Balladarez

I. Background

A. Balladarez’s Employment and Termination Vitro Flat Glass LLC manufactures glass at its facility in Fresno County, California. (Docket Entry No. 25 at ¶¶ 1–2). In January 2014, Ray Balladarez began working as a lead maintenance technician in the Fresno facility. (Docket Entry No. 27 at ¶¶ 2–3). Balladarez’s job

duties included “troubleshooting problems with mechanical and electrical systems, coordination with managers, working with general maintenance technicians, and doing preventative maintenance.” (Id. at ¶ 3). On March 15, 2020, Balladarez was injured at work. He had climbed a ladder to reach a soda ash platform seven feet off the ground. (Docket Entry No. 23-4 at 41–42). The ladder was gated at the top of the platform to prevent workers from falling off the platform. (Id. at 43). When Balladarez opened the gate and began to climb down the ladder, the gate detached from its hinges, causing Balladarez to fall backwards off the ladder. (Id. at 43, 46). Balladarez suffered a concussion, fractured scapula, and various muscle tears, requiring surgery. (Docket Entry No.

at ¶ 7). Balladarez took three days off work after his injury. …