In Chen v. County of Orange (2002) 96 Cal.App.4th 926, the Court of Appeal reviewed the law regarding marital status discrimination and antinepotism policies in the workplace, and discussed three general categories of cases. The first category includes cases that unquestionably involve marital status discrimination, such as "a refusal to hire unwed mothers because they were unwed, a refusal to hire single people because they were single, or the granting of maternity leave to married teachers only. " (Id. at p. 940.) The second category involves cases "in the general area of antinepotism rules, i.e., what can (or should) an employer do when two coworkers are married to one another." (Chen v. County of Orange, supra, 96 Cal.App.4th at p. 940.) Chen noted a split of authority in that area among state courts, with some courts striking down antinepotism rules on the ground they penalize the status of being married and others upholding antinepotism rules on the ground statutory protection against marital status discrimination does not extend to the identity of one's spouse. (Id. at pp. 940-942.) Chen referred to the third category of cases as "conduit" cases in which "the plaintiff is the object of adverse action because of something about his or her spouse, independent of whether the spouse works for the same employer . . . . (Chen v. County of Orange, supra, 96 Cal.App.4th at p. 943.) Chen divided conduit cases into two categories: "those in which the animus directed against the plaintiff's spouse is itself unlawful, and those in which the animus is not unlawful." (Ibid .) An example of unlawful animus is where an employee suffers adverse employment action because his or her spouse is of a different race or is a member of some other protected class. (Ibid.) Chen noted that "conduit cases not based on some wrongful animus . . . have been universally met with rejection as valid marital status discrimination claims. Perhaps the best explanation for that is this: In such cases, the marriage qua marriage is irrelevant to the adverse action taken by the employer. What the employer really cares about is the substantive relationship between the plaintiff and someone else, be he or she spouse, romantic partner, or even 'just a friend.'" (Ibid.)