In Watson v. Department of Rehabilitation (1989) 212 Cal. App. 3d 1271, the plaintiff, a state civil service employee, sued the State Department of Rehabilitation alleging causes of action for race and age discrimination under FEHA, as well as common law causes of action for breach of the implied covenant of good faith and fair dealing and intentional infliction of emotional distress. ( Watson, 212 Cal. App. 3d at pp. 1277, 1278.) On the defendant's appeal from a jury verdict in the plaintiff's favor, the court of appeal, addressing the plaintiff's FEHA causes of action, held she did not need to seek civil service relief because she had complied with administrative exhaustion requirements by filing a charge with the Department of Fair Employment Practices (DFEP), obtaining a right to sue letter, and timely filing her suit. ( Id. at p. 1284.) As for the plaintiff's common law cause of action for breach of the covenant of good faith and fair dealing, however, the court of appeal held the trial court erred in failing to dismiss this cause of action due to the plaintiff's failure to exhaust state civil service administrative procedures: "Watson chose not to avail herself of the remedies available through the state civil service system; she chose instead to proceed first through the DFEP and DFEH, and then through the courts. While she may so proceed with respect to her statutory claims and causes of action, she may not avail herself of a remedy which provides damages for breach of the covenant of good faith and fair dealing." ( Id. at p. 1288.)