{"id":319,"date":"2026-01-05T12:00:00","date_gmt":"2026-01-05T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=319"},"modified":"2026-01-05T12:00:00","modified_gmt":"2026-01-05T12:00:00","slug":"snow-conagra-brands-ed-cal-grants-summary-judgment-feha-administrative-complaint-lacked-detail","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=319","title":{"rendered":"Snow v. ConAgra Brands \u2014 E.D. Cal. Grants Summary Judgment Where FEHA Administrative Complaint Lacked Factual Detail"},"content":{"rendered":"
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Case<\/dt>\n
Snow v. ConAgra Brands, Inc.<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Eastern District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-05<\/dd>\n
Docket No.<\/dt>\n
1:22-cv-00699-DC-CKD<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
FEHA discrimination, administrative exhaustion, summary judgment, negligent hiring, UCL, wage and hour<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

The plaintiff, Michelle Snow, has worked at ConAgra’s Oakdale Plant since 1985, holding several positions including raw material receiver. She is a member of Teamsters Local 948 and her terms of employment are governed by a collective bargaining agreement. She has long suffered from PTSD, anxiety, and obsessive-compulsive disorder, and for several years requested a six-day workweek as an accommodation during the plant’s busy ‘Fresh Pack’ season \u2014 a period when most workers are scheduled seven days a week.<\/p>\n

Beginning in 2020, the plaintiff filed a series of grievances with the Union and complaints with ConAgra. She received a number of corrective-action notices that were grieved and, in several instances, downgraded or removed. She testified at a 2021 arbitration involving the discipline of three coworkers for alleged sexual harassment, and she filed an unfair labor practice charge with the National Labor Relations Board, which she ultimately withdrew. In 2021 she filed an administrative complaint with the California Civil Rights Department (CRD) and received a right-to-sue letter, then filed this federal lawsuit in April 2022.<\/p>\n

The complaint asserted thirteen causes of action including six under California’s Fair Employment and Housing Act (FEHA) \u2014 disability harassment and discrimination, failure to engage in the interactive process, failure to accommodate, failure to prevent harassment and discrimination, and retaliation \u2014 plus wage-and-hour claims, negligent hiring and supervision claims, and a derivative Unfair Competition Law (UCL) claim. ConAgra moved for summary judgment on every claim.<\/p>\n

The Court’s Holding<\/h2>\n

The court granted summary judgment for ConAgra in its entirety. The decisive ruling concerned administrative exhaustion: under California regulations, a CRD right-to-sue complaint must include a description of the alleged acts of discrimination, the dates of the conduct, and the protected activity for any retaliation claim. The plaintiff’s 2021 CRD complaint relied entirely on check-box selections and conclusory phrases \u2014 she had not filled in the ‘Additional Complaint Details’ section and provided almost no factual narrative. The court held that this kind of bare-bones administrative complaint does not give the agency or the employer the notice required for exhaustion, and therefore cannot support any FEHA cause of action in court.<\/p>\n

On the wage-and-hour claims (meal break, rest break, and itemized wage statement), the court found the plaintiff had already settled those claims as a member of two earlier class actions and had effectively abandoned them by failing to address them in opposition to the motion. On the negligent hiring and negligent supervision\/retention claims, the court applied the two-year statute of limitations under California Code of Civil Procedure section 335.1 to time-bar most allegations and found that the post-cutoff evidence \u2014 primarily double-hearsay deposition testimony about a supervisor allegedly asking coworkers to help fire the plaintiff \u2014 was inadmissible and insufficient to create a triable fact question.<\/p>\n

The UCL claim, which depended on the underlying statutory violations, fell with them. As the court put it, when statutory claims fail, derivative UCL claims fail too.<\/p>\n

Key Takeaways<\/h2>\n