Walton v. Victor Valley Cmty. Coll. Dist., 119 Cal. App. 5^th 1164 (2026)

Jessie Walton sued her employer for sexual harassment‑related claims. The trial court excluded her attorney’s declaration filed in opposition to the employer’s summary judgment motion for a “correctible omission” (failure to state the location where it was signed and that it was subscribed under penalty of perjury under the laws of the state of California as required by Cal. Code Civ. Proc. § 2015.5). Even though Walton’s attorney filed a corrected declaration hours after the hearing, the trial court granted the employer’s summary judgment motion. The Court of Appeal reversed, holding that technical oversights of counsel such as existed here are curable defects. The Court further held that a postsecondary nursing student like Walton doing a clinical rotation at a hospital qualifies as an “unpaid intern” and thus has standing to sue for sexual harassment under the Fair Employment and Housing Act.