Switzer

I. Background Events

Plaintiff is a teacher employed by the CDCR. Since 1994, she has worked at the men’s prison in Lancaster, California (the prison or the Lancaster prison). She has taught both high school equivalency (GED) and adult basic education (ABE) classes.

A. The Lancaster Prison The Lancaster prison is divided into four facilities or yards, designated A, B, C, and D. There is a separate facility for minimum security prisoners, many of whom work

1 All subsequent undesignated statutory references are to the Government Code.

2 outside the prison for part of the day. The minimum security facility is outside the prison’s secure perimeter. Each prison yard contains two distinct areas. The main yard, which is subject to the highest security, contains inmate housing, an exercise yard, and a “program building” or “education building,” which houses classrooms and a library. The doors that connect these secure areas to the outside require special keys, referred to as Folger-Adams keys. At all times relevant to this action, teachers were not permitted to carry Folger-Adams keys. Each prison yard also has a second area, sometimes referred to as a vocational area, which…