Joseph

I. FACTS

Joseph was fired from his position as a staff dentist at the California Rehabilitation

Center (CRC), a CDCR prison, in March 2014. His dismissal was preceded by a series of

lesser adverse actions, including (1) a March 2012 denial of a merit salary adjustment

(MSA); (2) a 30-day suspension in November 2012; (3) an April 2013 MSA denial; (4)

an October 2013 MSA denial; and (5) a salary reduction (a 5 percent reduction for nine 4 months) imposed in January 2014. During the relevant time period, Beltz was CRC’s

supervising dentist and Joseph’s direct supervisor, while Elliot was chief executive

officer of the medical, dental and mental health departments at CRC. Beltz is the

supervisor who issued the MSA denials; Elliot was responsible for the formal disciplinary

actions of suspension, salary reduction, and dismissal.

Joseph contends that his dismissal was retaliation for his oral and written 5 objections to CRC practices that he believed to be violations of a federal court order.

That order, arising out of the settlement of a class action lawsuit regarding CDCR inmate

4 An April 2013 settlement with CDCR reduced the November 2012 suspension to 20 days. As part…