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California Workplace Harassment Demand Letter

I draft demand letters for employees who have experienced harassment creating a hostile work environment. California's FEHA provides strong protections with strict liability for supervisor harassment.

Gov Code 12940(j)
FEHA Harassment
3 Years
CRD Filing Deadline
No Cap
Private Employer Damages
Strict Liability
Supervisor Harassment

📋 Overview: California Workplace Harassment

Workplace harassment occurs when unwelcome conduct based on a protected characteristic is so severe or pervasive that it creates a hostile, intimidating, or offensive work environment. Unlike discrimination (which focuses on adverse employment actions), harassment focuses on the abusive conduct itself.

Who This Guide Serves

I draft these demand letters for two distinct audiences:

For Employees (Senders)

You experienced harassment at work - sexual harassment, racial harassment, or other harassment based on a protected characteristic that made your workplace hostile or abusive.

For Employers (Recipients)

You received a harassment demand letter and need to understand your liability exposure, especially the difference between supervisor and coworker harassment.

Types of Workplace Harassment

Sexual Harassment

Unwelcome sexual advances, requests for sexual favors, sexually explicit comments or images, or physical conduct of a sexual nature

Quid Pro Quo

Job benefits (hiring, promotion, assignments) conditioned on submission to sexual demands or other unwelcome conduct

Hostile Work Environment

Severe or pervasive conduct based on protected characteristic that alters working conditions and creates abusive environment

Racial/Ethnic Harassment

Racial slurs, offensive jokes, stereotyping, display of racist symbols or materials

Age-Based Harassment

Repeated derogatory comments about age, "dinosaur" references, pressure to retire

Disability Harassment

Mockery of disability, offensive comments about medical conditions, interference with accommodations

Critical: Harassment vs. Discrimination

Harassment and discrimination are separate claims under FEHA. Discrimination requires an adverse employment action (termination, demotion). Harassment focuses on abusive conduct creating a hostile environment - no adverse action is required. I often assert both claims when facts support them.

The "Severe or Pervasive" Standard

To be actionable, harassment must be either:

Severe

A single incident of extreme conduct (physical assault, explicit threat, egregious slur) can be enough

Pervasive

A pattern of recurring conduct that, while individually less serious, collectively creates hostile environment

What You Can Recover

  • Back pay - Lost wages if harassment led to job loss or resignation
  • Front pay - Future lost earnings if reinstatement isn't feasible
  • Emotional distress - Often substantial in harassment cases
  • Punitive damages - To punish malicious or reckless conduct
  • Attorney fees - Recoverable if you prevail
  • Medical expenses - Therapy, counseling, treatment costs

Supervisor vs. Coworker Liability

California applies different liability standards depending on who committed the harassment. This distinction is crucial for both employees and employers.

STRICT LIABILITY

Supervisor Harassment

Under FEHA, employers are strictly liable for harassment by supervisors. This means:

  • Employer is automatically liable - no defense
  • Does not matter if employer knew about harassment
  • Does not matter if employer took corrective action
  • Supervisor's conduct is imputed directly to employer

If a supervisor harassed you, employer liability is automatic.

NEGLIGENCE STANDARD

Coworker Harassment

For harassment by coworkers (non-supervisors), employer liability requires showing:

  • Employer knew or should have known about harassment
  • Employer failed to take immediate corrective action
  • Failure to take reasonable steps to prevent

I build coworker harassment cases by documenting employer knowledge and inadequate response.

Who is a "Supervisor"?

Under California law (following Vance v. Ball State University federal standard adopted by FEHA), a supervisor is someone with authority to:

  • Hire, fire, demote, promote, or transfer the employee
  • Take tangible employment actions
  • Direct daily work activities (broader under California law)

California interprets "supervisor" more broadly than federal law. I analyze the harasser's actual authority over your employment.

💼 For Employers: Responding to Harassment Claims

If you've received a harassment demand letter, your liability exposure depends heavily on whether the alleged harasser was a supervisor. Quick, strategic action is essential.

Strict Liability Means No Defense

If the harasser was a supervisor, you are strictly liable. Period. There is no "Faragher-Ellerth" affirmative defense under California FEHA (unlike federal law). Your only options are (1) dispute that harassment occurred, (2) dispute the harasser was a supervisor, or (3) negotiate damages.

