Black v. L.A. County Metropolitan Transp. Authority

BACKGROUND

Plaintiff filed a complaint against defendants alleging wrongful termination in violation of public policy and violation of Labor Code section 970. After answering the complaint, defendants filed a motion for judgment on the pleadings asserting that plaintiff had failed to plead compliance with the claims presentation requirements of the GCA. Defendants argued that requirement applies because MTA is a “public entity created pursuant to the County Transportation Commissions Act,” and PTSC is both “a public corporation” and “a public agency.” Alternatively, defendants argued as public entities, they are immune from common law liability for wrongful termination in violation of public policy and also immune from causes of action for misrepresentation under Labor Code section 970. In his opposition, plaintiff conceded MTA is a public entity, but argued PTSC, as a nonprofit public benefit corporation, is distinct from a “public corporation” and therefore not protected by the GCA. The trial court granted the motion. The court agreed plaintiff had not pleaded facts addressing the claims presentation requirement, and indeed “apparently concede[d] he ha[d] not filed a claim”…