Coyle

BACKGROUND

Coyle worked for SMUD for 31 years until she retired on March 4, 2016. In 2009, she was diagnosed with cancer and received accommodations and medical leave from SMUD as a result of the cancer and treatment. On March 7, 2017, one year and three days after her retirement, Coyle filed a DFEH administrative complaint alleging SMUD discriminated against her under FEHA during her career at SMUD. Also on March 7, 2017, DFEH issued a right to sue letter. On March 13, 2017, Coyle filed this action against SMUD. She alleged four FEHA causes of action: violation of the California Family Rights Act, disability discrimination, failure to engage in the interactive process, and failure to accommodate. Coyle alleged she was constructively discharged on March 7, 2016, which was actually three days after she retired. We need not detail the discrimination allegations of the DFEH administrative complaint or the complaint filed in this case because the case hinges entirely on whether Coyle filed a timely administrative complaint with DFEH. SMUD answered the complaint and filed a motion for summary judgment, asserting, among other things, that Coyle failed to timely exhaust her…