Navarro v. 4 Earth Farms, Inc. (Cal. Ct. App. Feb. 8, 2019) No. B28485, 2019 WL 493781

Dominga Navarro brought a sexual harassment claim and other causes of action against her former employer under California’s Fair Housing and Employment Act (“FEHA”). The jury found in Navarro’s favor and awarded her compensatory and punitive damages. The defendant appealed, contending (1) the trial court erred by admitting evidence of past emotional distress damages because Navarro stipulated to waive her claims for all emotional distress damages; (2) the trial court abused its discretion by excluding evidence of Navarro’s sexual conduct with non-harassing employees; (3) there is no substantial evidence to support the finding that her supervisor engaged in sexual harassment; and (4) there is no substantial evidence to support the imposition of punitive damages. The Court of Appeal affirmed the judgment in its entirety.