Satyadi v. West Contra Costa Healthcare Dist.
Annotate this CaseBefore accepting a job with DMC, Satyadi , who holds board certifications in clinical laboratory science, was told the laboratory she would manage had no material deficiencies in staff and equipment performance and accreditation. Within days of starting the position, Satyadi received a list of deficiencies; she was directed to reduce overtime and to “clean up problem personnel.” Her initial performance was praised. Satyadi subsequently informed executives about practices she believed violated state and federal laws. Satyadi refused to engage in those activities. During labor negotiations, an executive made derogatory comments about Satyadi in front of her subordinates. Her complaint was not addressed. An attorney was hired to investigate allegations by other employees, but DMC withheld information. Satyadi was terminated and told that no further administrative appeals process existed. Satyadi sued, claiming retaliation (Labor Code 1102.5.1). The trial court dismissed, holding that Satyadi was required to first to seek relief from the Labor Commissioner. While appeal was pending, the Labor Code was amended to specify that employees need not exhaust administrative remedies before filing suit, unless the specific code provision expressly requires exhaustion. The court of appeal held that the amendments apply and reversed.
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