Jose Luis Nazar and Land of the Free own an office building located at 640 S. San Vicente Boulevard (the San Vicente property) and an event space located at 2400 Laurel Canyon Boulevard in Los Angeles (the Laurel Canyon property) L.P. Sylvia Noland was hired hired to work as their leasing agent and sales representative. She filed a lawsuit in August 2018 asserted 25 causes of action, including violations of California’s wage and hour laws, constructive and wrongful termination and other employment law related claims. The trial court granted defendants’ motion for summary judgment, finding no triable issues as to any of those claims. Among other things, the court found the evidence was undisputed that (1) plaintiff was an independent contractor, not an employee, and thus the wage and hour laws did not apply to her, (2) defendants did not owe plaintiff a commission because the tenant plaintiff said she secured ultimately did not execute a lease with defendants, (3) plaintiff had not demonstrated that she was subject to any adverse employment actions that could form the basis for a retaliation action, and (4) plaintiff did not demonstrate triable issues as to her intentional infliction of emotional distress claim. On July 25, 2023, plaintiff filed a notice of appeal from the order granting summary judgment and challenges the grant of summary judgment on several grounds. On appeal she was represented by Mostafavi Law Group and Amir Mostafav located in Los Angeles. The judgment was affirmed. Attorney Amir Mostafavi was directed to pay $10,000 in sanctions in the published case of Noland v. Land of the Free, L.P. -B331918 (September 2025). Relevant excerpts from the opinion are quoted below. "Prior to oral argument in this case, on our own motion we issued an order to show cause (OSC) why this court should not sanction plaintiff’s counsel, Amir Mostafavi, for filing appellate briefs replete with fabricated quotes and citations. The OSC noted that nearly all of the quotations in appellant’s opening brief, as well as many in the reply brief, were fabricated, and it warned that sanctions might include both an award of attorney fees and costs to defendants and an award of sanctions payable to the clerk of this court." "Attorney Mostafavi filed a written response. He acknowledged that he relied on AI 'to support citation of legal issues' and that the fabricated quotes were AI-generated. He further asserted that he had not been aware that generative AI frequently fabricates or hallucinates legal sources and, thus, he did not 'manually verify [the quotations] against more reliable sources.' Mostafavi accepted responsibility for the fabrications and said he had since taken measures to educate himself so that he does not repeat such errors in the future." "Plaintiff challenges the grant of summary judgment on several grounds, none of which raises any novel questions of law or requires us to apply settled law in a unique factual context. In short, this is in most respects a straightforward appeal that, under normal circumstances, would not warrant publication." "What sets this appeal apart - and the reason we have elected to publish this opinion - is that nearly all of the legal quotations in plaintiff’s opening brief, and many of the quotations in plaintiff’s reply brief, are fabricated. That is, the quotes plaintiff attributes to published cases do not appear in those cases or anywhere else. Further, many of the cases plaintiff cites do not discuss the topics for which they are cited, and a few of the cases do not exist at all. These fabricated legal authorities were created by generative artificial intelligence (AI) tools that plaintiff’s counsel used to draft his appellate briefs. The AI tools created fake legal authority - sometimes referred to as AI “hallucinations” - that were undetected by plaintiff’s counsel because he did not read the cases the AI tools cited." "Although the generation of fake legal authority by AI sources has been widely commented on by federal and out-of- state courts and reported by many media sources, no California court has addressed this issue. We therefore publish this opinion as a warning. Simply stated, no brief, pleading, motion, or any other paper filed in any court should contain any citations - whether provided by generative AI or any other source - that the attorney responsible for submitting the pleading has not personally read and verified. Because plaintiff’s counsel’s conduct in this case violated a basic duty counsel owed to his client and the court, we impose a monetary sanction on counsel, direct him to serve a copy of this opinion on his client, and direct the clerk of the court to serve a copy of this opinion on the State Bar." ...

Ventura County District Attorney Erik Nasarenko announced that Gonzalo Robles Zurita (DOB 10/10/88), of Oxnard, has been charged with felony workers’ compensation insurance fraud for allegedly claiming that an arm injury he received in 2022 occurred at his place of employment. He is also charged with one felony count of attempted perjury under oath for statements made during a sworn deposition regarding the arm injury. Zurita made his first court appearance on September 11, 2025, where he pled not guilty to all charges. Zurita’s claim in 2022 that he was injured on the job resulted in the opening of a State of California worker’s compensation claim, which entitled him to compensation, medical treatment, and other worker’s rights. The State Compensation Insurance Fund paid over $20,000 based on Zurita’s allegedly fraudulent claim that his injury was workplace related. The State Compensation Insurance Fund assigned their Special Investigation Unit to conduct a criminal investigation regarding the date, time, and location where the arm injury occurred. The investigation revealed that Zurita allegedly made false or fraudulent statements and representations for the purpose of obtaining compensation. Zurita is scheduled for an early disposition conference on September 22, 2025, at 1:30 p.m. in courtroom 12 and a preliminary hearing was scheduled for September 24, 2025, at 8:15 a.m. in courtroom 14. Zurita was released from custody on his own recognizance and faces a maximum of three years, six months in jail. The California Department of Insurance (CDI) estimates that workers’ compensation fraud costs $1 billion to $3 billion annually. This fraud increases the premiums that employers pay to obtain insurance, affecting legitimate businesses and all consumers in California through increased prices Senior Deputy District Attorney Joann Roth, a member of the Ventura County District Attorney’s Office Special Prosecutions Workers’ Compensation Fraud Unit, is prosecuting the case ...

The Sonoma Index-Tribune reports that California counties, including Sonoma, are struggling under skyrocketing insurance costs. It goes on to report that "Sonoma County has seen its overall liability insurance costs go up more than 500% in the past decade, according to data obtained by The Press Democrat. The county’s spending on that insurance has gone from under $3.8 million for fiscal year 2014-2015 to almost $23.8 million for 2024-2025." The Press Democrat primarily focuses on the surge in liability insurance costs for California counties (such as Sonoma County's 500% increase over the past decade, driven largely by law enforcement-related claims and a shrinking insurance market), it briefly mentions workers' compensation as one of the core insurance types local governments manage alongside property and liability coverage. A broader search for recent reports, statements from county officials, and industry analyses indicated that California's workers' compensation system is notoriously one of the most expensive in the U.S., and counties-as major public employers with high-risk roles like law enforcement, firefighting, and public works - face significant burdens. The following is a breakdown of the main issues based on recent reports (as of September 2025): California ranks as the 3rd most expensive state for workers' compensation insurance, with average rates about 178% higher than the national median. This is due to factors like high medical costs, a litigious environment, and the state's unique regulatory system (overseen by the Workers' Compensation Insurance Rating Bureau of California, or WCIRB, rather than the national NCCI standard). In 2025, the California Department of Insurance approved an 8.7% increase in the average advisory pure premium rate - the first meaningful rise in over a decade. Insurance Commissioner Ricardo Lara alerted state leaders in a letter that these "growing costs" could impact businesses and public entities like counties, signaling a shift in market conditions that might lead to further hikes. Ben Adler, spokesperson for the California State Association of Counties (CSAC), has echoed sentiments from the Sonoma article by noting that insurance challenges (including workers' comp) are forcing cuts to services residents rely on, such as law enforcement and wildfire protection. In Sonoma, where the Sheriff's Office already dominates liability spending ($13.1 million in 2024-2025), workers' comp adds to the fiscal strain for high-risk deputies and correctional staff. Napa County officials have reported general insurance costs (including workers' comp) doubling in five years, with expectations of 20% annual rises. This mirrors Sonoma's experience and has prompted "tough conversations" about service reductions, as noted by Napa CEO Ryan Alsop. Public sector roles like policing, firefighting, and jail operations involve inherent risks, leading to frequent claims for injuries (e.g., back strains, assaults, or repetitive stress). Counties complain that these drive up experience modification factors (which adjust premiums based on claim history), making coverage more expensive. Fraud is a major grievance. The Sonoma County District Attorney's Office received a $339,173 grant in 2023-2024 from the California Department of Insurance to investigate workers' comp fraud, including claimant exaggeration, employer premium evasion, and medical provider schemes. Officials like DA Carla Rodriguez emphasize that fraud inflates system-wide costs, affecting honest employers like counties. Statewide, fraud investigations highlight how it increases premiums for everyone, with counties bearing the brunt as self-insured or pooled entities. Similar to workers' comp costs liability insurance costs are fueled by increasing jury awards, lengthy claim resolutions (averaging 16 months), and uncapped damages in California. Counties complain about "nuclear verdicts" and extended filing deadlines (e.g., from recent laws like those extending child abuse claim windows, though this hits schools harder). Medical treatment costs in California are among the highest nationally, with evidence-based care requirements adding to expenses. The state's no-fault system ensures benefits for most claims, but counties report disputes over benefit delivery, leading to audits and appeals via the Division of Workers' Compensation (DWC). Shared risk pools like PRISM (used by Sonoma and 54 other counties) spread costs but also mean one county's high claims can raise premiums for all, exacerbating complaints during waves of litigation. Insurers are pulling back from California due to reinsurance shortages (85% loss, per CSAC) and post-2020 shifts in public perception of high-risk jobs (e.g., after George Floyd). This leads to fewer options and higher premiums, with some counties facing 1000% spikes in related coverages. Workers' comp follows suit, as noted in Gallagher's 2025 public sector trends analysis. Small or rural counties like Lake and Mendocino (neighbors to Sonoma) echo these issues, with officials pushing for reforms like better fraud prosecution and de-escalation training to lower claims ...

