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Franklin v. Union Pacific Railroad Co.
Defendant appeals from a judgment after a jury trial in an action for damages for race discrimination in employment under the California Fair Employment and Housing Act (FEHA). The jury found Union Pacific liable on a special verdict and awarded $500,000 damages on two rubrics: (1) disparate treatment amounting to an adverse employment action and (2) harassment amounting to a hostile work environment. Union Pacific contends that there is no substantial evidence supporting the first aspect of the special verdict because there is no substantial evidence of an adverse employment action. Court disagrees and affirms the judgment.

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