purpose of deflecting claim (California) · Go Syfert
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purpose of deflecting claim in California

7 California opinions name it 2 courts 1993–2017 0 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Nazir v. United Airlines, Inc.green
calctapp · 2009 · cited in 2 California opinions naming this issue, 2013–2015
2 sentences

2015As the California Supreme Court has made clear, for the workers’ compensation exclusivity doctrine to apply, the “risk of injury must be inherent in the workplace.” (Torres v. Parkhouse Tire Service, Inc. (2001) 26 Cal.4th 995, 1008 .) “Neither discrimination nor harassment is a normal incident of employment.” (Nazir v. United Airlines, Inc. (2009) 178 Cal.App.4th 243, 288 .) “The Legislature . . . did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices. . . . [¶] Thus, a claim for emotional and psychological da

2013A cause 14 of action for such a claim is barred by the exclusive remedy provisions of the workers‟ compensation law. [Citations.] The Legislature, however, did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices. [Citations.] [¶] Thus, a claim for emotional and psychological damage, arising out of employment, is not barred where the distress is engendered by an employer‟s illegal discriminatory practices.” (Accardi v. Superior Court (1993) 17 Cal.App.4th 341, 352 , disapproved on other grounds in Richards v. CH2

12
Murray v. Oceanside Unified School Districtgreen
calctapp · 2000 · cited in 2 California opinions naming this issue, 2013–2015
2 sentences

2015As the California Supreme Court has made clear, for the workers’ compensation exclusivity doctrine to apply, the “risk of injury must be inherent in the workplace.” (Torres v. Parkhouse Tire Service, Inc. (2001) 26 Cal.4th 995, 1008 .) “Neither discrimination nor harassment is a normal incident of employment.” (Nazir v. United Airlines, Inc. (2009) 178 Cal.App.4th 243, 288 .) “The Legislature . . . did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices. . . . [¶] Thus, a claim for emotional and psychological da

2013This is so because the claim is „founded upon actions that are outside the normal part of the employment environment . . . .‟ [Citation.]” (Murray v. Oceanside Unified School Dist. (2000) 79 Cal.App.4th 1338, 1363 .) Here, the emotional distress Lu alleges to have suffered, namely depression and anxiety, resulted from regular employment practices, specifically, Stanford‟s transfer of 11 Lu to OCME.

12
Shoemaker v. Myersgreen
cal · 1990 · cited in 1 California opinions naming this issue, 2017–2017
2 sentences

2017In Miklosy , the plaintiffs alleged causes of action for retaliation in violation of the California Whistleblower *688 Protection Act (§ 8547 et seq.), wrongful termination and constructive wrongful termination in violation of public policy, and intentional infliction of emotional distress. ( Id. at p. 884, 80 Cal.Rptr.3d 690 , 188 P.3d 629 .) As to the last claim, "Plaintiffs allege[d] defendants engaged in 'outrageous conduct' that was intended to, and did, cause plaintiffs 'severe emotional distress,' giving rise to common law causes of action for intentional infliction of emotional distres

2017In Miklosy , the plaintiffs alleged causes of action for retaliation in violation of the California Whistleblower *688 Protection Act (§ 8547 et seq.), wrongful termination and constructive wrongful termination in violation of public policy, and intentional infliction of emotional distress. ( Id. at p. 884, 80 Cal.Rptr.3d 690 , 188 P.3d 629 .) As to the last claim, "Plaintiffs allege[d] defendants engaged in 'outrageous conduct' that was intended to, and did, cause plaintiffs 'severe emotional distress,' giving rise to common law causes of action for intentional infliction of emotional distres

11
Hart v. National Mortgage & Land Co.green
calctapp · 1987 · cited in 1 California opinions naming this issue, 2015–2015
1 sentence

2015As the California Supreme Court has made clear, for the workers’ compensation exclusivity doctrine to apply, the “risk of injury must be inherent in the workplace.” (Torres v. Parkhouse Tire Service, Inc. (2001) 26 Cal.4th 995, 1008 .) “Neither discrimination nor harassment is a normal incident of employment.” (Nazir v. United Airlines, Inc. (2009) 178 Cal.App.4th 243, 288 .) “The Legislature . . . did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices. . . . [¶] Thus, a claim for emotional and psychological da