Immediate Steps for Employers

  1. Determine harasser's status - Was this person a supervisor under FEHA's broad definition?
  2. Preserve all evidence - Issue litigation hold immediately
  3. Review complaint history - Did employee report the harassment? When? How did you respond?
  4. Assess prior knowledge - Did anyone in management know or have reason to know?
  5. Evaluate your response - Did you investigate promptly? What corrective action was taken?
  6. Calculate exposure - Emotional distress damages in harassment cases are often substantial

For Coworker Harassment - Building Your Defense

Prompt Investigation

Document that you investigated immediately upon learning of the complaint

Appropriate Action

Show corrective action was proportional to the conduct (discipline, separation, training)

Prevention Efforts

Document anti-harassment policies, training, and complaint procedures

No Retaliation

Ensure complainant suffered no adverse treatment after reporting

📝 Elements of a FEHA Harassment Claim

To establish a harassment claim under FEHA, I prove each of these elements:

Prima Facie Elements

  1. Protected Characteristic - Harassment was based on race, sex, age, disability, religion, or other FEHA-protected class
  2. Unwelcome Conduct - The conduct was unwanted and offensive to the employee
  3. Severe or Pervasive - Conduct was either extremely severe (one bad incident) or recurring and pervasive
  4. Hostile Environment - Conduct altered working conditions and created abusive environment
  5. Employer Liability - Employer is liable based on harasser's status (strict for supervisors, negligence for coworkers)

The Totality of Circumstances Test

Courts evaluate whether harassment was "severe or pervasive" by examining:

Frequency

How often did the conduct occur? Daily harassment vs. isolated incidents

Severity

How serious was each incident? Physical touching vs. offensive comments

Physical vs. Verbal

Physical threats or touching are more serious than purely verbal harassment

Humiliating

Was the conduct publicly humiliating? Harassment in front of others is more severe

Work Interference

Did harassment unreasonably interfere with work performance?

Psychological Harm

What was the effect on the employee's mental health?

Examples of Severe vs. Pervasive

Severe (Single Incident Enough) Pervasive (Pattern Required)
Sexual assault or attempted assault Daily offensive jokes about protected characteristic
Explicit threat of violence Recurring display of offensive images
Use of extremely offensive slurs Persistent unwelcome romantic overtures
Quid pro quo demand (job for sex) Regular exclusion from meetings based on gender/race
Public physical humiliation Continuous derogatory nicknames or comments

Objective AND Subjective Test

California requires proving both:

  • Subjective: YOU actually found the environment hostile/abusive
  • Objective: A reasonable person in your position would find it hostile/abusive

The "reasonable person" is judged from the perspective of someone in the plaintiff's protected class (e.g., "reasonable woman" in sexual harassment cases).

💰 Damages and Penalties

Harassment cases often result in substantial damages, particularly for emotional distress. California has no cap on damages against private employers.

Damage Type Description Typical Range
Emotional Distress Mental anguish, humiliation, anxiety, depression, PTSD symptoms $50,000 - $1,000,000+
Back Pay Lost wages if harassment led to constructive discharge or resignation $20,000 - $300,000+
Front Pay Future lost earnings when reinstatement isn't feasible 1-5 years wages
Medical Expenses Therapy, counseling, medication, treatment costs $5,000 - $50,000+
Punitive Damages To punish malicious, oppressive, or fraudulent conduct Often 1-5x compensatory
Attorney Fees Prevailing plaintiff recovers reasonable fees $50,000 - $500,000+

📊 Sample Damages Calculation

Example: Severe Sexual Harassment by Supervisor - Constructive Discharge

Back pay (18 months at $75,000/year) $112,500
Lost benefits value $22,500
Front pay (2 years - difficulty finding comparable work) $150,000
Emotional distress (severe - therapy ongoing) $250,000
Medical/therapy expenses $25,000
Punitive damages (2x compensatory) $1,120,000
Attorney fees (estimate) $150,000
POTENTIAL TOTAL RECOVERY $1,830,000

My Fee Structure

I draft harassment demand letters at $240/hour or $450 flat fee for standard cases. This includes the demand letter, one round of revisions, and brief strategic consultation. Cases involving extensive documentation or multiple harassers may require additional time.

Emotional Distress is Often the Largest Component

In harassment cases, emotional distress damages often exceed lost wages. California juries have awarded six and seven-figure emotional distress damages in egregious cases. Document your psychological impact thoroughly: therapy records, medication, sleep problems, relationship impacts, daily functioning.

📂 Evidence Checklist

Gather these documents and evidence before sending your demand letter. Strong documentation dramatically increases settlement value in harassment cases.

📄 Employment Documents

  • Offer letter, employment contract, job description
  • Employee handbook and anti-harassment policy
  • Performance reviews showing competent performance
  • Organizational chart showing harasser's position

📩 Harassment Documentation

  • Written log of each incident (date, time, location, witnesses, exact words/conduct)
  • Emails, texts, voicemails from harasser
  • Photos of offensive materials, workspace decorations
  • Names and contact info for witnesses

📣 Complaints and Reports

  • Written HR complaints and employer responses
  • Investigation reports and findings
  • Evidence of what corrective action was (or wasn't) taken
  • CRD/DFEH or EEOC complaint (if filed)

💊 Damages Evidence

  • Therapy/counseling records and invoices
  • Prescriptions for anxiety, depression, sleep medication
  • Personal journal documenting emotional impact
  • Statements from family/friends about changes in behavior

Preserve Evidence Immediately

Forward work emails to personal email before losing access. Screenshot text messages. Keep originals of everything in a safe location outside work. If you believe employer may destroy evidence, consider sending a litigation hold letter immediately.