The Justice Department filed a lawsuit against Uber Technologies Inc. for discriminating against passengers with disabilities, including those who use service animals and mobility devices such as stowable wheelchairs. Uber is the largest provider of ride-hailing services in the United States. The lawsuit seeks $125 million for individuals who have been subject to discrimination and previously submitted complaints to Uber or the Department. The lawsuit, filed in the U.S. District Court for the Northern District of California, alleges Uber violated Title III of the Americans with Disabilities Act (ADA), which prohibits discrimination based on disability by private transportation companies like Uber. The ADA also requires Uber to allow service animals to accompany individuals with disabilities in vehicles and to provide rides to, and assist, riders with stowable wheelchairs and mobility devices. The Department’s civil complaint alleges that Uber and its drivers routinely refuse to serve individuals with disabilities; impose impermissible surcharges by charging cleaning fees for service animal shedding and cancellation fees to riders whom Uber has unlawfully denied service; and refuse to reasonably modify Uber’s policies, practices, or procedures, where necessary, to avoid discriminating against riders with disabilities, including by denying individuals with mobility disabilities the option to sit in the front seat when needed. Due to Uber’s ride denials, individuals with disabilities have experienced significant delays, missed appointments, and have been left stranded in inclement weather. “Rideshare companies like Uber are prohibited from denying riders with disabilities the same access to transportation that riders without disabilities enjoy,” said U.S. Attorney Craig H. Missakian of the Northern District of California. “This complaint underscores the United States’ commitment to enforcing the ADA’s promise of equal access.” “For too long, blind riders have suffered repeated ride denials by Uber because they are traveling with a service dog,” said Assistant Attorney General Harmeet K. Dhillon of the Justice Department’s Civil Rights Division. “This lawsuit seeks to end this persistent discrimination and allow riders with disabilities to use Uber. We will enforce the ADA’s guarantee that people with disabilities have equal opportunity and full participation in all aspects of American society, including transportation.” The lawsuit seeks a court order to force Uber to stop discriminating against individuals with disabilities, to modify its policies to comply with the ADA, and to train its staff and drivers on the ADA. In addition to the monetary damages to compensate aggrieved individuals subjected to Uber’s discrimination, the lawsuit demands that Uber pay a civil penalty to vindicate the public’s interest in eliminating disability discrimination. To learn more about the Civil Rights Division visit www.justice.gov/crt, and to report possible violations of federal civil rights laws go to www.civilrights.justice.gov. For more information on the ADA, please call the department’s toll-free ADA Information Line at 800-514-0301 (TTY 1-833-610-1264) or visit www.ada.gov ...

On July 21, 2025, the Department of Justice (DOJ) updated its recent accomplishments, which included a section on enforcing citizens’ rights in a place of public accommodation. The DOJ noted two such litigations under Title II on its website. The more recent matter was a case that took place in California. The United States filed a federal complaint in the U.S. District Court for the Northern District of California (Case No. 3:25-cv-04849-SK) United States v. Fathi Abdulrahim Harara, et al. (Jerusalem Coffee House). The case alleges that the defendants - Fathi Abdulrahim Harara (also known as Abdulrahim "Raheem" Harara) and Native Grounds LLC, doing business as Jerusalem Coffee House - engaged in discriminatory practices against Jewish customers at their Oakland, California, coffee shop. The suit claims violations of Title II of the Civil Rights Act of 1964, which prohibits discrimination based on race, color, religion, or national origin in places of public accommodation. The DOJ is seeking declaratory and injunctive relief, including a court order to stop the alleged discrimination and remedy its effects, but not monetary damages. The Jerusalem Coffee House, located on Telegraph Avenue in North Oakland's Temescal neighborhood, opened in September 2023 as a Palestinian-inspired café serving items like coffees, teas, smoothies, and baked goods influenced by Palestinian cuisine (e.g., a "Bebsi" coffee drink and date-tahini latte). Harara, whose parents were born in Gaza, described it upon opening as a "vibrant cultural hub for Palestinian and Islamic thought" and a space "directly linked in heart and faith to liberation struggles around the world," welcoming to Palestinians, Oakland residents, and beyond. The café has hosted art exhibits, public discussions, and fundraisers related to Palestinian causes, partnering with groups like Jewish Voice for Peace Bay Area and Eyewitness Palestine. The complaint details a "policy or practice" of denying Jewish individuals full access to the café's services based on their perceived race and religion. Key incidents cited include a June 2024 Incident Involving Michael Radice, a Jewish resident from Los Angeles scouting a nearby community space for a nonprofit event. He allegedly entered the café wearing a blue baseball cap with the phrase "Am Yisrael Chai" (Hebrew for "the people of Israel live") and a Star of David emblem. An employee allegedly confronted him, asking if he was a "Zionist" or "Jew" and accusing him of supporting "genocide" and "killing children" in Gaza. Harara joined, and they followed Radice outside, yelling insults like "Zionist" and "Jew." Radice was not served and left. The DOJ alleges this was the second interaction; in an earlier visit that month without the hat, Radice encountered the same employee but no issues. On October 26, 2024 there was an incident Involving Jonathan Hirsch. Hirsch, an Oakland resident, allegedly entered with his five-year-old son wearing a hat featuring a Star of David. Harara allegedly interrogated him about being a "Zionist," called the hat a "Jewish star" and "violent," accused him of supporting "genocide," and ordered them to leave, claiming they were "trespassing" and "causing a disruption." Video footage of the confrontation, which went viral, shows Harara telling Hirsch, "Get out of my business... You’re the Zionist. We don’t want you in our coffee shop." Harara called the police, falsely reporting trespassing; officers arrived but no arrests were made. Hirsch and his son were not served and left. The DOJ notes neither customer expressed political views during the visits. Additional allegations include - On October 7, 2024 (the one-year anniversary of the Hamas attacks on Israel), the café introduced drinks like "Iced In Tea Fada" (a play on "intifada," referencing Palestinian uprisings) and "Sweet Sinwar" (referencing Yahya Sinwar, the late Hamas leader who orchestrated the October 7 attacks that killed about 1,200 Israelis). The DOJ argues these actions demonstrate a pattern of discrimination, denying Jewish patrons "the full and equal enjoyment" of the café. Assistant Attorney General Harmeet Dhillon stated, "It is illegal, intolerable, and reprehensible for any American business open to the public to refuse to serve Jewish customers." Harara and his attorneys (Glenn Katon and Walter Riley) deny antisemitism, asserting the incidents were provoked by customers staging confrontations to target the pro-Palestinian café amid the Israel-Hamas war. They claim: - No one was actually denied service; interactions were brief and non-violent (e.g., Katon said Harara and Radice "literally shook hands"). Defense attorneys argue that the Star of David hats represent Zionism (support for Israel), not Judaism, and the café's actions were political protest against Israel's actions in Gaza, which Harara calls "genocide." He has lost relatives in the conflict. Harara spoke publicly for the first time on July 30, 2025, at a press conference at the café, surrounded by supporters including Jewish groups like the International Jewish Anti-Zionist Network and Jewish Voice for Peace. He described the café as a "treasured Oakland space" for community building, including Jewish patrons, and emphasized solidarity: "Despite the violence my people have endured... my heart remains faithfully tethered to a justice greater than anything the human mind can comprehend." Supporters packed events in his defense, viewing the case as an attack on Palestinian liberation efforts. On September 10, 2025, U.S. District Judge Susan Illston denied the defendants' motion to dismiss. Treating the DOJ's allegations as true, the court ruled that the complaint sufficiently states a claim under Title II for a "pattern or practice" of discrimination. The case is proceeding to discovery and further proceedings ...