11
Jones v. Los Angeles Community College Districtgreen
calctapp · 1988 · cited in 1 California opinions naming this issue, 2015–2015
1 sentence

2015College Dist. (1988) 198 Cal.App.3d 794, 802, 805 [upholding the plaintiff’s claim for emotional and psychological damages where the distress was allegedly caused by employer’s illegal discriminatory practices].) Here, the allegations surrounding Li’s IIED claim stemmed in large part from the same facts constituting her discrimination and retaliation claims.

11
Flait v. North American Watch Corp.green
calctapp · 1992 · cited in 1 California opinions naming this issue, 1993–1993
2 sentences

1993(Flait v. North American Watch Corp. (1992) 3 Cal.App.4th 467, 480 [ 4 Cal.Rptr.2d 522 ]; Goldman v. Wilsey Foods, Inc. (1989) 216 Cal.App.3d 1085, 1095-1096 [ 265 Cal.Rptr. 294 ].) Thus, a claim for emotional and psychological damage, arising out of employment, is not barred where the distress is engendered by an employer’s illegal discriminatory practices.

1993(Flait v. North American Watch Corp. (1992) 3 Cal.App.4th 467, 480 [ 4 Cal.Rptr.2d 522 ]; Goldman v. Wilsey Foods, Inc. (1989) 216 Cal.App.3d 1085, 1095-1096 [ 265 Cal.Rptr. 294 ].) Thus, a claim for emotional and psychological damage, arising out of employment, is not barred where the distress is engendered by an employer’s illegal discriminatory practices.

11
Goldman v. Wilsey Foods, Inc.green
calctapp · 1989 · cited in 1 California opinions naming this issue, 1993–1993
2 sentences

1993(Flait v. North American Watch Corp. (1992) 3 Cal.App.4th 467, 480 [ 4 Cal.Rptr.2d 522 ]; Goldman v. Wilsey Foods, Inc. (1989) 216 Cal.App.3d 1085, 1095-1096 [ 265 Cal.Rptr. 294 ].) Thus, a claim for emotional and psychological damage, arising out of employment, is not barred where the distress is engendered by an employer’s illegal discriminatory practices.

1993(Flait v. North American Watch Corp. (1992) 3 Cal.App.4th 467, 480 [ 4 Cal.Rptr.2d 522 ]; Goldman v. Wilsey Foods, Inc. (1989) 216 Cal.App.3d 1085, 1095-1096 [ 265 Cal.Rptr. 294 ].) Thus, a claim for emotional and psychological damage, arising out of employment, is not barred where the distress is engendered by an employer’s illegal discriminatory practices.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Accardi v. SUPERIOR COURT OF VENTURA CTY. green
calctapp · 1993
2 sentences

2017A cause of action for such a claim is barred by the exclusive remedy provisions of the workers' compensation law. [Citation.] The Legislature, however, did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices." ( Accardi, supra , 17 Cal.App.4th at p. 352 , 21 Cal.Rptr.2d 292 .) The Accardi plaintiff "allege[d] that she suffered emotional distress because of the pattern of continuing violations which were discriminatory; her cause of action for emotional distress is founded upon actions that are outside the normal

2017A cause of action for such a claim is barred by the exclusive remedy provisions of the workers' compensation law. [Citation.] The Legislature, however, did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices." ( Accardi, supra , 17 Cal.App.4th at p. 352 , 21 Cal.Rptr.2d 292 .) The Accardi plaintiff "allege[d] that she suffered emotional distress because of the pattern of continuing violations which were discriminatory; her cause of action for emotional distress is founded upon actions that are outside the normal

52013–2017
Miklosy v. Regents of the University of California green
cal · 2008
2 sentences

2017A cause of action for such a claim is barred by the exclusive remedy provisions of the workers' compensation law. [Citation.] The Legislature, however, did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices." ( Accardi, supra , 17 Cal.App.4th at p. 352 , 21 Cal.Rptr.2d 292 .) The Accardi plaintiff "allege[d] that she suffered emotional distress because of the pattern of continuing violations which were discriminatory; her cause of action for emotional distress is founded upon actions that are outside the normal

