Camacho v. Target Corp., 234 Cal. Rptr. 3d 223 (Cal. Ct. App. 2018)

Adrian Camacho, a former Target cashier, sued for alleged sexual orientation discrimination, harassment causing a hostile work environment, retaliation, constructive termination in violation of public policy and related claims. Prior to resigning his employment with Target, Camacho settled a workers’ compensation (“WC”) claim he had filed against Target based upon his assertion that he suffered workplace injuries as a result of the alleged harassment. In settling the WC claim, Camacho executed a compromise and release, which included an “Addendum A” that contained what Target contended was a general release of all claims, including civil claims that might be asserted outside the WC system. The trial court granted Target’s summary judgment motion in the civil action based upon the language contained in Addendum A, but the Court of Appeal reversed, holding that “there is no language in Addendum A that demonstrates that the parties intended to settle any claims other than Camacho’s workers’ compensation claims.”