Unreported / Non-Citable
Background
Unity Beddingfield sued United Parcel Service, Inc. and several UPS managers for race, gender, and pregnancy discrimination, asserting wrongful termination in violation of public policy, FEHA claims, intentional infliction of emotional distress, UCL violations, federal Pregnant Workers Fairness Act claims, and Equal Pay Act claims. The court previously allowed her claims to proceed against UPS but dismissed certain claims with leave to amend. Beddingfield filed a First Amended Complaint in May 2024.
Two individual UPS managers — Renee Rea (erroneously sued as “Rene Reyes”) and Omar Parra — returned waivers of service in August 2025 after not previously being successfully served. They moved to dismiss the claims against them under Rules 8 and 12(b)(6).
The Complaint mentioned Rea only briefly in connection with a meeting where Beddingfield discussed pay, transfer, and COVID-19 safety concerns; Rea was not named as a defendant in any specific count, only listed as an agent of UPS in Count Four (IIED). Parra was named as the manager at the Ceres location to which Beddingfield transferred and was alleged to have had no prior knowledge of her arrival.
The Court’s Holding
Judge Edward M. Chen granted both individual defendants’ motions to dismiss.
For Defendant Rea, the complaint failed to allege specific facts tying her to any cognizable cause of action. She was not named as a defendant in any of the seven counts, and the brief reference to her in the meeting did not state any actionable claim. The complaint did not specify her employment relationship with Beddingfield (whether she was a direct supervisor or in a position of authority over employment decisions affecting Beddingfield).
For Defendant Parra, the same problem existed. The few allegations about Parra — that he had no prior knowledge of Beddingfield’s transfer to Ceres — did not state a claim for race, gender, or pregnancy discrimination, IIED, or any of the other counts pleaded in the FAC. Under California’s Reno v. Baird framework, individual supervisors are not personally liable for FEHA discrimination claims; only the employer is. Although individuals can be liable for FEHA harassment, the complaint did not adequately plead harassment by either Rea or Parra. Title VII similarly does not provide for individual supervisor liability.
The court dismissed the claims against Rea and Parra under Rules 8 (notice pleading) and 12(b)(6) (failure to state a claim). The substantive claims against UPS remain, and the case continues against the corporate employer.
Key Takeaways
- California’s FEHA does not provide for individual supervisor liability on discrimination claims under Reno v. Baird. Plaintiffs can only sue the employer for FEHA discrimination.
- Title VII similarly does not provide for individual supervisor liability. Federal-court FEHA and Title VII claims against named managers will routinely be dismissed.
- Individual liability under FEHA is available for harassment claims under § 12940(j), but plaintiffs must plead specific harassment conduct by the individual.
- To survive Rule 12(b)(6), allegations against individual defendants must include specific factual content tying them to actionable conduct, not just brief mentions in passing.
- The IIED count against UPS naming a supervisor as an agent does not, by itself, support a separate claim against the supervisor in their individual capacity.
Why It Matters
Discrimination plaintiffs in California regularly name individual managers and supervisors alongside the corporate employer, hoping to leverage personal liability or to complicate the defense. The Northern District consistently shuts down most of those claims, leaving the case to proceed against the corporate defendant only.
For employment-litigation practitioners, the practical lesson is to focus FEHA discrimination claims on the corporate employer and to plead individual liability only where the conduct fits the FEHA harassment exception with specific factual support. For employers, the case is a useful reminder that motion practice can substantially narrow the defendant pool early in litigation, simplifying defense and discovery.