Jury Awards $1.5M Against Keyes Community Services District for CFRA Violations
Table of Contents
Case Background
Joann Sakurada filed a wrongful termination lawsuit against Keyes Community Services District, alleging disability discrimination, failure to accommodate, and violation of her rights under the California Family Rights Act (CFRA). The lawsuit was filed in the California Superior Court, Stanislaus County. Honorable John Mayne presided over the trial. [Case number: CV-23-000228]
Cause
Joann Sakurada lived in California at all relevant times. She worked for Keyes Community Services District, a special district operating in California with its main office in Keyes, Stanislaus County.
On September 3, 2019, she started working as an Office Assistant I. Michelle Harris, the Administrative Executive, supervised her and reported to General Manager Ernie Garza. On February 4, 2022, Sakurada gave Harris a medical certification stating she needed surgery on March 9, 2022, and would be off work until June 9, 2022, returning without restrictions on July 10, 2022. Three days later, Harris told Sakurada she would lose her medical coverage during leave but could continue it through COBRA. She was also told she would face a 90-day waiting period before reinstatement.
On February 9, 2022, Sakurada contacted the health insurance provider to understand her benefits. Two days later, Harris reprimanded her for violating the “chain of command,” claiming she should have only asked Harris about benefits. This discipline appeared to be a pretext for her termination, motivated by bias against employees with disabilities.
Sakurada faced conflicting and inaccurate information from Harris regarding her benefits. When she asked about CFRA leave, Harris incorrectly said she was ineligible. On March 8, 2022, the day before surgery, Harris met with Sakurada and a third party, disclosing her private medical details without her consent.
On June 8, 2022, Sakurada’s doctor cleared her to return to work with minor accommodations. Without discussion, Harris denied the request, extended her leave, and terminated her employment on June 27, 2022, citing undue hardship. The company made no effort to explore accommodations.
Sakurada also worked past her scheduled shifts without pay and missed legally required breaks. After termination, the company failed to provide her final wages on time. She pursued administrative remedies and obtained a Right to Sue letter before filing this lawsuit.
Damages
As a result of these actions, the Plaintiff suffered emotional distress, reputational harm, and various economic and non-economic damages. She sought compensation for these damages, including attorney's fees, costs, and prejudgment interest. The Plaintiff did not claim psychiatric illness but emphasized the substantial impact the Defendants' conduct had on her personal and professional life.
Key Arguments and Proceedings
Legal Representation
Plaintiff(s): Joann Sakurada
Counsel for Plaintiff(s): Jeffrey Scott Ranen | Amir H. Seyedfarshi
Defendant(s): Keyes Community Services District
Counsel for Defendant(s): Dennis L. Hay
Claims
The Plaintiff filed a complaint alleging violations of California employment laws by the Defendants, claiming disability discrimination and failure to provide reasonable accommodations. She argued that Defendants violated California Government Code sections 12940(a), (m), and (n) by refusing to engage in an interactive process regarding her disability and by terminating her without offering accommodations. The Plaintiff also cited wrongful termination under section 12940, as she needed accommodations due to her disabilities, but was instead dismissed.
Additionally, the Plaintiff alleged that the Defendants interfered with her CFRA rights by denying her leave and terminating her during approved medical leave. Defendants allegedly failed to engage in the interactive process and did not explore alternative accommodations.
The Plaintiff also accused Defendants of retaliation after she requested medical leave and accommodations. She contended that her termination resulted from her exercise of rights under the Fair Employment and Housing Act (FEHA) and CFRA. She further argued that the Defendants falsely disciplined her and used the reprimand as a pretext for firing her.
Defense
Defendant Keyes Community Services District denied all allegations and asserted multiple defenses. The Defendant argued that the complaint lacked a factual basis, the Plaintiff failed to exhaust administrative remedies, and unclean hands, assumption of risk, and failure to mitigate damages barred her recovery. Further, it was argued that Plaintiff contributed to her own termination through her actions and alleged prejudice from the delayed filing. It was maintained that actions were taken in good faith, Plaintiff’s expenses were unnecessary, and she waived claims by continuing employment. Defendant also argued that accommodating Plaintiff’s condition posed undue hardship and that termination was justified due to her inability to perform essential job duties.
Jury Verdict
On December 12, 2024, a Stanislaus County jury determined that Keyes Community Services District was Sakurada’s employer. They found that she had a knee condition, that the Defendant was aware of this condition, and that it limited her ability to perform essential job functions. Despite this, they concluded that Sakurada could still perform her essential job duties with or without accommodation. The jury further found that her knee condition was a substantial motivating reason for her termination. They also determined that her job performance did not pose an immediate and substantial risk to herself or others.
Regarding reasonable accommodation, the jury found that the Defendant failed to accommodate Sakurada and that this failure substantially contributed to her harm. However, they rejected the Defendant’s claim that accommodating her would have created an undue hardship. Similarly, they found that reasonable accommodations could have allowed Sakurada to perform her essential duties without endangering her safety or that of others.
The jury also found that the Defendant failed to engage in a timely, good-faith interactive process to determine whether accommodations could be made, and this failure was a substantial factor in causing harm to Sakurada.
Regarding wrongful termination, the jury determined that Sakurada’s knee condition was a substantial motivating factor in the Defendant’s decision to fire her, and this discharge caused her harm.
Under CFRA, the jury found that Sakurada was eligible for medical leave and had provided reasonable notice to the Defendant. They determined that the Defendant interfered with her CFRA rights by threatening to terminate both her health insurance benefits and her employment. This interference was found to be a substantial factor in causing her harm.
For the retaliation claim, the jury determined that Sakurada’s knee condition and her request for medical leave were substantial motivating reasons for her termination. They concluded that the Defendant’s conduct was a substantial factor in causing her harm.
Damages
Past and future lost earnings – $14,942
Past non-economic damages (mental pain and suffering, emotional distress, etc.) – $750,000
Future non-economic damages – $750,000
Total award – $1,514,942
Court Documents:
Documents are available for purchase upon request at jurimatic@exlitem.com