Adrian Camacho began working as a cashier at Target in 2012.

Target has a zero-tolerance policy with respect to harassment and discrimination in the workplace. Camacho complained to his supervisor and to individuals in the Human Resources Department, and also called Target’s “Anonymous Hotline,” regarding repeated verbal harassment from his coworkers at Target based on the fact that he is gay. According to Camacho, his coworkers would ridicule, mimic, and mock him, sometimes in the presence of Target customers.

Camacho alleges that rather than take corrective action in response to his complaints, Target instead retaliated against him by denying him a promotion and allowing the hostile work conditions to continue, unabated.

In August 2014, prior to resigning, Camacho filed a claim for workers’ compensation benefits, based on his assertion of workplace injuries that he suffered as a result of the harassment he endured while employed at Target. Specifically, Camacho asserted injuries related to head and neck pain, as well as digestive and psychological problems.

Camacho settled his workers’ compensation case with Target. He executed the mandatory preprinted Compromise and Release (C&R) form that is utilized in all workers’ compensation cases. Camacho and Target also executed an addendum and received $12,000 in exchange for executing the settlement document.

Camacho received a right-to-sue letter from the DFEH and then filed a civil complaint against Target in which he asserted several causes of action for discrimination based on sexual orientation, and harassment causing a hostile work environment.

Target moved for summary judgment. The trial court concluded that the C&R and Addendum executed by the parties in Camacho’s workers’ compensation case constitutes a general release of all potential civil claims that Camacho might have as a result of the harassment he experienced at Target. The court entered judgment in favor of Target and Camacho appealed. The Court of Appeal reversed in the published case of Camacho v Target.

Target relied on language in the C&R Addendum that said he released Target for the Workers’ Compensation claim “or any other claims for reimbursement, benefits, damages, or relief of whatever nature.”

The Court concluded that “After examining the language of the entire document, including the preprinted C&R and Addendum A and considering each term within the context of the others, it is clear that there is no reference in either the C&R or Addendum A to any causes of action outside the workers’ compensation system, much less to a release of such claims in “clear and nontechnical language,” as is required under Claxton v. Waters (2004) 34 Cal.4th 367.