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1 investigation, hearing, or inquiry, if the employee has reasonable cause to believe that
<br /> 2 the information discloses a violation of state or federal statute, or a violation of or
<br /> 3 noncompliance with a local, state, or federal rule or regulation, regardless of whether
<br /> 4 disclosing the information is part of the employee's job duties.
<br /> 5 160. Sections 1101 and 1102 protect "the fundamental right of employees in
<br /> 6 general to engage in political activity without interference by employers." (Gay Law
<br /> 7 Students Assn., 24 Cal.3d at 487 (quoting Fort v. Civil Service Commission (1964) 61
<br /> 8 Cal.2d 331, 335).)
<br /> 9 161. As shown by the facts pled above, Defendants, and each of them, have
<br /> 10 engaged in acts and/or omissions that violated Labor Code §§1101 and/or 1102 to the
<br /> 11 detriment of Plaintiff Serrano, Plaintiff SAPOA, and those members of the SAPOA that
<br /> 12 support the SAPOA's actions.
<br /> 13 162. Defendants, and each of them, have engaged in retaliation against both
<br /> 14 Plaintiffs for disclosing information, or because the employer believed that the
<br /> 15 employee disclosed or may disclose information, to a government or law enforcement
<br /> 16 agency, to a person with authority over the employee or another employee who has the
<br /> 17 authority to investigate, discover, or correct the violation or noncompliance, or for
<br /> 18 providing information to, or testifying before, any public body conducting an
<br /> 19 investigation, hearing, or inquiry, wherein the employee had reasonable cause to
<br /> 20 believe that the information disclosed a violation of state or federal statute, or a violation
<br /> 21 of or noncompliance with a local, state, or federal rule or regulation.
<br /> 22 163. As a proximate result of Defendants willful, knowing and intentional
<br /> 23 violations of the Labor Code sections referenced above, Plaintiff Serrano has suffered
<br /> 24 and continues to suffer substantial losses in earnings and/or other employment
<br /> 25 benefits. As a legal result of the conduct of Defendants, and each of them, Plaintiff has
<br /> 26 suffered and will continue to suffer distress, suffering, anguish, fright, nervousness,
<br /> 27 grief, anxiety, worry, shame, mortification, injured feelings, shock, humiliation and
<br /> 28 indignity, as well as other unpleasant reactions, damages to reputation, and other non-
<br /> 36
<br /> COMPLAINT
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