What Would You Do?

A Wake-Up Call for Employers – Lessons from Carranza v. City of Los Angeles (2025)

One of your employees, a respected senior manager, learns while on vacation that a sexually explicit photo, falsely attributed to her, is being circulated among staff. Colleagues are making degrading comments. The image is spreading from one work site to another, even showing up during shift changes and public events.

She calls you upset, humiliated, and desperate for help. She demands two things:

1. Tell employees the image is fake, and
2. Tell the employees that sharing it is misconduct and order them to stop sharing it.

She submits a formal complaint. The facts are alarming, the conduct serious, and the potential harm significant.

As the employer, what would you do?

What the City of Los Angeles Did—And Why It Wasn’t Enough

In Carranza v. City of Los Angeles (2025) 111 Cal.App.5th 388, the LAPD received this exact complaint from Captain Lillian Carranza in late 2018. A topless image that resembled her was circulating widely, accompanied by vulgar comments.

Despite her requests, LAPD leadership refused to issue a message disavowing the photo or instructing employees to stop spreading it. They were aware of the rumors and the damage being done to her reputation, but took no prompt public or corrective action. An investigation was eventually initiated, but it took over nine months to conclude.

The investigation sustained the allegation that the photo was being circulated within the department, identified 10-13 people who had seen the photo, determined that it violated the City’s and Department’s sexual harassment policy, and deemed it “serious misconduct.”  The Department did not discipline any employee because it was unable to determine who was responsible for the original distribution of the photo.

In 2022, a jury awarded her over $4 million in damages. In 2025, the California Court of Appeal upheld the verdict, making it clear: delay, inaction, and silence in the face of known sexual harassment violate FEHA.

Your Legal Obligation Under FEHA

As an employer in California, the Fair Employment and Housing Act (FEHA) imposes a non-negotiable duty to act when harassment occurs.

If you know—or should know—of harassment, you must:

• Take immediate, appropriate corrective action
• Conduct a timely and impartial investigation
• Protect the complainant from further harm
• Prevent retaliation

The Court in Carranza emphasized that despite her repeated requests, the Department did not order the officers to stop sharing the photo, advise them that it was not Carranza, or discipline anyone involved in the distribution.  The Court stated that allowing the distribution to continue unchecked not only speaks to the sufficiency of the response, but also to the pervasiveness and severity of the harassment itself, and the impact on the work environment.

What Should You Have Done? A Blueprint for Employers

If you were in the City’s shoes, here’s what FEHA expects of you:

1. Immediate Acknowledgment and Safety Measures

• Respond to the complaint within days.
• Send a department-wide notice stating:
  • The photo is fake.
  • Sharing it violates policy.
  • Harassment will not be tolerated.

Tip: A timely, transparent communication can both protect the complainant and prevent further liability.

2. Initiate a Prompt, Independent Investigation

• Appoint a skilled, neutral investigator with authority.
• Interview witnesses, secure evidence (phones, emails, text chains).
• Monitor for ongoing misconduct or retaliation.

Don’t wait until harm multiplies. Investigations should begin immediately, not weeks or months later.

3. Implement Interim Protections

• Modify work assignments or schedules if necessary.
• Reiterate anti-harassment and anti-retaliation policies.
• Offer the complainant EAP support, time off, or modified duties if needed.

4. Follow Through With Accountability

• Take corrective action where warranted.
• Discipline should be proportionate and documented.
• Close the loop with the complainant—even if findings are inconclusive.

Why Inaction Equals Liability

The City’s failure to act created a “poisoned” work environment that made Captain Carranza’s suffering worse with each passing day. The Court found that failure to respond to secondhand, image-based harassment was just as unlawful as ignoring direct misconduct.

The verdict and appellate ruling affirm:

• Gossip and rumor-based sexual harassment can violate FEHA.
• Delay or silence—even out of fear of drawing attention—can be interpreted as indifference or retaliation.
• Leadership choices matter. Chief Moore’s refusal to send a clarifying message became a central point of liability.

So, What Would You Do—Now?

If a similar complaint lands on your desk:

• Would you respond that day?
• Would you stop the rumor mill before it spreads?
• Would you wait until the investigation was complete—or act immediately to protect your employee’s dignity?

Takeaways for Employers

✅ Act fast. Delay is dangerous.

✅ Say something. Your silence may be perceived as tolerance of harassment.

✅ Protect first, investigate second. Interim measures are essential.

✅ Avoid retaliation. Support the complainant, and monitor their workplace experience going forward.

✅ Train leadership. Supervisors must know how to respond when serious allegations arise.

Conclusion

Carranza v. City of Los Angeles is a cautionary tale—but also a roadmap. As an employer, your first response to harassment will likely determine your legal exposure, workplace culture, and employee trust.

The question is no longer hypothetical.

What would you do?

If you would like to learn more about preventing harassment in the workplace or responding to complaints of harassment, please contact us.

Mark Myles has been advising private and government enterprises on a wide range of matters for more than 25 years.  He currently focuses his practice on workplace investigations. He is a member of the Association of Workplace Investigators.