In Carranza v. Los Angeles, 111 Cal. App. 5th 388 (2025), a female police captain, Lillian Caranza, sued for sexual harassment. A photo of a topless women who resembled her circulated electronically among department personnel. No one ever claimed the picture was of her, but when she found out about it spreading like wildfire through the department, she was mortified, and asked the department to notify employees it was not a picture of her and order personnel to stop sharing the post. The department did not accede to her request because it was concerned by sending out such a notice it would increase curiosity and attempts to find it and further embarrass Carranza. The department did, however, investigate Carranza’s complaint, but the investigation was unable to identify who was responsible for the distribution of the photo.
After the inconclusive investigation, on Christmas Eve, Carranza experienced shortness of breath, palpitations, pain in her left arm, and high blood pressure to such an extent that she went to an emergency room and was hospitalized overnight and released on Christmas day. Since learning about the photo, Carranza felt uncomfortable at work and had difficulty concentrating. She felt ashamed, avoided public settings, and was no longer comfortable speaking to the public and press—tasks that were part of her job. She developed major depressive disorder and generalized anxiety disorder.
Carranza conceded that no one ever directly joked about the picture with...
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