Trovato v. Beckman Coulter, Inc., 192 Cal. App. 4th 319 (2011)

Irene Trovato, who was employed as a sales representative for Beckman Coulter, submitted a letter of resignation on May 14, 2007, with an effective date of May 25, 2007. On May 8, 2008, Trovato filed an administrative complaint against Beckman and her former supervisor, Michael Allyn. On May 22, 2008, Trovato sued Beckman and Allyn, alleging sexual harassment and retaliation in violation of the Fair Employment and Housing Act (“FEHA”). Beckman and Allyn filed a motion for summary based on FEHA’s one-year statute of limitations on the ground that the undisputed evidence established that the last act of harassment and retaliation occurred on or about January 31, 2007, when Allyn gave Trovato her 2006 performance review. The trial court granted the motion for summary judgment, and the Court of Appeal affirmed, rejecting Trovato’s assertion that the “continuing violation” doctrine saved her claim.