Unreported / Non-Citable
Background
Princess Obienu sued her former employer, the County of Los Angeles Department of Health Services, in September 2019. The superior court's November 2022 judgment on the pleadings eliminated four causes of action without leave to amend, including discrimination and retaliation claims, while permitting amendment of five others. The court found the promotion and suspension allegations untimely and the termination claim barred after Obienu pursued a Civil Service Commission remedy, received an adverse determination, and did not seek writ review.
Five claims ultimately reached the jury: failure to accommodate, failure to engage in the interactive process, and three California Family Rights Act claims for violation, interference, and retaliation. Obienu alleged that the County should have provided a flexible schedule, intermittent leave, or reassignment and should have engaged in a good-faith interactive process. After an earlier mistrial caused by her counsel's health, the retrial began in July 2024.
The special verdict resolved every tried claim against Obienu. Although the jury found that she could perform essential duties with accommodation and was eligible for and had requested medical leave, it found no failure to accommodate, unwillingness on her part to participate in the interactive process, that she did not provide reasonable notice of her need for leave, and no substantial motivating connection between her leave request and an adverse employment action. Judgment was entered September 3, 2024, and her new trial motion was denied on December 3, 2024.
The Court’s Holding
The Court of Appeal affirmed. It emphasized that an appellant must provide reasoned argument, supporting authority, record citations, and an affirmative showing of error, rules that also govern self-represented litigants. Obienu's briefing often failed to identify the particular ruling challenged or connect it to an adverse special-verdict finding. The court nevertheless addressed contentions it could reasonably discern. It also declined judicial notice of an October 2025 Labor Commissioner determination because the document postdated the judgment and was never before the trial court.
The court found no abuse of discretion in three scheduling decisions. Refusing a half-day adjournment for Obienu's conflicting unlawful-detainer appearance did not prevent identified testimony or examination; her counsel cross-examined a County witness, and she testified herself. Refusing to postpone closing argument was supported by the waiting jury, the earlier mistrial, concern about losing jurors, and counsel's impending federal-court commitment. Refusing a continuance for witness Nick Christofer was also proper because Obienu did not specify the evidence he would supply, declined to read his deposition to the jury, and did not explain how his testimony related to the verdict.
The evidentiary challenges failed because Obienu identified no particular exhibit, exclusion ruling, or offer of proof establishing the evidence's substance, purpose, and relevance. Nor did she show that the material would have changed the jury's findings. On instructions, the record contradicted her assertion that CACI No. 2542 had been refused: it was supplied in writing and read to the jury. Her reply-brief request for preferential-reassignment instruction was both untimely and unsupported by evidence of a vacant position for which she qualified. The court rejected the remaining jurisdictional, due-process, record-completeness, pleadings, counsel-withdrawal, and cumulative-error arguments, affirmed the judgment, and awarded the County its appellate costs.
Key Takeaways
- An appellant must connect each challenged trial ruling to the record and to a finding that affected the judgment rather than merely listing categories of alleged error.
- A party seeking reversal for excluded evidence generally must preserve the evidence's substance, purpose, and relevance through an offer of proof or another permitted method.
- A continuance request based on an unavailable witness must explain the expected material evidence and why alternatives, such as deposition testimony, are insufficient.
- A proposed preferential-reassignment instruction requires substantial supporting evidence, including evidence of a vacant position for which the employee was qualified.
- Even a demonstrated trial-management, evidentiary, or instructional error would not warrant reversal without a reasonably probable more favorable result.
Why It Matters
The decision illustrates how preservation, prejudice, and the special verdict can independently defeat an employment-law appeal. The court did not disturb the jury's factual findings; it concluded that Obienu had not shown how the challenged rulings could have changed them. Its analysis also distinguishes CACI No. 2542's definition of reasonable accommodation from the separate elements instructions for accommodation and interactive-process claims.
The opinion is designated not to be published in the official reports. Its practical account of continuances, reopened discovery after a mistrial, and the limits of reply-brief arguments explains the court's resolution of this appeal without announcing a new employment-law rule.