Rogers v. County of Los Angeles

After 19 weeks of medical leave, longtime employee Katrina L. Rogers returned to her job with the County of Los Angeles (County), only to learn that she was being transferred to another position in another department. She sued the County for violation of California’s Moore-Brown-Roberti Family Rights Act (CFRA) (Gov. Code, § 12945.2). Her *483 claim had two components: (1) that the County interfered with her CFRA rights by transferring her to a noncomparable position, and (2) that the County retaliated against her for exercising her right to take CFRA leave. The jury returned a special verdict in her favor and awarded damages of $356,000.

The County appealed, contending that her interference claim was barred as a matter of law and that there was insufficient evidence to support her retaliation claim. We agree and reverse the judgment.

FACTUAL AND PROCEDURAL BACKGROUND

Rogers’s Employment

Rogers worked more than 36 years for the County in various positions. Most recently, she was the personnel officer (or chief of special services) in the executive office, which was responsible for rendering administrative and other support services to the Los Angeles County Board of…