Satyadi

After respondent Doctor’s Medical Center (DMC) terminated Carolyn Satyadi’s employment, Satyadi sued DMC, its owner, the West Contra Costa Healthcare District (the District), and various DMC officials. Satyadi claimed she had been fired in retaliation for reporting and refusing to participate in her employer’s allegedly illegal activities. Her complaint alleged causes of action under Labor Code section 1102.5.

Respondents filed a demurrer, arguing Satyadi had not filed a complaint with the Labor Commissioner under section 98.7 before bringing her action, and thus her suit was barred by her failure to exhaust administrative remedies. The trial court agreed with respondents, ruling that Campbell v. Regents of University of California (2005) 35 Cal.4th 311 [ 25 Cal.Rptr.3d 320 , 106 P.3d 976 ] (Campbell) required Satyadi first to seek relief from the Labor Commissioner before filing suit in court. It therefore entered a judgment dismissing Satyadi’s action, and Satyadi appealed to this court.

While her appeal was pending, the Legislature amended the Labor Code to specify that employees such as Satyadi need not exhaust administrative remedies prior to filing suit for…