Raines v. U.S. Healthworks: Employer’s Agreement Binds Employees

In 2015, Robert Raines applied for a position with U.S. Healthworks Medical Group. As part of the hiring process, he was required to provide detailed information about his personal medical history and that of his family. The form asked for conditions ranging from cancer to mental illness, with questions extending to parents and other relatives. Raines provided the requested information but later challenged the requirement.

Raines filed a putative class action lawsuit against U.S. Healthworks Medical Group, alleging that the company’s application process violated the California Fair Employment and Housing Act (FEHA). He claimed the inquiries were impermissible under state law, which limited employer medical inquiries before making a conditional offer of employment. The trial court dismissed the action, reasoning that FEHA did not authorize a private right of action for such claims.

Proceedings in state courts

On appeal, the California Court of Appeal affirmed the dismissal, agreeing that FEHA did not expressly provide an applicant with the right to sue over pre-offer medical inquiries. The appellate court concluded that enforcement authority rested with the Department of Fair Employment and Housing.

Raines sought review in the California Supreme Court. The central question before the court was whether FEHA provided job applicants with a private right of action against employers for allegedly unlawful medical inquiries during the hiring process.

California Supreme Court’s analysis

The Supreme Court of California reviewed the statutory framework of FEHA. The law prohibited medical and psychological inquiries of applicants before a conditional offer of employment, except in very limited circumstances. It also expressly authorized civil actions by “any person claiming to be aggrieved by an unlawful employment practice.”

The court concluded that unlawful pre-offer medical inquiries qualified as unlawful employment practices under FEHA. It emphasized that the statute’s plain language allowed individuals to bring civil actions for such practices, rather than limiting enforcement solely to administrative agencies.

The justices also examined the broader legislative intent of FEHA, noting its purpose of ensuring equal employment opportunities and preventing discrimination at all stages of the employment process. By recognizing a private right of action, the court explained that applicants had a remedy to challenge practices that could lead to discrimination.

Final outcome

The California Supreme Court reversed the appellate court’s decision. It held that job applicants had the right to bring civil lawsuits under FEHA when employers required improper medical disclosures during the hiring process.

Help with labor and employment law disputes

If you have faced improper medical inquiries, discrimination, or unfair treatment during the hiring process or in employment, Whitcomb, Selinsky PC handles labor and employment cases involving hiring practices, workplace discrimination, and employee rights. Reach out to schedule a consultation and learn how our team can assist with your claim.