California Civil Code Section 3333
In Commodore Home Systems, Inc. v. Superior Court (1982) 32 Cal. 3d 211, 221 185 Cal. Rptr. 270, 649 P.2d 912, the California Supreme Court held that ". . . in a civil action under the Fair Employment and Housing Act (FEHA), all relief generally available in noncontractual actions, including punitive damages, may be obtained."
Civil Code section 3333 sets out the available relief:
"For the breach of an obligation not arising from contract, the measure of damages, except where otherwise expressly provided by this code, is the amount which will compensate for all the detriment proximately caused thereby, whether it could have been anticipated or not."
California courts are authorized to award to a victim of employment discrimination all damages necessary to make the victim whole. Blind obedience to the limitation on postresignation damages developed in the federal courts does not serve that purpose.