California Court Says Pre-Litigation Email to State Agency's Lawyers Isn't Privileged
A California appellate court found that the state's Department of Fair Employment and Housing must hand over an email its lawyers received from a transgender woman alleging discrimination at a local gym.
March 17, 2020 at 01:00 AM
4 minute read
The original version of this story was published on The Recorder
An appellate court has found that the state's Department of Fair Employment and Housing must hand over an email its lawyers received from a transgender woman who complained when a San Diego-area Crunch Fitness gym denied her access to its women's locker room.
In a ruling clarifying just who lawyers at the California agency charged with enforcing the state's anti-discrimination laws regarding housing and employment represent, the Fourth District Court of Appeal on Friday found that Christynne Wood, a transgender woman who claims she faced discrimination in the men's locker room after the El Cajon Crunch Fitness gym refused her request to use facilities that conformed with her gender identity, couldn't claim privilege over her pre-litigation email to lawyers at the DFEH even though they ultimately filed suit against the gym.
"DFEH lawyers have an attorney-client relationship with the State of California," wrote Justice Patricia Guerrero. "Wood has not shown DFEH lawyers formed an attorney-client relationship with her," she continued.
DFEH sued the gym in April 2018 in San Diego Superior Court and Wood and her lawyers joined the case as an intervenor the following month. The fight over the email, which is already on its second stop at the Fourth District, ensued. Crunch initially convinced the trial court to compel production of the email by arguing that DFEH acts on behalf of the state similar to a criminal prosecutor and cannot compromise its impartiality by representing a specific individual. The Fourth District summarily denied a writ petition in the case, but the California Supreme Court took the case up last year and instructed the lower appellate court to issue an order to show cause why the relief sought in Wood's petition should not be granted.
In Friday's order, the Fourth District noted that Wood and her lawyers, a team from the ACLU Foundation of San Diego & Imperial Counties, Nixon Peabody, and ACLU Foundation of Southern California, had raised some federal court decisions finding attorney-client privilege in communications between complaining parties and the U.S. Equal Employment Opportunity Commission, the federal agency who handles employment discrimination matters. But Guerrero, in a 31-page opinion joined by Justices Richard Huffman and Terry O'Rourke, wrote that the federal common law surrounding privilege was more "flexible" than the boundaries of privilege set out by statute in California. The decision also noted that though DFEH's interest often aligns with those of plaintiffs such as Wood, the agency has consistently disclaimed any representation of individuals like other state enforcement agencies.
"Crime victims have a similar convergence of interests with prosecutors, and prosecutors routinely seek specific relief on behalf of victims in the form of restitution, but no attorney-client relationship exists between them." Guerrero wrote. "Similarly, local child support agencies seek and enforce specific relief—child and spousal support—on behalf of members of the public, but no attorney-client relationship exists there either," the judge continued.
Lawyers for Wood didn't immediately respond to requests for comment Monday.
Liedle, Larson & Vail's Tamara Vail, who represents the Crunch defendants, said in an email Monday that she and her clients "believe the Court of Appeal's ruling will ensure that the government's investigations into allegations of discrimination will remain fair and neutral, and more importantly, transparent for all involved."
"The government cannot pick sides as between parties involved in a complaint since doing so undermines any neutrality," she said. "When we have a sincerely unbiased and open exchange of information, the public as a whole will have faith in the processes employed by the government."
She said her clients believe the ruling will ensure that they and other parties in their situation get access to the information DEFH collects and relies on to file suit seeking significant injunctive relief and civil penalties.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2025 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllLaw Firms Mentioned
Trending Stories
- 1Troutman Pepper, Claiming Ex-Associate's Firing Was Performance Related, Seeks Summary Judgment in Discrimination Suit
- 2Law Firm Fails to Get Punitive Damages From Ex-Client
- 3Over 700 Residents Near 2023 Derailment Sue Norfolk for More Damages
- 4Decision of the Day: Judge Sanctions Attorney for 'Frivolously' Claiming All Nine Personal Injury Categories in Motor Vehicle Case
- 5Second Judge Blocks Trump Federal Funding Freeze
Who Got The Work
J. Brugh Lower of Gibbons has entered an appearance for industrial equipment supplier Devco Corporation in a pending trademark infringement lawsuit. The suit, accusing the defendant of selling knock-off Graco products, was filed Dec. 18 in New Jersey District Court by Rivkin Radler on behalf of Graco Inc. and Graco Minnesota. The case, assigned to U.S. District Judge Zahid N. Quraishi, is 3:24-cv-11294, Graco Inc. et al v. Devco Corporation.
Who Got The Work
Rebecca Maller-Stein and Kent A. Yalowitz of Arnold & Porter Kaye Scholer have entered their appearances for Hanaco Venture Capital and its executives, Lior Prosor and David Frankel, in a pending securities lawsuit. The action, filed on Dec. 24 in New York Southern District Court by Zell, Aron & Co. on behalf of Goldeneye Advisors, accuses the defendants of negligently and fraudulently managing the plaintiff's $1 million investment. The case, assigned to U.S. District Judge Vernon S. Broderick, is 1:24-cv-09918, Goldeneye Advisors, LLC v. Hanaco Venture Capital, Ltd. et al.
Who Got The Work
Attorneys from A&O Shearman has stepped in as defense counsel for Toronto-Dominion Bank and other defendants in a pending securities class action. The suit, filed Dec. 11 in New York Southern District Court by Bleichmar Fonti & Auld, accuses the defendants of concealing the bank's 'pervasive' deficiencies in regards to its compliance with the Bank Secrecy Act and the quality of its anti-money laundering controls. The case, assigned to U.S. District Judge Arun Subramanian, is 1:24-cv-09445, Gonzalez v. The Toronto-Dominion Bank et al.
Who Got The Work
Crown Castle International, a Pennsylvania company providing shared communications infrastructure, has turned to Luke D. Wolf of Gordon Rees Scully Mansukhani to fend off a pending breach-of-contract lawsuit. The court action, filed Nov. 25 in Michigan Eastern District Court by Hooper Hathaway PC on behalf of The Town Residences LLC, accuses Crown Castle of failing to transfer approximately $30,000 in utility payments from T-Mobile in breach of a roof-top lease and assignment agreement. The case, assigned to U.S. District Judge Susan K. Declercq, is 2:24-cv-13131, The Town Residences LLC v. T-Mobile US, Inc. et al.
Who Got The Work
Wilfred P. Coronato and Daniel M. Schwartz of McCarter & English have stepped in as defense counsel to Electrolux Home Products Inc. in a pending product liability lawsuit. The court action, filed Nov. 26 in New York Eastern District Court by Poulos Lopiccolo PC and Nagel Rice LLP on behalf of David Stern, alleges that the defendant's refrigerators’ drawers and shelving repeatedly break and fall apart within months after purchase. The case, assigned to U.S. District Judge Joan M. Azrack, is 2:24-cv-08204, Stern v. Electrolux Home Products, Inc.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250