employer under FEHA | Rhodes argues SGMF and GMG are jointly liable under integrated-enterprise theory | SGMF contends no joint-employer relationship; GMG handles employment, not SGMF | SGMF not a joint employer; integrated enterprise test not extended to this foundation-model relationship |
| Whether the integrated enterprise test applies to FEHA and wrongful termination claims | Plaintiff urges extension of integrated-enterprise to FEHA wrongful termination | Defendant argues test does not reliably apply to non-parent-subsidiary entities under §1206(1) | Court declines to extend integrated-enterprise to foundation-model relationships; grants summary judgment on FEHA and wrongful-termination claims |
| Whether Rhodes' defamation claim against SGMF survives | Defamation claim remains against SGMF | Defendant disputes credibility and evidence; seeks dismissal | Defamation claim against SGMF dismissed with prejudice |
| Whether the Frazier declaration should be struck under Rule 26/37 | Frazier was not disclosed but referenced in other depo, supporting claims | Failure to disclose may warrant striking or sanctions | Frazier declaration not struck; denial conditioned on deposing Frazier and potential amended reply; sanctions deferred until deposition opportunity |
| Punitive damages and IIED claims dependency on deposition | Punitive damages/IIED rely on IV claims; unresolved without deposition | Deposition required to assess punitive/IIED viability | Court reserving ruling on IIED and punitive damages pending Frazier deposition or amended reply |
Key Cases Cited
- Laird v. Capital Cities/ABC, Inc., 68 Cal.App.4th 727 (Cal. Ct. App. 1998) (integrated enterprise test limited to parent-subsidiary context in FEHA/wrongful termination)
- Vernon v. State, 116 Cal.App.4th 124, 116 Cal.App.4th 124 (Cal. Ct. App. 2004) (four-factor test for joint employment; control over day-to-day operations important)
- Cal. Physicians’ Serv. v. Aoki Diabetes Research Inst., 163 Cal.App.4th 1506 (Cal. Ct. App. 2008) (corporate practice of medicine prohibition; physician independence protection)