To establish a prima facie case of retaliation, a plaintiff must show that (1) they engaged in a protected activity, (2) that they were thereafter subjected to adverse employment action by their employer, and (3) there was a causal link between the two. Iwekaogwu v. City of Los Angeles, 75 Cal.App.4th 803, 814 (1999), quoting Flait v. North American Watch Corp., 3 Cal.App.4th 467, 476 (1992).
In order to be protected against discharge, a complainant need only make a good faith complaint about working conditions that they believes to be unsafe. Cabesuela v. Browning-Ferris Industries of California, Inc., 68 Cal.App.4th 101, 1009 (1998) [emphasis added]. An employer is prohibited from retaliating against a complainant who made “a bona fide oral or written complaint to [their] employer of unsafe working conditions, or work practices, in [their] employment or place of employment.” Labor Code § 6310(b) [emphasis added].
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