California Court of Appeal

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Satyadi v. West Contra Costa Healthcare Dist., A138948

In this case in which plaintiff’s complaint alleges causes of action under Labor Code section 1102.5 on grounds of retaliation for reporting and refusing to participate in her employer’s illegal activities, defendants filed a demurrer arguing that plaintiff’s suit was barred by her failure to exhaust administrative remedies as a complaint had not been filed with the Labor Commissioner under section 98.7 before bringing the present action. Judgment dismissing plaintiff’s action is reversed and the case is remanded for further proceedings on the complaint, where: 1) recent amendments that the Legislature made to the Labor Code (sections 98.7(g) and 244(a)) confirm that a party may bring a civil action for violation of the Labor Code without first exhausting the remedy provided by section 98.7(a); and 2) the complaint alleges that plaintiff exhausted her employer’s internal administrative remedies.

Appellate Information

  • Decided 12/31/2014
  • Published 12/31/2014


  • Jones


  • California Court of Appeal