A former employee has accused a healthcare district of wrongful termination and privacy violations, leading to a legal battle that highlights the complexities of employment law in the context of public health policies. On August 21, 2024, Debra Linn Smith filed a complaint against Sonoma Valley Health Care District in the California Court of Appeal, First Appellate District, Division Three.
Debra Linn Smith's lawsuit stems from her refusal to disclose her COVID-19 vaccination status to her employer, Sonoma Valley Health Care District, where she worked as a surgery scheduling coordinator for over two decades. According to the court documents, in August 2021, Meghan Healy from the hospital’s human resources department requested Smith's vaccination information. When Smith declined to provide this information and refused to undergo mandatory COVID-19 testing required by hospital policy for unvaccinated employees, she was placed on unpaid leave and subsequently terminated on September 28, 2021. Smith alleges that this termination caused her significant financial hardship.
Smith's complaint includes two causes of action under the Confidentiality of Medical Information Act (CMIA) and one for fraud. She claims that the hospital discriminated against her based on her refusal to release medical information and terminated her due to her medical history and vaccination status. Furthermore, she accuses Healy and Lynn McKissock of making false representations about the legality of the hospital’s policies. Despite submitting a claim under the Government Claims Act on May 6, 2022, defendants argued that Smith failed to meet the six-month deadline for presenting such claims as required by Government Code section 911.2.
The trial court sustained a demurrer without leave to amend on two grounds: failure to present a claim within six months from the date of injury and failure to submit a written claim before filing the lawsuit. The court found all causes of action barred under Government Code sections 911.2 and 945.4 because Smith did not present her claim within six months following her termination date or submit it before initiating legal proceedings.
On appeal, Smith contended that her CMIA claims should be subject to a twelve-month presentation period rather than six months since they are statutory rather than tort-based claims. However, both lower courts interpreted these claims as tortious in nature due to their reliance on demonstrating economic loss or personal injury—criteria typically associated with tort actions.
Smith sought compensatory damages for economic loss resulting from what she described as wrongful termination under fraudulent pretenses related to privacy violations concerning medical information disclosure mandates imposed by her employer.
The appellate court affirmed the trial court’s decision without leave to amend, emphasizing that plaintiff’s arguments were insufficiently raised during initial proceedings and thus forfeited upon appeal review standards.
The case was presided over by Judges Fujisaki, Tucher (Presiding Judge), and Rodriguez with case ID A168045.