Guzman

INTRODUCTION

Gloria Guzman timely filed an administrative complaint with the Department of Fair Housing and Employment (DFEH) after her employer, NBA Automotive, Inc. dba Hooman Chevrolet of Culver City (NBA Automotive),1 terminated her employment. DFEH issued Guzman a right-to-sue letter, and Guzman filed this action against NBA Automotive, alleging wrongful termination and various causes of action under the Fair Employment and Housing Act (Gov. Code, § 12900 et seq.) (FEHA).2 A jury found in favor of Guzman and awarded her monetary damages, and the trial court entered judgment in her favor. NBA Automotive appeals from the judgment, challenging the trial court’s orders denying its motions for judgment notwithstanding the verdict and for a new trial. NBA Automotive argues Guzman failed to exhaust her administrative remedies under FEHA because her administrative complaint, though it named something very close (“Hooman Chevrolet”) to NBA Automotive’s correct fictitious business name (“Hooman Chevrolet of Culver City”), it incorrectly identified “Hooman Enterprises, Inc.,” rather than “NBA Automotive, Inc.,” as the corporation doing business as Hooman Chevrolet of Culver City.…