Vatalaro v. County of Sacramento
Annotate this CaseAfter being terminated from a position with Sacramento County (the County), plaintiff-appellant Cynthia Vatalaro sued the County for unlawful retaliation under Labor Code section 1102.5. Vatalaro alleged that, in violation of this statute, the County retaliated against her after she reported that she was working below her service classification. The County moved for summary judgment, contending Vatalaro could not show that she had a reasonable belief, or any belief at all, that the information she disclosed evidenced a violation of any law. The County added that, regardless, Vatalaro’s claim still failed because the County had a legitimate, nonretaliatory reason for terminating her. The trial court, agreeing with the County on both these points, granted summary judgment in the County’s favor. On appeal, Vatalaro alleges that the trial court was wrong on both these issues. The Court of Appeal affirmed, though on a ground somewhat different than those raised at the trial level: "the relevant standard is not whether the County demonstrated it had such a [non-discriminatory] reason; it is instead whether the County 'demonstrate[d] by clear and convincing evidence that the alleged action would have occurred for legitimate, independent reasons even if the employee had not engaged in activities protected by Section 1102.5.'"
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