Saavedra v. Orange County Transportation etc. Agency

In Saavedra v. Orange County Transportation etc. Agency (1992) 11 Cal. App. 4th 824, plaintiff filed an administrative complaint which charged her employer with discrimination and named an individual in the body of the complaint. This court agreed with Martin that the individual defendant, having been named in the body of the administrative complaint, received proper notice. (Saavedra, supra, 11 Cal. App. 4th at p. 827.) By way of dictum, the opinion expressed agreement with the dissent in Valdez v. City of Los Angeles (1991), stating that, because of the same purported ambiguities in the administrative complaint form upon which Justice Johnson relied, individuals may be sued whether or not they are named in that complaint. (Id. at pp. 827-828.)