Plaintiff Adelaida Martinez, who worked at a Carl's Jr. in Hemet, California, for 32 years, alleges she was fired after requesting an additional six months of medical leave to recover from breast cancer surgery.
The court found genuine disputes of material fact regarding whether the restaurant chain's stated reason for the termination—that the leave appeared indefinite and caused staffing hardships—was pretextual.
Martinez’s benefits analyst, Alicia Dietrich, testified that the leave was the only reason for her termination, yet also stated the company could not accommodate what appeared to be an indefinite leave. The court noted this inconsistency, along with doctor’s notes specifying a return date, created a factual question for a jury.
Additionally, the court rejected the argument that Martinez’s absence created an undue hardship, noting the store operated for over six months without her and hired other cooks during her leave.
The ruling also preserves Martinez’s claim for punitive damages against two corporate employees, HR director Charon Alexander and Dietrich. The judge determined there is a dispute over whether these individuals qualify as "managing agents" with the authority to set corporate policy.
District Manager Rigoberto Salinas was granted summary judgment on punitive damages, as the court found he did not exercise substantial independent authority over corporate policy.
Martinez’s complaint, originally filed in Riverside County Superior Court, was removed to federal court and alleges violations of the Fair Employment and Housing Act.