Aviles-Rodriguez v. Los Angeles Cmty. Coll. Dist., 2017 WL 3712199 (Cal. Ct. App. 2017)

Guillermo Aviles-Rodriguez was employed as a professor for the Los Angeles Community College District (“LACCD”). Although Aviles-Rodriguez was notified on March 5, 2014 that his tenure had been denied by the Board of Trustees of the LACCD, his employment did not end until June 30, 2014, which was the last day of the academic year. Aviles-Rodriguez filed his complaint with the DFEH on June 29, 2015, alleging racial discrimination. The LACCD demurred to the complaint that was later filed in court on the ground that Aviles-Rodriguez had failed to file his DFEH complaint within one year “from the date upon which the alleged unlawful practice… occurred.”  The trial court agreed and dismissed the lawsuit, but the Court of Appeal reversed, holding that the one-year statute of limitations for filing a complaint with the DFEH began to run on the last day of his employment and not on the earlier date on which he learned of the denial of tenure.