Lilian Carranza, then a captain in the Los Angeles Police Department (LAPD or Department), learned that a photo of a topless woman, which was falsely said to be her, was circulating among LAPD personnel. One of her subordinates told her: 1) he had seen on-duty officers looking at the photo on a cellphone and making lewd comments about Carranza; and 2) he had heard officers were talking about the photo everywhere he went. Carranza asked the Department to notify personnel that the photo was not of her, and to order they stop sharing it.
The Department investigated. The investigation found that an unknown Department employee, while on or off-duty, circulated a photograph of a nude woman throughout the Department and indicated it was Carranza. The investigation identified 10 to 13 people who saw the photo and four separate incidents of people viewing or hearing about the photo. Carranza received a letter from the LAPD that said appropriate penalties would be imposed but did not disclose further details, citing confidentiality reasons. Carranza later learned no officers were disciplined.
The Department did not notify personnel that the photo was not Carranza, nor order that employees stop sharing it.
Carranza sued the City of Los Angeles, asserting a single cause of action for hostile work environment due to sexual harassment under the Fair Employment and Housing Act (FEHA). A jury found in Carranza’s favor, and determined that the LAPD failed to take immediate and appropriate corrective action despite that it knew of the conduct. It awarded Carranza $4 million in noneconomic damages.
The City appealed. The City claimed that there was insubstantial evidence that the harassment was sufficiently severe or pervasive to alter the conditions of Carranza’s employment and create an abusive work environment.
The California Court of Appeal rejected the City’s claim. The Court determined that substantial evidence supported the jury’s determination that Carranza endured severe or pervasive harassment that altered the conditions of her workplace, based on Carranza’s secondhand knowledge that the photo was widely circulating. Carranza understood that the photo circulated for some length of time and involved “dozens if not hundreds” of officers, both identified and unknown, throughout the LAPD.
Plus, despite Carranza’s repeated requests, the Department did not order LAPD officers to stop sharing the photo, advise them that it was not Carranza in the photo, or discipline anyone who distributed the photo. The fact that LAPD allowed the distribution to continue unchecked supported not only Carranza claims that LAPD’s response to the harassment was not sufficient, but also demonstrated the pervasiveness and severity of the harassment itself and the impact on Carranza’s work environment.
Carranza v. City of Los Angeles, 111 Cal.App.5th 388 (2025).