The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) proposed a Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings rule in July 2024, which was formally published in the Federal Register on August 30, 2024. This marked the first federal standard aimed at protecting approximately 36 million workers across general industry, construction, maritime, and agriculture sectors from heat-related hazards, with requirements triggering at a heat index of 80°F (initial controls like water, rest, and shade) and escalating at 90°F (additional measures like acclimatization and emergency response plans). The proposal builds on OSHA's National Emphasis Program on heat hazards, launched in 2022, which has already led to over 5,000 inspections. Informal public hearings took place from June 16 to July 2, 2025 on the proposed rule. The hearings were virtual, allowing broad participation. A post-hearing comment period remains open until September 30, 2025, for those who participated to submit additional evidence or briefs. The hearings drew over 50,000 written comments prior, reflecting high interest amid record heat waves. Representatives from the National Employment Law Project (NELP) and unions like the AFL-CIO argued the rule is essential for vulnerable workers, such as farmworkers, construction laborers, and warehouse employees, who face disproportionate risks from climate change-exacerbated heat. NELP's Anastasia Christman, who attended multiple sessions, noted OSHA staff appeared "engaged and asked substantive questions," praising the agency's focus on real-world implementation. Farmworker advocates and groups like the United Farm Workers highlighted how the rule could prevent thousands of heat-related illnesses annually (OSHA estimates up to 2,000 preventable deaths and 50,000 injuries yearly without it). They pushed for stronger enforcement in high-risk sectors like H-2A temporary agricultural labor, where language barriers and lack of acclimatization increase dangers. Public health witnesses cited data showing only 24% of employers currently have heat policies, with 41% of workers unaware of any protections, often leaving rest and cooling decisions to employees - potentially forcing health vs. productivity trade-offs. The U.S. Small Business Administration’s Office of Advocacy testified on the first day (June 15 or 16), arguing the 80°F trigger is too low for many operations and could impose undue costs on small employers without flexibility. They advocated for a more "performance-based" approach, allowing employers to tailor plans rather than follow rigid requirements. Construction industry representatives, such as from the Associated General Contractors, warned of compliance challenges in varying climates, suggesting geographic variations or higher triggers in cooler regions. They noted 16 states already have or are proposing heat rules, creating a patchwork that a federal standard might complicate. Broader business coalitions criticized the rule's scope, estimating high implementation costs (e.g., monitoring, training, and plan development) and potential litigation risks under recent Supreme Court decisions limiting agency authority (e.g., challenges via the Chevron doctrine's overturn). Some expressed surprise the hearings proceeded under the Trump administration, given its deregulation focus, but speculated the rule might be "toned down" to a less detailed version ...

President Donald J. Trump just signed a memorandum aimed at addressing misleading direct-to-consumer (DTC) prescription drug advertisements. The action aligns with Health and Human Services Secretary Robert F. Kennedy Jr.'s long-standing criticism of DTC drug ads, which he argues contribute to overmedicalization and mislead consumers. Kennedy has stated, “Pharmaceutical ads hooked this country on prescription drugs,” emphasizing the need for transparency to break this cycle. The U.S. and New Zealand are the only countries allowing broad DTC pharmaceutical advertising. Despite widespread violations, the FDA has been increasingly lax and reactive in its enforcement approach over the last few decades. The FDA used to send more than a hundred warning letters each year, and misleading ads were rare. But over time, enforcement waned and the number of warning letters sent to pharmaceutical companies dropped to one in 2023 and zero in 2024. On the same day as the Presidential memorandum, the FDA announced it is sending approximately 100 cease-and-desist letters and thousands of warning letters to pharmaceutical companies and online pharmacies for deceptive ads. The FDA said that it will no longer tolerate such deceptive practices. Going forward, the agency will aggressively deploy its available enforcement tools. The FDA is already implementing AI and other tech-enabled tools to proactively surveil and review drug ads. A 2024 review in the Journal of Pharmaceutical Health Services Research reveals that while 100% of pharmaceutical social media posts highlight drug benefits, only 33% mention potential harms. Moreover, 88% of advertisements for top-selling drugs are posted by individuals and organizations that fail to adhere to the FDA fair balance guidelines. The Pharmaceutical Research and Manufacturers of America (PhRMA) defended DTC advertising, citing First Amendment protections and its role in patient awareness, but expressed willingness to engage with the policy changes. DTC advertising is a multi-billion-dollar industry, with $10.8 billion spent in 2024, including $5.15 billion on TV ads. Stricter regulations could reduce ad revenue for drugmakers and media networks, particularly if longer disclosures make TV ads less feasible. The action stops short of a full ban on DTC ads, which Kennedy had previously advocated for, likely to avoid legal challenges on First Amendment grounds, as seen in a 2019 court ruling that blocked Trump’s attempt to require price disclosures in TV ads. Past efforts to regulate DTC ads have faced court challenges, and the current action may encounter similar resistance, especially given the Supreme Court’s 2025 ruling overturning the Chevron doctrine, which limits executive regulatory authority. The memorandum directs the Department of Health and Human Services (HHS) and the Food and Drug Administration (FDA) to enhance transparency and accuracy in DTC pharmaceutical advertising, particularly by increasing disclosures of drug risks and side effects. It seeks to ensure ads provide a fair balance of benefits and risks, as mandated by existing regulations under the Federal Food, Drug, and Cosmetic Act (FDCA). The action targets both traditional media (e.g., TV) and digital platforms, including social media, where ads often lack proper disclosures. It addresses issues like undisclosed influencer promotions and online pharmacies flouting rules that larger pharmaceutical companies follow. The administration is also closing a 1997 FDA "adequate provision" loophole, which allowed companies to provide abbreviated side effect information in ads by directing consumers to external sources (e.g., websites). This change may require longer, more detailed disclosures, potentially impacting ad formats ...

