Watson
Watson v. Chubb & Sons, Inc.
Opinion
Lead Opinion
MEMORANDUM **
Juanita Watson appeals the district court’s grant of summary judgment in favor of her employer, Chubb & Sons, Inc., on her claims of disability discrimination in violation of the California Fair Employment and Housing Act (“FEHA”), California Government Code § 12940 et seq. We have jurisdiction pursuant to 28 U.S.C. § 1291 and we affirm.
Watson failed to timely exhaust her administrative remedies under FEHA. To bring a civil action under FEHA, Watson should have filed a written charge with the Department of Fair Employment and Housing (“DFEH”) within one year of the alleged unlawful employment discrimination. Cal. Gov’t Code § 12960. Watson did not file her disability discrimination claim until fourteen months after she was terminated, although she timely filed her race discrimination complaint. Filling out a pre-complaint questionnaire, alone, was insufficient to exhaust her administrative remedies with respect to her disability claims. Cole v. Antelope Valley Union High Sch. Dist., 47 Cal.App.4th 1505 , 55 Cal.Rptr.2d 443, 448-49 (1996) (holding that FEHA does not authorize any alter *829 native to the requirement of the filing of a verified complaint in…