Jaimes

INTRODUCTION

Before initiating a civil action alleging violations of the Fair Employment and Housing Act (FEHA), an employee must exhaust his or her administrative remedies by filing a complaint with the Department of Fair Employment and Housing (DFEH). (Gov. Code § 12960, subd. (c).)1 That complaint must “set forth the particulars” of the alleged FEHA violation. (Id.) We decide here whether an employee exhausted his administrative remedies by filing a DFEH complaint that alleged (a) that disability discrimination, a FEHA violation, took place on a specific date, but (b) failed to allege any factual basis whatsoever for the claimed violation. The trial court held the answer was “no.” It granted the employer’s motion for summary judgment. We affirm. To satisfy the exhaustion requirement, a DFEH administrative complaint must at least minimally describe the “particulars” of an alleged FEHA violation. Where, as here, an administrative complaint fails to plead any of the facts underlying a claim for disability discrimination—such as whether the disability was physical or mental, or which individuals were responsible for the alleged discrimination—a plaintiff has not exhausted his or…