Detabali

Plaintiff-Appellant Lorraine Detabali (Detabali) appeals the district court’s (1) ruling that her California Fair Employment and Housing Act (FEHA), Cal. Gov’t Code § 12940 et seq., claims for employment discrimination and retaliation against Defendant-Appellee St. Luke’s Hospital (St.Luke’s) were preempted by § 301 of the Labor Management Relations Act (LMRA), 29 U.S.C. § 185 (a), and (2) imposition of sanctions against her attorney, Charles J. Katz (Katz), for flouting the court’s instructions regarding a possible second amended complaint.

We reverse the district court’s dismissal of Detabali’s FEHA claims and the imposition of sanctions against Detabali’s counsel, and remand to the district court with instructions to remand Detabali’s action to the San Francisco Superior Court.

BACKGROUND

Lorraine Detabali, a 57-year-old Filipi-na woman, was employed as an intensive care unit nurse at St. Luke’s. She also served as a union representative and had been instrumental in negotiating provisions of the collective bargaining agreement concerning certain measures to ensure quality of care, patient safety, and minimize liability exposure for nurses. St. Luke’s terminated Detabali for…