Wassmann v. South Orange County Cmty. Coll. Dist., 2018 WL 3063946 (Cal. Ct. App. 2018)

Carol Wassmann challenged her dismissal from employment as a tenured librarian at Irvine Valley College in a five-day administrative proceeding brought pursuant to the Education Code. The administrative law judge determined there was cause to terminate Wassmann’s employment, and the trial court upheld the judge’s decision. Wassmann then filed a civil lawsuit against the District and various other parties for race and age discrimination under the Fair Employment and Housing Act (“FEHA”) and intentional infliction of emotional distress (“IIED”). The trial court granted defendants’ motions for summary judgment on the ground that the FEHA claims were barred by res judicata, collateral estoppel and/or failure to exhaust administrative remedies and that the IIED was barred by the applicable two-year statute of limitations. The Court of Appeal affirmed the dismissal, holding that the adverse ruling of the administrative law judge barred the civil proceeding, as did Wassmann’s failure to timely file a complaint with the Department of Fair Employment and Housing; the court also affirmed dismissal of the IIED claim on statute of limitations grounds.