Can an action for back pay and punitive damages be brought under the Tort Claims Act?

Similarly, the court in Snipes v. City of Bakersfield (1983) 145 Cal.App.3d 861, 870, 193 Cal.Rptr. 760, held that an action for injunctive relief and other remedies as redress for employment discrimination was not subject to the claim presentation requirements of the Tort Claims Act merely because back pay and punitive damages were sought. "[A]n action for specific relief does not lose its exempt status solely because incidental money damages are sought.... Back pay clearly is specific monetary relief incidental to the requested orders that appellant be hired and that respondents be enjoined from discriminating against him." (Id., emphasis in original.)