Miller-Brumfield
Miller-Brumfield v. Cal. Dept. of State Hospitals CA4/1
Opinion
Opinion
INTRODUCTION
Katherine Miller-Brumfield (Brumfield) appeals from a summary judgment
granted in favor of her former employer, the California Department of State Hospitals
(the Department), on her first amended complaint (complaint) alleging discrimination and
retaliation related claims. She contends the trial court erred in finding the doctrine of res
judicata barred her claims. We conclude claim preclusion bars some of her claims. As to
her remaining claims, we conclude either she cannot establish a prima facie case of
discrimination or she cannot establish the Department's actions were a pretext for
discrimination or retaliation. We, therefore, affirm the judgment.
BACKGROUND
Brumfield worked for the Department as a psychiatric technician at Patton State
Hospital (Hospital). In July 2009 Brumfield filed a complaint with the Department of
Fair Employment and Housing (DFEH) alleging race discrimination, denial of medical
leave, and retaliation (first DFEH complaint).
A few months later, in October 2009, the Department provided Brumfield with a
notice of adverse action (first notice) advising her she would be discharged in 14 days.