Bakersfield Recovery Service, Inc. (BRS) provides substance abuse treatment to recovering alcoholics and drug addicts. In 2019, Plaintiff Steven Kruitbosch began working as an assistant corporate compliance officer at BRS. His job responsibilities required him to oversee client services, ensure all staff properly documented services, that staff were providing clients with evidence-based services, ensure facilities were operational and properly maintained, and ensure BRS adhered to contractual obligations. Plaintiff Kruitbosch also trained all staff on various aspects of their jobs. Near the end of his employment, he was tasked with overseeing construction of a new facility that BRS was designing for clients. At various times during his employment, Kruitbosch attended sexual harassment trainings that made clear even sexual harassment off the clock was a violation of BRS policy. Many of BRS’s employees, including plaintiff, are recovering addicts, and most employees, including co-worker Lisa Sanders, knew plaintiff was sober after having struggled with drug addiction. Plaintiff and other employees were open about their addiction recovery as part of their work with BRS. In October 2022, plaintiff’s long-time partner passed away. In dealing with the grief of that loss, plaintiff took leave under the California Family Rights Act beginning February 1, 2023, and was scheduled to return to work on March 7, 2023. In the week leading up to plaintiff’s return to work, Lisa Sanders began sending plaintiff multiple unsolicited nude pictures and stating she wanted to have sex with him; plaintiff firmly rejected these advances. On March 3, 2023, Sanders went to plaintiff’s home uninvited and brought a friend. Sanders indicated to plaintiff she was there to have sex with him; plaintiff instructed the women to leave him alone and to stop harassing him. Sanders again indicated she wanted to have sex with plaintiff. Sanders eventually departed plaintiff’s property, On March 7, 2023, plaintiff returned to work and immediately complained to the acting program director Stephanie Carroll about Sanders’s conduct. HR representative Kimberly Giles was also made aware that Sanders had sent plaintiff nude photos, propositioned him for sex, offered him drugs, and presented herself at his house. Carroll informed plaintiff that there was not much she could do about Sanders’s behavior ostensibly because it occurred off the worksite. Later that day, Giles posted a video on social media depicting whining dogs and stated, “‘This is a work day at thr [sic] office … lmbo.’” (Italics omitted.) Later in the week, Giles sarcastically commented to plaintiff, “‘I hope you don’t get no more pictures.’” At no point did either Carroll or Giles take any steps to separate plaintiff from Sanders or prevent future harassment; nor did BRS take any disciplinary action as to Sanders. Although Kruitbosch made efforts to avoid Sanders in the office, his distress at the prospect of interacting with her coupled with BRS’s failure to protect him in the workplace and mocking him for his complaint detracted from his work duties and made continuing his employment feel impossible. Plaintiff resigned a week later. Plaintiff filed the operative second amended complaint (SAC) in October 2023 alleging nine claims against BRS, and a claim of intentional infliction of emotional distress against Sanders only: (1) hostile work environment sexual harassment in Violation of FEHA (§ 12940, subd. (j)); (2) sex/gender discrimination in violation of FEHA (§ 12940, subd. (a)); (3) retaliation in violation of FEHA (§ 12940, subd. (h)); (4) failure to prevent harassment, discrimination, or retaliation in violation of FEHA (§ 12940(k)); (5) whistleblower retaliation in violation of Labor Code section 1102.5; (6) constructive termination in violation of public policy; (7) intentional infliction of emotional distress (against Sanders only); (8) negligent hiring, supervising, or retention; (9) failure to timely produce personnel records; and (10) failure to timely produce payroll records. BRS demurred as to all claims, except as to claims 9 and 10. The trial court sustained BRS’s demurrer without leave to amend. Following the trial court’s ruling, plaintiff dismissed his two remaining claims for failure to timely produce records and appealed with respect to BRS. The Court of Appeal reversed in part and affirmed in part in the partially published case of Kruitbosch v. Bakersfield Recovery Services, Inc. -F087809 (September 2025). Only the Introduction, Factual Background, parts I. and V. of the Discussion, and the Disposition are certified for publication. In the view of the Court of Appeal "although Sanders’s alleged conduct was reprehensible, it was not sufficiently work related within the ambit of FEHA, and it did not recur inside the workplace. Her underlying conduct is not imputable to BRS, and the claim is not cognizable on that basis." "Nevertheless, the sexual harassment hostile work environment claim is viable based on a theory that BRS’s response to plaintiff’s complaint about Sanders’s conduct altered plaintiff’s work environment in an objectively severe manner. Plaintiff’s claim for failure to prevent harassment, discrimination or retaliation under section 12940, subdivision (k) (§ 12940(k)) is dependent upon a viable claim for harassment, discrimination or retaliation; because plaintiff’s underlying claim for sexual harassment is viable, plaintiff’s section 12940(k) claim is also cognizable. With respect to these claims, we reverse the trial court’s ruling sustaining BRS’s demurrer." "As for the remaining claims, plaintiff did not sufficiently allege constructive termination or any other adverse employment actions necessary to support his claims for discrimination, retaliation, and constructive discharge in violation of public policy. Finally, plaintiff’s claim for negligent hiring, supervision or retention does not sufficiently allege BRS’s knowledge of the unfitness of its employees. With respect to these claims, we affirm the trial court’s ruling." "For purposes of clarity, plaintiff shall amend the complaint to present his allegations under the theory of hostile work environment sexual harassment, consistent with this opinion, that we have found viable. Plaintiff’s amendment may include additional allegations regarding the imputability of Carroll’s and Giles’s actions to BRS under the relevant standard." ...

In May 2019, Dr. Duke Ahn, a licensed physician, pleaded guilty to a misdemeanor violation of Business and Professions Code section 650 for receiving compensation for patient referrals. He was placed on three years’ probation, paid $80,114 in restitution and $8,000 to a victim witness fund, and successfully moved for dismissal of the case in August 2020 under Penal Code section 1385, before completing probation. In August 2022, the Division of Industrial Relations (DIR) suspended Ahn from the workers’ compensation system under Labor Code section 139.21, which mandates suspension for physicians convicted of certain crimes, including fraud related to the workers’ compensation system or patient care. Ahn challenged the suspension in an administrative hearing, arguing that the dismissal under Penal Code section 1385 nullified his conviction, rendering Labor Code section 139.21 inapplicable. The administrative law judge (ALJ) upheld the suspension, noting that the dismissal did not erase the guilty plea or its factual basis. Ahn filed a petition for writ of mandate in superior court under Code of Civil Procedure section 1094.5, which was denied on December 6, 2023. The court found that Ahn’s guilty plea constituted a “conviction” under Labor Code section 139.21, subdivision (a)(4)(C), and the dismissal did not exempt him from suspension. Ahn appealed, arguing that the Penal Code section 1385 dismissal meant he was not “convicted” under Labor Code section 139.21. The Court of Appeal affirmed the trial court in the unpublished case of Ahn v. Parisotto - B337936 (September 2025). The Court of Appeal affirmed the suspension, finding it supported by the plain language of Labor Code section 139.21. The legal issue was whether a dismissal under Penal Code section 1385 negates a guilty plea for the purposes of suspension under Labor Code section 139.21, which defines “convicted” to include a guilty plea accepted by a court. The Court of Appeal conducted a de novo review, as the issue was purely legal with no disputed facts. Labor Code section 139.21, subdivision (a)(4)(C) explicitly defines “convicted” as including a guilty plea accepted by a court, with no exceptions for subsequent dismissals. The court emphasized that the statute’s plain language does not allow for inserting exceptions not provided by the Legislature. The court distinguished cases like People v. Barro (2001) and People v. Chavez (2016, 2018), which dealt with criminal sentencing or post-probation dismissal procedures, as inapplicable to the administrative context of Labor Code section 139.21. The court noted that Labor Code section 139.21, enacted in 2016 and amended in 2018, is a specific, later-enacted statute compared to the general Penal Code section 1385 (enacted 1872). If there were a conflict, the more specific and recent statute would control. The court concluded that Ahn’s guilty plea, accepted by the court, met the definition of “convicted” under Labor Code section 139.21, and the subsequent dismissal did not negate this. Thus, the DIR’s suspension was legally supported. Key Takeaway: A guilty plea, once accepted by a court, constitutes a “conviction” under Labor Code section 139.21 for the purpose of suspending a physician from the workers’ compensation system, regardless of a subsequent dismissal under Penal Code section 1385 ...

