Brown

Brown v. City of Inglewood

Good Law
Supreme Court of CaliforniaJuly 7, 2025S280773California9,392 words

Opinion

Opinion

Jenkins, J.

Opinion of the Court by Jenkins, J.

California’s Legislature has built a “powerful network” of “whistle-blower protection laws . . . available to those who seek to expose wrongdoing.” (Garcetti v. Ceballos (2006) 547 U.S. 410, 425.) Labor Code section 1102.5,1 a part of that network, “provides whistleblower protections to employees.” (Lawson v. PPG Architectural Finishes, Inc. (2022) 12 Cal.5th 703, 709; § 1102.5, subd. (b) [“An employer . . . shall not retaliate against an employee”].) For purposes of section 1102.5, the Legislature has defined the term “employee” so it “includes, but is not limited to, any individual employed by the state or any subdivision thereof, any county, city, city and county, including any charter city or county, and any school district, community college district, municipal or public corporation, political subdivision, or the University of California.” (§ 1106.) In this case, we consider whether an elected treasurer of the City of Inglewood is an employee under section 1106 who may invoke section 1102.5’s protections and sue for retaliation. We conclude such an elected official may not invoke the statute’s protections. Because the Court of Appeal…

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