What is the test for establishing a prima facie case of retaliation under section 1102.5 of the California Civil Code?

California, United States of America


The following excerpt is from Miller v. City of L. A., B245514 (Cal. App. 2014):

"To establish a prima facie case of retaliation, the a plaintiff 'must show (1) [he or she] engaged in a protected activity, (2) [the] employer subjected [the plaintiff] to an adverse employment action, and (3) there is a causal link between the two.' [Citation.]" (McVeigh v. Recology San Francisco (2013) 213 Cal.App.4th 443, 468.) "An employee engages in protected activity [under section 1102.5, subdivision (b)] when [he or she]

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