A felony complaint has been filed by the People of the State of California against Defendant Maria Erolina Delgado (DOB: 6/17/1963) in the Superior Court of California, County of San Diego, Central Division. The complaint, brought by the California Attorney General's Division of Medi-Cal Fraud & Elder Abuse, alleges multiple counts of elder and dependent adult abuse under Penal Code sections 368(b)(1) and 368(c). The offenses are alleged to have occurred in San Diego County and other counties in California between January 1, 2020, and November 30, 2020. The criminal charges against Delgado are for alleged severe neglect of residents at J & M Happy Guest Home, a residential care facility for the elderly in San Diego County. J & M Happy Guest Home is licensed by the California Department of Social Services (CDSS) Community Care Licensing Division as an RCFE with a capacity of 6 beds. It is described in public directories as providing "loving and dignified care" in a home setting, with services like assistance with daily activities. The facility is not rated on state volunteer programs like Choose Well and has no publicly detailed citations or complaints in recent profiles (last updated June 10, 2025, for licensing; August 31, 2025, for citations). However, one public report from October 30, 2024, notes a fire clearance violation, resulting in an immediate civil penalty assessment. No other historical violations, complaints, or enforcement actions are publicly detailed in available sources, though state databases update quarterly. Delgado is the owner of J & M and allegedly left the facility severely understaffed, often leaving residents in bed all day in soiled diapers, sometimes for days at a time. As a result of this neglect, multiple residents suffered from bed sores, dehydration, and malnourishment. The California Department of Justice’s Division of Medi-Cal Fraud and Elder Abuse (DMFEA) works to protect Californians by investigating and prosecuting those responsible for abuse and neglect of elderly and dependent adults and those who perpetrate fraud on the Medi-Cal program. The Division of Medi-Cal Fraud and Elder Abuse receives 75 percent of its funding from the U.S. Department of Health and Human Services under a grant award totaling $69,244,976 for Federal fiscal year (FY) 2025. The remaining 25 percent is funded by the State of California. FY 2025 is from October 1, 2024, through September 30, 2025 ...

Plaintiffs Joseph Davis and Shavonda Early brought a class action lawsuit against defendant CSAA Insurance Exchange (CSAA), an automobile insurance company, claiming that automobile insurance rates became excessive during the COVID-19 pandemic when there was less driving and fewer traffic accidents. Plaintiffs alleged that, in 2020 and 2021, CSAA was the fifth largest automobile insurance company in the state and insured over one million California drivers. The complaint alleged two causes of action under California’s Unfair Competition Law (Bus. & Prof. Code § 17200 et seq.) (UCL) and a cause of action for unjust enrichment. The complaint alleged that, by not unilaterally refunding premiums, CSAA violated Insurance Code § 1861.05, subdivision (a) (section 1861.05(a)).2 This section, titled “Approval of Insurance Rates,” provides that “[n]o rate shall be approved or remain in effect which is excessive, inadequate, unfairly discriminatory or otherwise in violation of this chapter.” CSAA filed a demurrer, which the trial court sustained with leave to amend. The court interpreted section 1861.05(a)’s language that no excessive rate shall “remain in effect” as applying to the insurance commissioner’s system of approving rates, and meant to “ensure that a previously approved rate does not ‘remain in effect’ if the circumstances have changed.” The court found that the statute allowed for prospective rate reductions when rates become excessive, but not retroactive modifications of previously approved rates. In their first amended and consolidated complaint, plaintiffs reasserted the UCL claims, and reiterated that CSAA received an “unprecedented windfall” from the COVID-19 pandemic by continuing to charge preapproved rates as driving and traffic accidents decreased dramatically. At the same time, plaintiffs acknowledged that some refunds were given. They recognized that, in April 2020, the insurance commissioner issued a bulletin directing insurers to “make an initial premium” refund for the prior two months. Although CSAA gave a 20 percent refund to policyholders, plaintiffs alleged that this amount was inadequate and the approved rates for this period remained excessive. Plaintiffs also recognized that the commissioner sent additional bulletins extending the directive for refunds. Although CSAA subsequently gave a 10 percent refund for May and June 2020, plaintiffs alleged that the rates were still excessive. According to plaintiffs, in 2021 the commissioner described the premium returns by California insurance companies as “insufficient.” Plaintiffs asserted that CSAA’s failure to provide sufficient refunds violated section 1861.05(a) and was unfair and unlawful. They sought restitution for the “unearned premiums acquired from [named plaintiffs] and the Class along with CSAA’s investment returns on those unearned premiums.” CSAA again demurred, and this time the trial court sustained the demurrer without leave to amend. The Court of Appeal affirmed in the published case of Davis v. CSAA Ins. Exchange - A169729 (September 2025). The central question in this appeal is whether Insurance Code § 1861.05(a) imposes an independent obligation on insurers to refund premiums that were collected under approved rates when those rates later become purportedly excessive. Section 1861.05(a) was enacted through the passage of Proposition 103 in 1988. Its stated purpose was “to protect consumers from arbitrary insurance rates and practices, to encourage a competitive insurance marketplace, to provide for an accountable Insurance Commissioner, and to ensure that insurance is fair, available, and affordable for all Californians.” Proposition 103 was one of five competing insurance initiatives on the ballot, but the only one that passed. Proposition 103 required automobile insurance rates to be determined by applying three factors - the insured’s driving safety record, the annual number of miles driven, and the years of driving experience - and it allowed the insurance commissioner to adopt additional factors. It prohibited rates that were “unfairly discriminatory” and specified that the business of insurance was subject to California’s unfair business practice laws. Proposition 103 also designated the insurance commissioner to be an elected official, no longer appointed by the governor. In arguing that the section imposes an independent obligation on insurers to issue refunds when approved rates become excessive, plaintiffs focus on the language in the first sentence that no “excessive” rate shall “remain in effect.” Plaintiffs contend that the term “approved” and the phrase “remain in effect” in section 1861.05(a) are two distinct directives, and the latter phrase would be surplusage if the statute were interpreted to impose no obligation on insurers to unilaterally refund previously approved rates when circumstances render them excessive. After reviewing the parties arguments, and citations supporting these arguments, the Court of Appeal wrote that "we conclude that section 1861.05(a) does not impose an independent obligation on insurers to retroactively refund premiums, based on rates that were approved by the insurance commissioner, when those rates later become purportedly excessive." The judgment of the trial court was affirmed ...

A man pleaded guilty in a federal court in Los Angeles to leading a long-running scheme in which dozens of medical doctors’ personal information was stolen and then used to create fraudulent e-prescribing accounts, which his accomplices then used to issue thousands of fraudulent prescriptions of controlled substances. Benjamin Jamal Washington, 25, of Hyattsville, Maryland, pleaded guilty to one count of conspiracy to commit wire fraud, one count of aggravated identity theft, and one count of conspiracy to distribute controlled substances. Washington remains in federal custody. According to his plea agreement, from September 2020 to May 2023, Washington and his co-conspirators obtained personal identifying information (PII) belonging to dozens of doctors, including their names, dates of birth, addresses, phone numbers, National Provider Identification number, and Drug Enforcement Administration (DEA) Registration Numbers. After obtaining this information, the co-conspirators impersonated the victims by obtaining fake drivers’ licenses in their names. They also paid corrupt telephone company employees to perform illegal subscriber identity module (SIM) swaps – fraudulently inducing a phone carrier to reassign a cell phone number from the legitimate subscriber to a phone controlled by the co-conspirators – to gain access to the physicians’ phone numbers. Washington and his co-conspirators then used the fraudulent drivers’ licenses and the stolen phone numbers to open fraudulent e-prescribing accounts in the physicians’ names. At least one co-conspirator spoke with a pharmacy technician to understand the patterns and practices of physicians submitting e-prescriptions so Washington and his co-conspirators could avoid detection and issue more fraudulent prescriptions. Once the co-conspirators opened the fraudulent e-prescribing accounts, Washington and others used the accounts to submit at least 5,600 fraudulent prescriptions of controlled substances, including illegal prescriptions of oxycodone and promethazine with codeine. The co-conspirators then traveled to pharmacies across the United States, including pharmacies within the Los Angeles and Orange county area, to pick up the illegally prescribed controlled substances, which they sold for a significant profit. Washington has a criminal history in Maryland, including arrests for robbery-related probation violations in 2022 and 2024, as well as an escape from pre-trial release in St. Mary's County in September 2022 after tampering with his GPS monitor. United States District Judge Wesley L. Hsu scheduled a January 13, 2026, sentencing hearing, at which time Washington will face a statutory maximum sentence of 42 years in federal prison, including a mandatory two-year consecutive prison sentence for the aggravated identity theft count ...

