Jefferson v. California Department of Youth Authority

In Jefferson v. California Department of Youth Authority (2002), the plaintiff stopped working and filed a workers' compensation claim. Seven months later, she filed an administrative claim for sex discrimination under the FEHA. She settled the workers compensation claim using the mandatory compromise and release form required by the workers' compensation appeals board. The form provided that the plaintiff " 'releases and forever discharges the employer from all claims and causes of action, whether now known or ascertained, or which may hereafter arise or develop as a result of the claimed injury.' " (Id. at p. 7462.) She then filed a civil action under the FEHA. The court held that the broad language in the release form applied to release the claims encompassed in the civil action. It specifically held as follows: "Accordingly, we hold that when, as in this case, an employee has knowledge of a potential claim against the employer at the time of executing a general release in a workers' compensation proceeding, but has not yet initiated litigation of that claim, the employee has the burden of expressly excepting the claim from the release. Absent this exception, and absent contrary extrinsic evidence, a court will enforce general language, such as is found in the compromise and release and attachment in the present case, releasing all claims including civil claims." (Id. at p. 7464.)