Denise Steffens v. Regus Group, Plc

MEMORANDUM

Denise Steffens (“Steffens”) appeals the district court’s grant of summary judgment to her former employer, Regus Group, PLC (“Regus”), on her claim for wrongful termination in violation of California public policy. We reverse and remand for trial.

We review a grant of summary judgment de novo. Mark H. v. Hamamoto, 620 F.3d 1090, 1096 (9th Cir.2010). In California, an employer may be subject to tort liability for wrongful termination if the termination violates a fundamental public policy. Gould v. Md. Sound Indus., Inc., 31 Cal.App.4th 1137, 1147 , 37 Cal.Rptr.2d 718 (1995). Claims for wrongful termination “typically arise when an employer retaliates against an employee for refusing to violate a statute, performing a statutory obligation, exercising a statutory right, or reporting an alleged violation of a statute of public importance.” Id. An employee is not required to report the violation to a government or law enforcement agency; internal reporting is sufficient. Id. at 1150 , 37 Cal.Rptr.2d 718 .

To establish a prima facie case of retaliation, the plaintiff must demonstrate that she engaged in a protected activity, her employer subjected her to an adverse…