Beyda

Marlee M. Beyda appeals from a defense judgment in her sexual harassment case against Los Angeles City Councilperson Nate Holden, members of his staff, and the City of Los Angeles. Her sole claim of error is that the court erroneously excluded evidence of acts of sexual harassment of other employees by Mr. Holden and one of his staff members. We conclude that while evidence of this sort may be relevant to the determination of a hostile work environment, in this case the plaintiff did not present, or offer to present, the necessary foundational facts to permit its admission.

Factual and Procedural Summary

Mr. Holden met Ms. Beyda while she was working as a waitress. The two chatted about the possibility of Mr. Holden helping Ms. Beyda obtain employment with the city, and he gave her his business card. Ms. Beyda called about a possible job opening, was interviewed, and began work as a council aide in Mr. Holden’s district office on Pico Boulevard in April 1991. While Ms. Beyda’s work was at the district office, on occasion she would go to Mr. Holden’s downtown office on business. She also went to Mr. Holden’s apartment in Marina Del Rey several times.

Ms. Beyda resigned…