Palmer v. Regents of the Univ. of Cal., 107 Cal. App. 4th 899 (2003)

Patricia Palmer, who worked as a clinical laboratory technologist at the UCLA Medical Center, sued the UC Regents for wrongful termination in violation of public policy following the restructuring of the department in which she had worked and the termination of her employment after 21 years. Palmer alleged that she was retaliated against for reporting unlawful activity involving “laboratory abuses,” among other things. The trial court granted summary judgment to the Regents on the ground that Palmer had failed to exhaust available internal grievance procedures. The Court of Appeal affirmed, holding that Palmer was required to comply with the UCLA Procedures for Reporting Whistle Blowing Complaints before filing her lawsuit.