Diego

Cecilia Diego sued her former employer Pilgrim United Church of Christ (Pilgrim United) for wrongful termination in violation of public policy. Diego alleged she was terminated from her employment as assistant director of Pilgrim United’s preschool as a result of the director’s mistaken belief that she had lodged a complaint with the Community Care Licensing Division of the State Department of Social Services (Licensing), which resulted in an unannounced inspection of the preschool.

The trial court granted summary judgment in favor of Pilgrim United on the basis that, because Diego in fact had not made a complaint to Licensing (or otherwise engaged in activity associated with protected disclosure of alleged wrongdoing), her termination of employment did not violate public policy as a matter of law. We disagree and reverse that part of the judgment directed to Diego’s claim for wrongful termination in violation of public policy and remand with instructions that the court enter an order denying Pilgrim United’s motion.

At the onset, we stress the limited issue that is presented and decided in part II.A., post: Does California public policy preclude Pilgrim United from…