Plaintiff prevailed in her employment action brought under California’s Fair Employment and Housing Act [FEHA; Government Code section 12900] because defendant did not take reasonable steps to prevent sexual harassment. In reversing the judgment, the appellate court stated: “We hold there cannot be a valid claim for failure to take reasonable steps necessary to prevent sexual harassment if, as here, the jury finds that the sexual harassment that occurred was not sufficiently severe or pervasive as to result in liability. A claim for failure to take reasonable steps necessary to prevent sexual harassment cannot prevail when the necessary element of sexual harassment is not established.” (Dickson v. Burke Williams, Inc. (Cal. App. Second Dist., Div. 5; March 6, 2015) 234 Cal.App.4th 1307 [184 Cal.Rptr.3d 774].)
