In October 2012, plaintiff Deborah Sanders, a black, long-term relief nurse at the Los Angeles County + USC Medical Center, was terminated from her temporary assignment. Sanders began working at LAC+USC in 1993, during which she was primarily staffed to work in the psychiatric emergency room. Sanders claimed that she continually complained about patient safety issues and patient-to-nurse staffing ratios, as well as complained about harassment and/or discrimination in the workplace, and that as a result, she was retaliated against based on her race and national origin and wrongfully terminated. Sanders sued her employer, the operator of LAC+USC Medical Center, the county of Los Angeles; her nursing supervisor, Sunday Okundolor; and the nursing director of emergency medicine at LAC+USC, Sheila Mallett. Sanders alleged that the defendants’ actions constituted racial and national origin harassment and discrimination, retaliation, and wrongful termination. Sanders claimed that she continually engaged in whistleblowing activities by complaining to Okundolor about patient safety issues and patient-to-nurse staffing ratios and that she regularly complained during staff meetings. With respect to staffing ratios, Sanders alleged that there was a violation of the four-to-one patient-to-staff ratio in the psychiatric emergency room, as proscribed by Title 22 (22 CCR § 70217). She also claimed that she complained about harassment and discrimination in the psychiatric emergency room during the course of an investigation of other employees’ claims of harassment or discrimination by other nursing staff. Sander contended that her support for others made her a target of her nurse managers, who were Nigerian and white, and that as a result, she began to experience harassment and discrimination based on her race and national origin in or about January 2012. Sanders asserted that Okundolor, who is black/Nigerian, harassed her by instructing her to cover shifts in other areas of the hospital outside of the psychiatric emergency room and beyond her scope of training. She also asserted that Mallett, who is white, harassed her by unjustly blaming work incidents on her and making comments about her being a distraction to other employees. In addition, Sanders claimed that the defendants forced her to violate the Health Insurance Portability and Accountability Act with respect to patient charting on the computer system used in the psychiatric emergency room. She alleged that as a result, she made anonymous complaints about the alleged HIPAA violations due to improper access of patient records by other nurses. Thus, Sanders claimed that favoritism displayed to Nigerian nurses in the unit resulted in her termination due to her race and national origin, since she is black and non-Nigerian. She also claimed that as a result of her complaints, she was terminated from her temporary position with the county in violation of Labor Code § 1102.5 (whistleblower retaliation) and in violation of the Fair Employment and Housing Act. Defense counsel argued that Sanders had significant performance problems that resulted in her termination from her temporary relief nurse position at LAC+USC. Counsel asserted that Sander’s inattention and poor performance led to two sentinel events in the psychiatric emergency room that resulted in a thorough investigation by the performance management unit, which ultimately recommended Sanders’ termination as well as the disciplining of other staff. Specifically, defense counsel contended that in June 2012, a psychiatric patient was able to escape from the locked psychiatric emergency room during the night shift by sneaking out of a back door that was left ajar. Sanders was involved in the incident, as she came to the psychiatric emergency room an hour after her shift ended. Defense counsel argued that Sanders’ purpose for the visit was to socialize with other employees who were on duty, causing a distraction. An employee who was on duty and tasked with monitoring the patient who escaped was held responsible for the incident, not Sanders, but defense counsel asserted that the incident led management to be concerned about Sanders’ conduct. Defense counsel further contended that in August 2012, a patient-on-patient sexual assault occurred in the locked psychiatric emergency room during the night shift. Several employees were implicated as contributing to the incident as a result of being inattentive to their duties in the psychiatric emergency room, including failing to monitor patients and taking improperly long breaks. The incident was self-reported by the county to law enforcement and the county’s Department of Public Health. As a result, the Los Angeles Sheriff’s Department undertook a full investigation, and a male patient was subsequently charged with the sexual assault of a female patient. Defense counsel contended that law enforcement relied on the psychiatric patients’ eyewitness testimony to provide a basis for the assault charge, as the staff members in the psychiatric emergency room were unable to serve as credible witnesses of the incident because they were inattentive and, in certain cases, asleep while on duty. In addition, performance management investigators interviewed the employees on duty during the sexual assault incident, and reviewed all document and videotape evidence available. Defense counsel contended that performance management concluded that during the incident, Sanders was the acting charge nurse for the psychiatric emergency room and was in view of the middle patient area where the assault occurred. Counsel further contended that as a result, performance management determined that Sanders failed to either monitor the psychiatric emergency room patients or ensure another staff member was present in the area to prevent the assault. Defense counsel maintained that as a result of the incidents, the nursing administration considered staffing Sanders out of the psychiatric emergency department, but ultimately decided that Sanders’ conducted merited termination. In response, plaintiff’s counsel argued that nursing administrators and performance management investigators conspired to hold Sanders responsible for the incidents involving a patient escape and a patient sexual assault because of Sanders’ complaints about patient safety and patient-to-staff ratios, as well as her reporting of discrimination and harassment. Plaintiff’s counsel further argued that Okundolor and Mallett were the moving force behind Sanders’ release, and targeted Sanders because of bias and bigotry toward her race and national origin., Sanders claimed that she suffered a loss of earnings, overtime, and benefits as a result of her termination. She also claimed she suffered emotional and physical distress, including weight loss and an increase in blood pressure, as a result of the harassment, retaliation, and discrimination. Thus, Sanders claimed that her economic losses exceeded $600,000 and that her noneconomic losses exceeded $750,000.