Overview

HOLDINGS: [1]-Substantial evidence supported a jury finding that a church and an affiliated entity operated as a single employer for purposes of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000 et seq., because testimony showed that church officials were involved in a decision to terminate an employee who complained of sexual harassment; [2]-The religious entity exemption in Gov. Code, § 12926, subd. (d), applied to preclude liability for retaliation under Gov. Code, § 12940, subd. (h), because the exemption was not waived, equitable estoppel could not be used offensively, and a single employer fell within the § 12940, subd. (h), definition of an employer; [3]-The employee could recover punitive damages for a whistleblower violation under Lab. Code, §§ 1102.5, 1105, and Civ. Code, § 3294, subd. (a), because the whistleblower statute did not limit recovery to contract damages.

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Outcome

Affirmed as modified.