Easton
Easton v. Crossland Mortgage Corp.
Opinion
Lead Opinion
*981 OPINION
We consider in this appeal whether the district court should have remanded a complaint which referenced federal theories, but did not seek federal remedies. Because we find that the case should have been remanded to state court, we reverse.
I.
Patty Easton, Peggy Maarup, and Maria Scott believed they had been sexually harassed by their female supervisors at Cross-land Mortgage Corporation (“Crossland”). They filed a complaint in state court alleging sexual harassment, hostile work environment, sex discrimination, wrongful termination, assault and battery, invasion of privacy, and retaliation. The counts of the complaint alleging sexual harassment claimed that the described conduct was in violation of Title VII of the Civil Rights Act of 1964, Cal. Gov’t Code § 12940, the plaintiffs’ right of privacy under the “California and federal” constitutions, and the “common law right to be free of sexual harassment, a sexually abusive workplace, a hostile and discriminatory workplace.” For damages proximately caused by these acts, Plaintiffs sought relief under California Civil Procedure Code § 425 et seq.