A man pleaded guilty in a federal court in Los Angeles to leading a long-running scheme in which dozens of medical doctors’ personal information was stolen and then used to create fraudulent e-prescribing accounts, which his accomplices then used to issue thousands of fraudulent prescriptions of controlled substances. Benjamin Jamal Washington, 25, of Hyattsville, Maryland, pleaded guilty to one count of conspiracy to commit wire fraud, one count of aggravated identity theft, and one count of conspiracy to distribute controlled substances. Washington remains in federal custody. According to his plea agreement, from September 2020 to May 2023, Washington and his co-conspirators obtained personal identifying information (PII) belonging to dozens of doctors, including their names, dates of birth, addresses, phone numbers, National Provider Identification number, and Drug Enforcement Administration (DEA) Registration Numbers. After obtaining this information, the co-conspirators impersonated the victims by obtaining fake drivers’ licenses in their names. They also paid corrupt telephone company employees to perform illegal subscriber identity module (SIM) swaps – fraudulently inducing a phone carrier to reassign a cell phone number from the legitimate subscriber to a phone controlled by the co-conspirators – to gain access to the physicians’ phone numbers. Washington and his co-conspirators then used the fraudulent drivers’ licenses and the stolen phone numbers to open fraudulent e-prescribing accounts in the physicians’ names. At least one co-conspirator spoke with a pharmacy technician to understand the patterns and practices of physicians submitting e-prescriptions so Washington and his co-conspirators could avoid detection and issue more fraudulent prescriptions. Once the co-conspirators opened the fraudulent e-prescribing accounts, Washington and others used the accounts to submit at least 5,600 fraudulent prescriptions of controlled substances, including illegal prescriptions of oxycodone and promethazine with codeine. The co-conspirators then traveled to pharmacies across the United States, including pharmacies within the Los Angeles and Orange county area, to pick up the illegally prescribed controlled substances, which they sold for a significant profit. Washington has a criminal history in Maryland, including arrests for robbery-related probation violations in 2022 and 2024, as well as an escape from pre-trial release in St. Mary's County in September 2022 after tampering with his GPS monitor. United States District Judge Wesley L. Hsu scheduled a January 13, 2026, sentencing hearing, at which time Washington will face a statutory maximum sentence of 42 years in federal prison, including a mandatory two-year consecutive prison sentence for the aggravated identity theft count ...

The Alamitos Bay Yacht Club in Long Beach hired Brian Ranger as a maintenance worker. He helped the club with its fleet by painting, cleaning, maintaining, repairing, unloading, and mooring vessels. One day, Ranger used a hoist to lower a club boat into navigable waters. He stepped from the dock onto its bow, fell, was hurt, and applied for workers’ compensation. Then he sued the club in state court on federal claims of negligence and unseaworthiness. The trial court sustained the club’s final demurrer to the second amended complaint. The trial court ruled there was no admiralty jurisdiction. The California Court of Appeal affirmed the trial court decision to dismiss the case in the published case of Ranger v. Alamitos Bay Yacht Club - 95 Cal. App. 5th 240, 313 Cal. Rptr. 3d (September 2023). The opinion concluded that “In sum, California’s workers’ compensation law is Ranger’s exclusive remedy. Congress in 1984 decreed this state law aptly covers his situation. A core part of the state workers’ compensation bargain is that injured workers get speedy and predictable relief irrespective of fault. In return, workers are barred from suing their employers in tort. The trial court correctly dismissed Ranger’s tort suit against his employer.” The California Supreme Court reversed in Ranger II v. Alamitos Bay Yacht Club 17 Cal.5th 532 (February 2025). It ruled the Longshore Act’s exclusion of club workers from the act’s coverage meant only that the state, rather than the federal, workers’ compensation system applies, but did not otherwise deprive workers of their federal right to pursue available tort remedies under general maritime law. (Ranger, supra, 17 Cal.5th at p. 548.) The state's top court wrote "To the extent the Court of Appeal's opinion suggests that California's workers' compensation scheme in itself displaces general maritime remedies and constitutes Ranger's exclusive remedy, we disagree. It is true that California's workers' compensation system provides 'a comprehensive statutory scheme governing compensation given to California employees for injuries incurred in the course and scope of their employment." (Charles J. Vacanti, M.D., Inc. v. State Comp. Ins. Fund (2001) 24 Cal.4th 800, 810 [102 Cal.Rptr.2d 562, 14 P.3d 234].) Under Labor Code section 3602, the workers' compensation remedy "provides an injured employee's "exclusive" remedy against an employer for compensable work-related injuries.' (King, supra, 5 Cal.5th at p. 1046.) We conclude, though, that the exclusive-remedy provision does not displace federal law in this case." The California Supreme Court remanded the case to back to the Court of Appeal to consider: 1) whether federal jurisdiction exists; 2) whether Ranger can assert the tort of unseaworthiness; and 3) whether Ranger can assert a negligence claim against his vessel- owning employer. On remand the California Court of Appeal in the unpublished case of Ranger III v. Alamitos Bay Yacht Club -B315302 (September 2025) answered these three questions. In answering the first question, the Court of Appeal began with the step analysis in Grubart v. Great Lakes Dredge & Dock Co. (1995) 513 U.S. 527 and reviewed and applied case law following that decision and held that admiralty jurisdiction applies to Ranger’s claim. The review next turned to the Club’s contention that, even if Ranger’s claim is within admiralty jurisdiction, he cannot bring a claim for unseaworthiness because this claim can only be brought by Jones Act seamen. After reviewing case law beginning with Seas Shipping Co. v. Sieracki, (1946) 328 U.S. 85 and following, the Court of Appeal ruled that this "argument is incorrect. Ranger has an unseaworthiness claim." The Court of Appeal then moved to the third question. "We turn finally to the Club’s faulty contention that Ranger cannot bring a claim against it for negligence as a vessel owner because it is also his employer." The Club’s argument fails because it is founded in the Longshore Act, which does not cover Ranger." "The fact that the Longshore Act only prohibits workers engaged in certain types of service to the vessel from bringing a negligence claim suggests that even covered workers not engaged in those services can sometimes appropriately sue the vessel owner for negligence. The Club has not established Ranger cannot sue the Club for negligence as the vessel owner." ...

AstraZeneca is suing Hawaii over a state statute that requires pharmaceutical companies to offer discounted “340B” drugs to contract pharmacies. The company claims the statute is preempted by federal law and that federal appeals courts have made it clear that federal statute regulating such drugs does not require manufacturers to provide discounted drugs to “unlimited” contract pharmacies. Hawaii is in the United States Court of Appeals for the Ninth Circuit. The Ninth Circuit's jurisdiction covers the western United States, including the states of Alaska, Arizona, California, Hawaii, Idaho, Montana, Nevada, Oregon, and Washington, as well as the U.S. territories of Guam and the Northern Mariana Islands. Thus if this case is appealed, the outcome of the appeal will likely to some degree apply here in California, at least as to the preemption issue. The 340B Drug Pricing Program, established under Section 340B of the Public Health Service Act (42 U.S.C. § 256b), requires pharmaceutical manufacturers participating in Medicaid to offer discounted outpatient drugs to qualifying "covered entities" such as safety-net hospitals, community health centers, and certain clinics serving low-income or underserved populations. These entities can contract with external pharmacies (known as "contract pharmacies") to dispense the discounted drugs to their patients, but the federal statute itself does not explicitly mandate that manufacturers provide these discounts through an unlimited number of such pharmacies. Over the past few years, disputes have arisen as some manufacturers, including AstraZeneca, have imposed restrictions on contract pharmacy arrangements, citing concerns over program integrity, duplicate discounts, and diversion of drugs to ineligible patients. Federal appeals courts have largely sided with manufacturers on this point, ruling that the 340B statute does not prohibit such restrictions. In response, several states have enacted laws to protect access to 340B discounts via contract pharmacies, effectively requiring manufacturers to honor unlimited arrangements. Hawaii joined this trend on May 30, 2025, when Governor Josh Green signed Act 143 (also known as Senate Bill 3202) into law, with an effective date of July 1, 2025. The AstraZeneca complaint cites the Third Circuit's decision in Sanofi Aventis U.S. LLC v. HHS (58 F.4th 696, 706 (3d Cir. 2023)), which held that restrictions on contract pharmacy discounts "do[es] not violate Section 340B" and enjoined HHS from enforcing a contrary interpretation. Similarly, the D.C. Circuit in Novartis Pharms. Corp. v. Johnson (102 F.4th 452, 459 (D.C. Cir. 2024)) rejected the idea that Section 340B prohibits manufacturers from imposing "any conditions" on discounts involving contract pharmacies. AstraZeneca notes that Hawaii submitted amicus briefs in both cases supporting unlimited access, but the courts ruled against that position. Should this case be favorable to drug makers, and be successfully affirmed by the 9th Circuit Court of Appeals, it will become binding on California unless the U.S. Supreme Court hears the case. It is therefore a case of interest to those states who are included in 9th Circuit jurisdiction ...

