California Court Clarifies FEHA Strict Liability for Supervisor Harassment

In a recent decision, the Second District Court of Appeal clarified that the Fair Employment and Housing Act’s (FEHA) strict liability standard for supervisor harassment does not apply when the alleged harasser is not the plaintiff’s supervisor and only supervises other employees (Jane Doe v. Wells Fargo Bank, N.A., No. B344642, (Cal. Ct. App. Oct. 5, 2026)).

What Happened?

Jane Doe worked for her employer as a wealth advisor, assisting wealthy clients with a team of specialists, including investment strategists, financial advisors and private