2017A cause of action for such a claim is barred by the exclusive remedy provisions of the workers' compensation law. [Citation.] The Legislature, however, did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices." ( Accardi, supra , 17 Cal.App.4th at p. 352 , 21 Cal.Rptr.2d 292 .) The Accardi plaintiff "allege[d] that she suffered emotional distress because of the pattern of continuing violations which were discriminatory; her cause of action for emotional distress is founded upon actions that are outside the normal

22017–2017
Richards v. CH2M Hill, Inc. green
cal · 2001
2 sentences

2015As the California Supreme Court has made clear, for the workers’ compensation exclusivity doctrine to apply, the “risk of injury must be inherent in the workplace.” (Torres v. Parkhouse Tire Service, Inc. (2001) 26 Cal.4th 995, 1008 .) “Neither discrimination nor harassment is a normal incident of employment.” (Nazir v. United Airlines, Inc. (2009) 178 Cal.App.4th 243, 288 .) “The Legislature . . . did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices. . . . [¶] Thus, a claim for emotional and psychological da

2013A cause 14 of action for such a claim is barred by the exclusive remedy provisions of the workers‟ compensation law. [Citations.] The Legislature, however, did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices. [Citations.] [¶] Thus, a claim for emotional and psychological damage, arising out of employment, is not barred where the distress is engendered by an employer‟s illegal discriminatory practices.” (Accardi v. Superior Court (1993) 17 Cal.App.4th 341, 352 , disapproved on other grounds in Richards v. CH2

22013–2015
Torres v. Parkhouse Tire Service, Inc. green
cal · 2001
1 sentence

2015As the California Supreme Court has made clear, for the workers’ compensation exclusivity doctrine to apply, the “risk of injury must be inherent in the workplace.” (Torres v. Parkhouse Tire Service, Inc. (2001) 26 Cal.4th 995, 1008 .) “Neither discrimination nor harassment is a normal incident of employment.” (Nazir v. United Airlines, Inc. (2009) 178 Cal.App.4th 243, 288 .) “The Legislature . . . did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices. . . . [¶] Thus, a claim for emotional and psychological da

12015–2015
Fisher v. San Pedro Peninsula Hospital green
calctapp · 1989
1 sentence

2000We said, “In Fisher[, supra, 214 Cal.App.3d 590 ], the court held that . . by its very nature, sexual harassment in the work place is outrageous conduct as it exceeds all bounds of decency usually tolerated by a decent society. [H] Accordingly, if properly pled, sexual harassment will constitute the outrageous behavior element of a *1363 cause of action for intentional infliction of emotional distress . . . .’ (Id. at p. 618.) We hold that the same is true of harassment based on sexual orientation.” (Kovatch, supra, at p. 1278 , italics added.) We then found that Kovatch’s evidence was suffici

12000–2000
Kovatch v. California Casualty Management Co. green
calctapp · 1998
1 sentence

2000Thus, “[a] cause of action for such a claim is barred by the exclusive remedy provisions of the workers’ compensation law. [Citations.] The Legislature, however, did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices. [Citations.] [ft] Thus, a claim for emotional and psychological damage, arising out of employment, is not barred where the distress is engendered by an employer’s illegal discriminatory practices.” (Id. at p. 352, italics added; also see Leibert, supra, 32 Cal.App.4th at pp. 1706-1707.) Similarly,

12000–2000
Cole v. Fair Oaks Fire Protection District green
cal · 1987
1 sentence

1993Code, § 3601, subd. (a); Cole v. Fair Oaks Fire Protection Dist., supra, 43 Cal.3d at p. 160 .) The Legislature, however, did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices.

11993–1993

Statutes the citing opinions construe

CA § Cal. Government Code § 12900 (4) CA § Cal. Government Code § 12940 (3) CA § Cal. Government Code § 12960 (3) CA § Cal. Government Code § 12965 (3) CA § Cal. Labor Code § 3600 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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