California

Faragher v. City of Boca Raton in California Law

How Faragher v. City of Boca Raton applies in California: state-specific rules, key cases, and bar exam notes for Employment Discrimination.

State Approach

California law follows the principles established in Faragher v. City of Boca Raton regarding employer liability for harassment by employees. California courts adopt a broader interpretation of employer responsibility in maintaining a harassment-free workplace under the Fair Employment and Housing Act (FEHA).

State Rule
Under California law, employers are strictly liable for harassment by supervisors unless they can prove they took reasonable steps to prevent and correct discriminatory behavior.
Significant State Cases

McRae v. Department of Corrections

The court found that an employer could not escape liability for sexual harassment merely because it had established a reporting mechanism if it failed to act on reported complaints.

Janken v. GM Hughes Electronics

The court held that harassment by a coworker did not result in employer liability unless the employer knew or should have known of the harassment and failed to take appropriate action.

Roby v. McKesson Corp.

The court confirmed that an employer can be liable for the harassment of non-employees if it has a reasonable opportunity to investigate and stop the harassment.

Comparison to Federal Law

While the federal standard established in Faragher provides a framework for employer liability, California's approach under FEHA extends employer responsibility by emphasizing proactive prevention and remedies for harassment claims. This means California courts may impose a higher standard for employer liability compared to federal law.

Bar Exam Note

Questions on the California bar exam may involve scenarios applying the principles of employer liability for harassment, particularly focusing on the standards set forth in FEHA and relevant case law.

Practice Pointers
  • Ensure that your organization has clear anti-harassment policies and training programs in place.
  • Document all complaints thoroughly and retain proof of investigations and outcomes to defend against potential harassment claims.
  • Be proactive in creating a workplace culture that emphasizes respect and tolerance to minimize the risk of harassment.

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