Yvette Fortier Bline a former correctional deputy at the Tehama County Sheriff's Office in California, filed a federal civil rights lawsuit in the U.S. District Court for the Eastern District of California against the County and Tehama County District Attorney Matthew D. Rogers, Tehama County Sheriff Dave Kain, Tehama County Under Sheriff Jeff Garrett and District Attorney's Office investigator, Defendant Eric Clay, The lawsuit alleges she accepted a position in the Tehama County Sherriffs Office in September 2008. After approximately two years of employment, she became a Correctional Deputy. Bline successfully completed required training, including P.O.S.T. Certification, to serve as a Correctional Officer at the Tehama County Jail. In February 2017, during a 12-hour training that was fairly physically intense, Bline injured her right shoulder and neck region. Bline developed numbness and tingling in both hands following her injuries, and claimed to have developed a torn meniscus as a result to the training. She filed a workers compensation claim and was provided benefits and medical treatment. Bline was approved for neck surgery for the injuries she sustained from the previous training incident. The spinal injuries were later included in a cumulative Workers' Compensation claim in January 7, 2023 following her spine fusion. Joseph Ambrose, D.C., performed a Qualified Medical Evaluation on July 7, 2022. He diagnosed lumbar disc protrusion with bilateral radiculopathy; lumbar myoligamentous sprain/strain; patellofemoral syndrome, bilateral; sacroiliac sprain/strain, chondromalacia patella; and meniscus tears in both knees. He attributed this to the continuous trauma of 13 years of employment with the County. She continued to receive medical care following his report. And disputes arose between the parties over authorization for some of the recommended care. The complaint alleges that Bline's "medical costs had risen to approximately a half a million dollars by the summer of 2023 for her cumulative trauma sustained during her 13 years employment working with Tehama County. Because Plaintiffs medical costs and benefits, and the costs incurred due to Plaintiffs on the job injuries at Tehama County were expensive and as of January 23, 2023, and were escalating, Defendants' allegedly decided to form a scheme to falsely accuse Plaintiff of Insurance Fraud to retaliate against her for exercising her statutory right to seek redress through the California Workers' Compensation benefits system by procuring unlawful search warrants to gather evidence to try to convince a trier of fact that Plaintiff performed actions that, in their opinion, were evidence of malingering." She was ultimately charged with two counts of insurance fraud under California Penal Code Section 550(a). She claims her reputation in the community was damaged by press releases such as an article published by the Tri-County News which was based on the press release from the District Attorney's Office. The first sentence stated: "A Tehama County Sheriffs correctional deputy is being accused of workers' compensation fraud in excess of $500,000." Another press release was published by the Red Bluff Daily News on August 30, 2023, the day Bline was arrested. After Bline was arrested, she alleges she was placed on an ankle monitor during the pendency of charges, subjected to warrantless searches of her home and property, restricted in her travel, and deprived of her county salary, employment benefits, and liberty. The prosecution was eventually terminated in her favor. After a preliminary hearing involving several prosecution witnesses Judge Laura Woods told the prosecutor: "So, Ms. Frost you have completely failed to even remotely meet your burden. As we know, a burden of proof at a preliminary hearing is incredibly low. And you haven't even met that." The court then informed the prosecutor that: "Quite frankly, I think you can tell that I'm a little irritated and annoyed and angry that I have spent all these hours, that she has been charged with a felony, that she spent the night in jail based on these charges. It's absolutely unconscionable to me." The judge continued to express her dismay: "I've been doing this for a long time. I was a prosecutor, and I was a defense attorney, and I've never seen a case like this. I cannot believe this. You should be embarrassed. The S.O. should be embarrassed. And I say that having known all these guys for 25 years This is absolutely unacceptable. And I just can't believe it. I'm probably making inappropriate comments, but this is outrageous to me. And quite frankly, I'm angry that I had to sit here and listen to this. And I didn't even spend the night in jail. And I didn't have to hire a defense attorney." "So, I think you guys need to go back to your office and really rethink what is happening. This is ridiculous. I have known Eric Clay for a long time. I don't have any problem telling him this is unbelievable. So-I would tell Under Sheriff Garrett that, and I would tell Sheriff Kain that as well." Bline's federal lawsuit makes claims under 42 U.S.C. § 1983 for conspiracy to violate her civil rights, specifically breaches of her First Amendment rights (retaliation for protected activity), Fourth Amendment rights (unlawful seizure and searches), and Fourteenth Amendment rights (due process violations through fabricated evidence and malicious prosecution) ...

At two years after diagnosis of COVID-19, employees who experience long COVID symptoms have substantially reduced work productivity, reports a study in the August issue of the Journal of Occupational and Environmental Medicine. Led by Hiten Naik, MD, SM, of The University of British Columbia and the Post-COVID-19 Interdisciplinary Clinical Care Network, Vancouver, the online survey study included 908 employed patients diagnosed with COVID-19 between March 2020 and May 2021. Of these, 165 patients were classified as having long COVID, defined as continued symptoms three months after an initial positive COVID-19 test. Work productivity loss and work performance impairment were assessed using validated questionnaires. About 75% of participants with ongoing long COVID symptoms reported any productivity loss within the last three months, compared to 47% of those without long COVID. After adjustment for other characteristics, employees in the long COVID group were about three times more likely to report lost productivity. Average paid productivity loss over three months was about 62 hours, including 33 hours of absenteeism and 29 hours of presenteeism (decreased productivity at work). Long COVID was also associated with high unpaid productivity loss, including activities such as caregiving and household chores: about 37 hours, on average. About 73% of participants with long COVID reported impaired work performance within the past week, compared to 39% of those without long COVID symptoms. On adjusted analysis, employees with long COVID were four times more likely to have work performance impairment. Based on average hourly wage, the economic impact of total productivity loss was estimated at nearly $14,000 CAD over a year. Long COVID has been described as a "global public health crisis," affecting over 400 million people worldwide. Although studies have shown that long COVID can impair health and occupational functioning, the overall impact on work productivity loss has been unclear. Long COVID is "associated with substantial productivity loss, even two years after the onset of SARS-CoV-2 infection and even in individuals who have returned to work," Dr. Naik and coauthors conclude. "Clinicians, health systems, and employers should understand that long COVID can have long-lasting impacts on occupational functioning and requires long-term support." ...

