Erica Zeitlin v. AFSCME District Council 36
Opinion
Trial Court Opinion
I. Introduction
On September 8, 2020, Erica Zeitlin (“Zeitlin” or “Plaintiff”) filed this action in the Los Angeles Superior Court against AFSCME District Council 36 (“Council 36” or the “Council”). Dkt. 6-1 at 8-23 (the “Original Complaint”). The Original Complaint advanced the following causes of action: (1) discrimination in violation of California’s Fair Employment and Housing Act (“FEHA”) (Cal. Gov. Code §§ 12926, 12940, and 12945); (2) harassment in violation of FEHA (Cal. Gov. Code §§ 12926, 12940, and 12945); (3) failure to prevent discrimination, retaliation, or harassment under FEHA (Cal. Gov. Code § 12940(k)); (4) retaliation in violation of FEHA (Cal. Gov. Code §§ 12926 and 12940); and (5) wrongful termination in violation of public policy. Id.
On May 25, 2022, Zeitlin added AFSCME (the “Union,” and collectively with the Council, “Defendants”) as a defendant. Dkt. 6-1 at 40. Also in May 2022, Zeitlin filed a First Amended Complaint. Id. at 42-57. On August 4, 2022, Zeitlin filed a Second Amended Complaint against the Defendants. Id. at 79. On September 1, 2022, the Union removed the action based on federal-question jurisdiction. Dkt. 1.