Contemporaneous Documentation is Gold

The best evidence is what you documented at the time it happened. Emails you sent to yourself, text messages to friends, or journal entries dated near the incidents are far more powerful than reconstructed timelines. Start documenting NOW if you haven't already.

📝 Sample Language

Copy and customize these paragraphs for your harassment demand letter.

Opening Paragraph
I am writing to formally demand compensation for the unlawful workplace harassment I endured while employed at [COMPANY NAME]. The conduct described herein violates California's Fair Employment and Housing Act, Government Code Section 12940(j), and has caused me significant emotional and financial harm.
Harassment Description - Sexual Harassment
From [START DATE] to [END DATE], I was subjected to severe and pervasive sexual harassment by [HARASSER NAME], who served as [HARASSER'S TITLE - MY DIRECT SUPERVISOR/MANAGER/etc.]. This harassment included [SPECIFIC DESCRIPTION: unwanted sexual comments about my body; repeated requests for dates after I declined; display of sexually explicit images; unwelcome physical touching]. This conduct created a hostile work environment that was both objectively and subjectively offensive and made it impossible for me to perform my job effectively.
Harassment Description - Hostile Environment
Throughout my employment, I was subjected to a hostile work environment based on my [PROTECTED CHARACTERISTIC]. [HARASSER NAME] regularly made offensive comments including [SPECIFIC QUOTES]. This conduct occurred [FREQUENCY - daily/weekly/etc.] and was witnessed by [WITNESS NAMES IF AVAILABLE]. The harassment was so severe and pervasive that it altered the conditions of my employment and created an abusive working environment.
Employer Knowledge and Failure to Act
I reported this harassment to [HR/MANAGER NAME] on [DATE(S)]. Despite my complaints, [COMPANY NAME] failed to take immediate and appropriate corrective action as required by Government Code Section 12940(k). [DESCRIBE WHAT HAPPENED: The harassment continued unchanged / My complaint was ignored / The "investigation" was a sham / I was retaliated against for complaining]. This failure to prevent and correct harassment makes [COMPANY NAME] directly liable for my damages.
Strict Liability for Supervisor Harassment
Because [HARASSER NAME] was my supervisor with authority over my employment conditions, [COMPANY NAME] is strictly liable for this harassment under Government Code Section 12940(j)(3). Under California law, employers are automatically liable for harassment by supervisors regardless of whether the employer knew about the conduct or took corrective action. There is no affirmative defense available.
Demand and Deadline
I hereby demand that [COMPANY NAME] pay me the sum of $[DEMAND AMOUNT] to compensate me for the harm I have suffered, including emotional distress, lost wages, medical expenses, and other damages. This amount represents a good-faith effort to resolve this matter without formal litigation. If I do not receive full payment within [30 DAYS], I will file a complaint with the Civil Rights Department and pursue all available legal remedies, including punitive damages and attorney fees.

🚀 Next Steps

After sending your demand letter, follow this process.

Expected Timeline

Days 1-7

Employer receives and forwards to legal counsel for review

Days 7-21

Internal investigation, exposure assessment, response preparation

Days 21-30

Response with settlement offer, counteroffer, or denial

CRD Filing Process

  1. File Complaint with CRD

    File online at calcivilrights.ca.gov within 3 years of the last harassing act. You can request an immediate Right to Sue letter or allow CRD to investigate.

  2. Receive Right to Sue Letter

    If you request immediate Right to Sue, CRD issues it promptly. This satisfies the administrative prerequisite for filing suit.

  3. File Lawsuit Within 1 Year

    You must file your civil lawsuit in Superior Court within 1 year of receiving the Right to Sue letter.

Critical: 3-Year Filing Deadline

You must file with CRD within 3 years of the last harassing act. For continuing harassment, the deadline runs from the most recent incident. Do not miss this deadline - it is an absolute bar to your FEHA claim.

If Settlement Fails

  1. Consult an Employment Attorney

    Many employment attorneys handle harassment cases on contingency. FEHA fee-shifting makes these cases attractive. Look for attorneys with harassment trial experience.

  2. File CRD Complaint

    If not already filed, file immediately to preserve rights and obtain Right to Sue letter.

  3. Consider Mediation

    Many harassment cases settle during early mediation. CRD offers free mediation services.

  4. Litigation

    If necessary, file in Superior Court. Discovery often reveals additional evidence supporting your claims.

Ready to Move Forward?

I draft professional harassment demand letters that maximize settlement value. Get started with a consultation to evaluate your case.

California Resources

  • Civil Rights Department (CRD): calcivilrights.ca.gov - File complaints, free mediation
  • CRD Hotline: 1-800-884-1684 (voice) / 1-800-700-2320 (TTY)
  • EEOC: eeoc.gov - Federal dual-filing option
  • State Bar Lawyer Referral: calbar.ca.gov
  • Legal Aid at Work: legalaidatwork.org - Consultations