Miklosy v. Regents of the University of California , decided today, holds that "Tameny" suits for wrongful termination in violation of public policy -- which courts have often allowed to be asserted against public entity employers -- are barred by Government Code section 815, which bars common-law causes of action against public entities.
Plaintiffs cannot get around this bar by suing individual employees, the court holds. Tameny causes of action can only be asserted against employers, not supervisors or other employees.
The court also strictly interpreted provisions in the whistleblowers' protection statutes that bar lawsuits by employees of the Regents of the University of California against the Regents if the Regents timely resolve the employee's administrative complaint.