Mathews v. Happy Valley Conference Center, Inc.
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Mathews worked for Happy Valley Conference Center in the Santa Cruz Mountains. Valley is an affiliate of the Community of Christ. When a younger male employee confided in Mathews that Valley’s female executive director had been sending him sexually inappropriate text messages, Mathews reported the allegation to the board of directors and the Church’s general counsel. The director admitted sending the messages, was reprimanded, and was allowed to continue supervising Mathews and the younger male employee. Mathews, terminated less than a month later, alleged retaliatory termination. Defendants were ordered to pay almost $900,000 in damages (including punitive damages) and $1 million in attorney’s fees.
The court of appeal affirmed, rejecting arguments that the Church cannot be held liable for Valley’s actions because the two do not fall within the single employer doctrine and that the single employer doctrine jury instruction was prejudicially erroneous; that Valley is not liable under Title VII, 42 U.S.C. 2000, because it does not have enough full-time employees; that defendants are not liable under the version of the whistleblower statute in effect at the time of the events; that the evidence was insufficient to establish that the Church breached Mathews's implied or actual contract; that the Title VII damages were beyond the maximum allowed; that noneconomic and punitive damages were not recoverable for breach of contract; that punitive damages were excessive; and that attorney’s fees were not recoverable. The judgment must be modified to reflect that defendants are exempt from liability under the California Fair Employment and Housing Act, Gov. Code, 12900.
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