In a powerful reminder that employers must act swiftly to stop workplace harassment, the California Court of Appeal recently upheld a $4 million jury verdict for an LAPD captain who was the target of offensive, sexually harassing conduct—even though she never personally saw the harassing material.
The case, Carranza v. City of Los Angeles, 111 Cal. App. 5th 388 (2025), affirms the principle that learning about harassing conduct through others can still create a hostile work environment, and that employers who refuse to intervene may face steep legal consequences under California’s Fair Employment and Housing Act (FEHA).
What Happened in the Carranza Case?
Captain Lillian Carranza, one of the highest-ranking women in the Los Angeles Police Department, discovered that a sexually explicit image of a topless woman resembling her was being widely circulated by fellow LAPD officers. She never personally saw the photo—but colleagues told her it was being shared and discussed in a way that was deeply degrading and disrespectful.
Carranza asked the department to:
- Investigate the circulation of the image
- Notify employees that the woman in the photo was not her
- Take steps to stop further distribution
The LAPD declined to issue any corrective communication or discipline those involved.
Carranza sued the City under FEHA’s sexual harassment provisions, claiming the circulation of the image and LAPD’s inaction created a hostile work environment. A jury agreed—awarding her $4 million in emotional distress damages.
The Legal Ruling: Harassment Doesn’t Have to Be Direct
The City of Los Angeles appealed the verdict, arguing that Carranza:
- Never saw the image herself
- Was not directly confronted or harassed in person
- Did not suffer a “severe or pervasive” hostile work environment
The Court of Appeal rejected those arguments and affirmed the verdict in full.
Key Legal Takeaways from the Court:
- Secondhand Knowledge Is Enough
A worker does not have to personally witness the harassing behavior. Learning that your image is being sexually circulated without consent—especially in a male-dominated workplace—is enough to support a harassment claim. - One Incident Can Be Actionable
FEHA § 12923, amended in 2019, makes clear that a single incident of harassing conduct can be unlawful if it disrupts work or creates a hostile environment. - Employer Inaction Is Liability
The City’s refusal to act after Carranza complained was critical. The Court said the employer’s inaction “amplified the severity and pervasiveness” of the harassment. - Credibility and Harm Were Clear
Carranza’s testimony, and that of other officers, showed she experienced humiliation, stress, and professional harm, even without seeing the image herself.
What This Means for California Workers
This case is a wake-up call to employers—and a powerful validation for employees.
Your employer must take action if:
- A rumor, image, video, or sexually explicit comment is circulating about you
- You are being objectified, degraded, or sexualized—even indirectly
- You report offensive conduct and are ignored, gaslit, or retaliated against
You don’t have to wait until it gets worse. You don’t have to be touched, propositioned, or verbally abused in person to file a claim. The emotional harm is real—and the law recognizes it.
Harassment Doesn’t Always Look Like Harassment
Carranza shows how non-traditional forms of harassment—like the circulation of photos, AI-generated images, or group chat content—can still be actionable under FEHA.
The workplace has gone digital. So has harassment. But California law keeps evolving to protect workers from the emotional and professional damage that comes from being sexually humiliated at work.
What to Do If This Happens to You
If you learn that:
- An offensive or doctored image of you is circulating at work
- Coworkers are discussing you in a sexual or derogatory way
- Management refuses to take action after you complain
You may have a strong claim for:
- Hostile work environment harassment
- Failure to prevent harassment
- Retaliation, if you are demoted, isolated, or punished for reporting it
At Employees First Labor Law, we will help you document what happened, hold your employer accountable, and fight for the compensation you deserve.
EFLL Is Here to Help
You have a right to dignity at work. If your employer stands by while you are harassed—even indirectly—we’ll stand with you.
We’ve helped thousands of workers navigate discrimination and harassment claims across California—and we’re ready to help you next.
