Calif. 1st: Prima Facie Case of Retaliation Made

Showing that an adverse employment action followed protected conduct closely in time and that the employer was aware of it is sufficient for showing a prima facie case of retaliation, the California First District Court of Appeal ruled in an unpublished opinion. The ruling in Sandra Sealock v. Costco Wholesale Corp., A110863 (Alameda County Superior Court No. VG03082806) 7/31/096, involved Sealock's wrongful-termination case against her employer, Costco. Sealock began working for defendant in 1989. She was diagnosed by Dr. James Boccio with plantar fascitis in both feet, and had surger...