Williams v. Sacramento River Cats Baseball Club, LLC
Annotate this CasePlaintiff Wilfert Williams sued defendant Sacramento River Cats Baseball Club, LLC in a common law tort action for failing to hire him due to his race. His complaint also alleged discrimination under the Unruh and Ralph Civil Rights Acts and that defendant engaged in unfair business practices under Business and Professions Code section 17200. From April 2014 through July 2015, plaintiff catered meals to the visiting and home team players at Raley Field, home of defendant’s minor league baseball team. He was hired by the visitor clubhouse manager, Wayne Brown, and the home clubhouse manager to do so. He also helped Brown with meal preparation during that time. While assisting Brown, the job of assistant visitor clubhouse manager became available and plaintiff applied for the job. Brown recommended plaintiff to both defendant’s human resources director and to the baseball operations and public relations coordinator, Daniel Emmons. Plaintiff was never interviewed for the position even though he was already performing some of the tasks of assistant clubhouse manager and had experience running his own catering business. Instead, defendant hired a Caucasian teenager who was still in high school and did not meet any of the qualifications for the job. The trial court dismissed plaintiff’s complaint after sustaining defendant’s demurrer. Plaintiff stipulated the dismissal be entered without leave to amend. Defendant contended as a threshold matter, that plaintiff lacked standing in this appeal given his stipulation in the trial court was tantamount to a nonappealable consent judgment and in any event, his causes of action failed on the merits. In the unpublished portion of its opinion, the Court of Appeal rejected defendant’s contention that plaintiff lacked standing to appeal but agreed the trial court properly dismissed plaintiff’s causes of action for discrimination under the Unruh and Ralph Civil Rights Acts and for unfair business practices. In the published portion of its opinion, the Court addressed plaintiff’s common law failure to hire claim. Central to that claim is the applicability of Tameny v. Atlantic Richfield Co., 27 Cal.3d 167 (1980). While the Court agreed that failing to hire a prospective employee based on race violated public policy, specifically the Government Code as well as our state Constitution, that prospective employee’s remedies were grounded in the Fair Employment and Housing Act (the Act). Tameny on the other hand required “the prior existence of an employment relationship” between the parties upon which to predicate a tort duty of care. Because defendant did not owe plaintiff any duty, plaintiff could not bring a failure to hire claim against defendant in a common law tort action and must instead proceed under the Act.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.