Jefferson v. California Dep’t of Youth Authority, 28 Cal. 4th 299 (2002)

Mary Jefferson worked as a part-time teacher’s assistant at a high school. After the teacher and his students allegedly subjected Jefferson to sexually offensive conduct, she filed a workers’ compensation claim in which she sought benefits for “psychological factors affecting physical condition.” Jefferson later filed a claim of sex discrimination with the California Department of Fair Employment and Housing. When Jefferson settled her workers’ compensation claim, she executed a compromise and release of all known and unknown claims. Three weeks after the Workers’ Compensation Appeals Board (WCAB) approved the compromise and release, Jefferson filed a civil claim alleging sex discrimination and essentially the same injuries for which she had been compensated in the workers’ compensation case. The employer moved for summary judgment based on the broad language of the workers’ compensation release. The trial court granted the employer’s motion for summary judgment; the California Court of Appeal and Supreme Court affirmed the dismissal. The Supreme Court held that “when an employee has knowledge of a potential claim against the employer at the time of executing a general release in a workers’ compensation proceeding, but has not yet initiated litigation of that claim, the employee has the burden of expressly excepting the claim from the release.”