Hodge v. Poway Unif. School Dist.
Plaintiff brought an action against the Defendant, alleging the District's refusal to rehire her for a custodian position constituted gender discrimination and unlawful retaliation in violation of the Fair Employment and Housing Act (FEHA). The jury found plaintiff did not prove these claims, and the superior court entered judgment in the District's favor.
On appeal, appellant contends the court erred in denying her motion for judgment notwithstanding the verdict because the District failed to satisfy its burden, under McDonnell Douglas Corp. v. Green, to identify the reason it did not hire her with respect to eight open custodial positions. This contention is without merit. The McDonnell Douglas analysis is inapplicable to a motion brought after a jury reached its verdict. In any event, even assuming the analysis applies, appellant's contention that the District did not meet its McDonnell Douglas burden is unsupported by the factual record. Appellant also challenges the court's earlier order granting summary adjudication of her breach of an implied contract claim. The court concludes that the juvenile court properly granted summary adjudication on this cause of action. Court thus affirms the judgment.
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