Odom v. Los Angeles Cmty. Coll. Dist., 110 Cal. App. 5th 470 (2025)

Sabrena Odom, a tenured Los Angeles Community College (“LACC”) professor, sued LACC and one of its top administrators for sexual harassment and retaliation. After a three-week trial, the jury awarded plaintiff a total of $10 million for past and future mental suffering and emotional distress damages. The Court of Appeal reversed, finding that the trial judge improperly admitted 20-year-old newspaper articles regarding the administrator-defendant’s stalking and prior conviction for sexual assault. The judge also erred in allowing “me too” testimony from a student at LACC regarding her complaint against a different administrator.

The Court held the trial court committed additional error when the judge made “extreme and bizarre” racial and gender-based comments to defendant’s counsel, a Black woman, during the post-judgment phase of trial. Among other things, the judge talked about “miscegenation” and the societal impact of mixed-race football players as well as his support for Black Lives Matter. He also repeated an offensive joke he heard as a young lawyer about female secretaries doing a better job providing sexual favors than typing. The judge eventually recused himself after defendant’s counsel moved to disqualify him.

Finally, the Court of Appeal found the $10 million jury award for mental suffering and emotional distress to be “excessive” in that plaintiff continued to work through the close of trial and proved no economic damages. The Court agreed with defendants that there is no precedent for this high of an award absent economic or debilitating injuries, and the award was grossly disproportionate to awards in comparable cases; the Court remanded for a new trial.