On March 6, 2025, Walgreens announced that it agreed to be acquired by private equity firm, Sycamore. The proposed transaction, which involves over 450 California Walgreens stores. Howevever a settlement was reached under Assembly Bill 853 (AB 853), which requires notice and review by the Attorney General of transactions involving retail pharmacies and grocery stores in order to assess impact on access and labor. AB 853 was authored by former Assemblymember Brian Maienschein (D-San Diego) and went into effect on October 8, 2023. The settlement is subject to court approval. Walgreens is the last nationwide and statewide independent pharmacy chain - that is, a chain not owned by one of the Big Three Pharmacy Benefit Managers (PBMs), which are CVS Caremark, Optum Rx, and Express Scripts. The proposed transaction between Walgreens and Sycamore includes, but is not limited to, the following Walgreens stores in California: six in Bakersfield, 11 in Fresno, five in Huntington Beach, 13 in Los Angeles, eight in Modesto, five in Riverside, seven in Sacramento, seven in San Diego, 26 in San Francisco, 10 in San Jose, and seven in Stockton. The California Attorney General announced a settlement with Walgreens Co. and its succeeding owner, Sycamore Partners Management, L.P. (Sycamore), that would operate as an injunction and protect competition, patients, and pharmacy-related workers. Under the settlement, Walgreens and Sycamore agree to the following conditions for the next seven years: - - Use best efforts to maintain all California Walgreens stores remaining as of the date of the agreement, as well as all required licenses. - - Provide 90-day notice of sale or closure of any remaining Walgreens stores. - - Prohibition from reselling any of the Walgreens stores in California to any of the Big Three PBMs. - - Prohibition from using any dividend recapitalization or other distribution of profits where such a dividend recapitalization or other distribution of profits would reasonably be likely to materially impair the operations of Walgreens. - - Use best efforts to continue participation in Medi-Cal and Medicare. - - Use best efforts to provide financial assistance to patients. - - Ensure best efforts regarding compliance with state staffing levels. - - Maintain a hiring list for all employees from stores that close going forward for preferential hiring at other Walgreens stores. - - Use commercially reasonable efforts to pay retirement contributions if collective bargaining agreements require such payments. - - Use commercially reasonable efforts to abstain from contesting unemployment for individuals who are laid off as a result of the sale or closure of Walgreens stores if no nearby Walgreens store offers employment. - - Use commercially reasonable efforts to bargain with any unions in good faith. - - Comply with nondiscrimination rules in the provision of healthcare services. This settlement is the second reached by the California Attorney General under AB 853. The first settlement was with Rite Aid and was announced on August 19, 2024. In addition, on April 14, 2025, the California Attorney General joined a bipartisan coalition of 39 attorneys general in urging the leaders of the U.S. House of Representatives and U.S. Senate to enact a law that prohibits PBMs, their parent companies, or affiliates from owning or operating pharmacies. Created in the late 1960s to process claims for drug companies, PBMs were supposed to help consumers access low-cost pharmaceutical care through negotiated volume-pricing discounts, generic substitution, manufacturer rebates, and other tools. However, PBMs have overtaken the market and now wield outsized power to reap massive profits at the expense of consumers and local community pharmacies ...

Well-known Fresno restaurant owner Robert “Bobby” Salazar, 63, has been arrested on a federal complaint for arson of commercial property and arson in furtherance of a felony for directing a motorcycle gang member to set fire to an underperforming restaurant property, U.S. Attorney Eric Grant announced. Salazar pleaded not guilty Thursday during a federal court appearance. Prosecutors also filed additional charges after investigators discovered five firearms at his home, including four with serial numbers removed and one ghost gun. According to court documents, on April 2, 2024, a fire broke out at the vacant Bobby Salazar’s restaurant on Blackstone Avenue in Fresno. Fire investigators determined that the cause of the fire was arson, with partially burned gas cans located inside the restaurant and extensive fire damage to the interior: According to court documents, agents learned that the person who set the fire was the president of the local Screamin’ Demons Motorcycle Club. Salazar allegedly hired the motorcycle gang member to start the fire and then claimed to his insurance company that he had nothing to do with the arson. He was ultimately paid out at least $980,739 for his insurance claim. If convicted, Salazar faces a mandatory minimum of five years in prison and maximum statutory penalty of 20 years in prison for commercial arson, as well as 10 years in prison mandatorily consecutive for arson in furtherance of a felony. Any sentence, however, would be determined at the discretion of the court after consideration of any applicable statutory factors and the Federal Sentencing Guidelines, which take into account a number of variables. The charges are only allegations; the defendant is presumed innocent until and unless proven guilty beyond a reasonable doubt. This case is the product of an investigation by the Bureau of Alcohol, Tobacco, Firearms and Explosives and the Fresno Fire Department, with assistance from the Fresno Police Department, the Fresno County Sheriff’s Department, and the Federal Bureau of Investigation. Assistant U.S. Attorneys Robert L. Veneman-Hughes and Brittany M. Gunter are prosecuting the case ...

A Burbank man has pleaded guilty to evading the payment of more than $11.2 million in federal taxes by using a shill to illegally collect Medicare reimbursement payments made to his blood-testing company, and to fraudulently obtaining nearly $100,000 in taxpayer-funded COVID-19 business relief, the Justice Department announced today. Armen Muradyan, 60, pleaded guilty to one count of conspiracy to commit health care fraud, one count of wire fraud, and one count of tax evasion. According to his plea agreement, Muradyan owned and operated a Burbank-based blood testing laboratory called Genex Laboratories Inc. Medicare and bank records show that Medicare paid millions of dollars in reimbursements to Genex for blood testing. The reimbursements were wired to bank accounts in the name of an individual identified in court documents as “L.S.” – Muradyan’s long-time friend to whom Muradyan had offered to pay $2,000 per month to pretend to be Genex’s owner. Muradyan told L.S. that he needed him to submit Medicare enrollment papers to Medicare on Genex’s behalf because Medicare had banned Muradyan from submitting claims. L.S. and Muradyan opened bank accounts for Genex in L.S.’s name, but which Muradyan controlled. L.S. neither owned nor operated Genex and visited the company’s Burbank office to collect his $2,000 monthly payment and to sometimes sign documents at Muradyan’s direction. Muradyan used the proceeds from the health care fraud conspiracy to pay the mortgage on a property he owned. For the tax years of 2015 through 2020, Muradyan instructed L.S. to report Genex’s financial activity on L.S.’s personal income tax returns using documents that L.S. provided to his own tax preparer. The documents purportedly showed that Genex had minimal net profit or was operating at a loss, meaning the company had little or no income tax liability. For the same period, Muradyan submitted income tax returns that reported none of Genex’s financial activity as his own and that he averaged an income of $40,000 per year. In fact, Muradyan personally received and used millions of dollars in Medicare reimbursements to support his own expensive lifestyle. Muradyan also did not file tax returns for the years 2021 through 2023. In total, Muradyan’s unreported federal taxable income was approximately $23,915,762, resulting in a total federal income tax due and owing by him of approximately $11,236,357. In July 2020, Muradyan wired a false and fraudulent application for an Economic Injury Disaster Loan (EIDL) that was funded by federal taxpayers. On the application, Muradyan falsely stated that GenMed employed multiple people and generated $800,000 in income for the year 2019. In fact, Muradyan knew GenMed employed no one and generated zero income for that year. The U.S. Small Business Administration (SBA) wired $99,900 to a bank account Muradyan controlled. He then used the money for personal expenses not permitted under the terms of the EIDL. Muradyan admitted he acted with the intent to deceive and cheat the SBA. United States District Judge John A. Kronstadt scheduled a December 11 sentencing hearing, at which time Muradyan will face a statutory maximum sentence of 20 years in federal prison for the wire fraud count, up to 10 years in federal prison for the health care fraud conspiracy count, and up to five years in federal prison for the tax evasion count. Muradyan remains free on $2.6 million bond. IRS Criminal Investigation, the FBI, and the United States Department of Health and Human Services Office of Inspector General investigated this matter. Assistant United States Attorney Mark Aveis of the Major Frauds Section and Trial Attorney Mahana K. Weidler of the Department of Justice’s Tax Division are prosecuting this case. Anyone with information about allegations of attempted fraud involving COVID-19 can report it by calling the Department of Justice’s National Center for Disaster Fraud Hotline at (866) 720-5721 or via the NCDF Web Complaint Form at: https://www.justice.gov/disaster-fraud/ncdf-disaster-complaint-form ...