Oakland v. Workers' Comp. Appeals Bd

In Oakland v. Workers' Comp. Appeals Bd. (2002) 99 Cal.App.4th 261, plaintiff sought workers' compensation benefits for psychiatric injury caused by his employer's decision to demote him. The Labor Code specifically precludes such an award if the employer's decision was a "lawful, nondiscriminatory, good faith personnel action . . . ." ( Lab. Code, 3208.3, subd. (h).) The court simply adopted, without additional analysis, the hybrid "objective good faith" standard established by the Supreme Court in Cotran for determining whether an employer had "good cause" for taking disciplinary action against an employee. As we have already explained, that hybrid standard was derived because the court wished to bridge the gap between the purely subjective "good faith" standard and the purely factual requirement that the "cause" be proven as true. Indeed, the City of Oakland court specifically noted that in creating the "objective good faith" standard in Cotran, the Supreme Court had "'coupled "good faith" with "objectivity"'" ( City of Oakland v. Workers' Comp. Appeals Bd., supra, 99 Cal.App.4th at p. 266).