Hoglund v. Sierra Nev. Memorial-Miners Hosp., 102 Cal. App. 5th 56 (2024)

Following a bench trial, the trial court found in favor of Jessica Hoglund, a former laboratory supervisor who supervised all of the phlebotomists at the Hospital. Hoglund, age 56, alleged her former supervisor, Rhonda Horne who was six years younger than Hoglund, had harassed and discriminated against her because of her age. The trial court awarded Hoglund $881,800 in economic damages (lost wages) and $550,000 in noneconomic, emotional distress damages. The trial court also awarded Hoglund more than $1 million in prevailing-party attorney’s fees and costs. The Court of Appeal affirmed, holding that the continuing violation doctrine applied and, therefore, the statute of limitations did not bar Hoglund’s claims even though the alleged unlawful conduct began in 2011 and Hoglund did not file her administrative complaint until 2018. The Court also rejected the Hospital’s contention that the verdict was not supported by substantial evidence, citing “copious evidence of Horne’s age discrimination” against Hoglund.