Bus Driver's Wage and Wrongful Termination Claims Dismissed for Missing California's Filing Deadlines
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Not every employment lawsuit ends in a win for the employee - and this case is an important reminder of why filing deadlines matter as much as the underlying facts of a case. A federal court dismissed most of a former Transdev bus driver's claims, not because her allegations lacked merit, but because she waited too long to file them.
Case: Tekoma Chaney v. Transdev Services Inc.
Court: U.S. District Court for the Central District of California
Case No.: 2:24-cv-10761
Get to Know the Plaintiff: Chaney v. Transdev Services
Tekoma Chaney began working for Transdev as a bus driver in March 2019. She alleges that during her employment, her supervisors discriminated against her, penalized her for properly requesting leave under the Family and Medical Leave Act to care for her children, and penalized her for absences related to work injuries. Transdev terminated Chaney's employment in January 2020, citing absenteeism and tardiness.
Get to Know the Defendant: Chaney v. Transdev Services
Transdev Services Inc. is a transportation and transit services company that operates bus services, employing drivers like Chaney. Jamie Ogilvie is also named as a defendant in the case.
What Are the Allegations in the Complaint?
Chaney's complaint asserted sixteen causes of action under California statutory and common law, including several wage and hour violations. According to the complaint:
● Chaney's supervisors discriminated against her during her employment
● She was penalized for taking properly requested FMLA leave to care for her children
● She was penalized for absences related to work-related injuries
● Transdev failed to provide proper overtime compensation, rest breaks, and meal breaks
● Transdev failed to pay waiting time penalties and provide accurate itemized wage statements
● Chaney was ultimately terminated, allegedly in violation of public policy
What Was the Main Question in the Case?
The central legal question was not whether Chaney's underlying allegations were true, but whether her claims were filed within California's applicable statutes of limitations. Transdev moved for judgment on the pleadings, arguing that Chaney's Labor Code and wrongful termination claims were filed too late — even accounting for COVID-19 emergency tolling rules that temporarily extended certain filing deadlines.
Why Does the Case Matter to California Employees?
This is a California case, and its outcome is a critical cautionary lesson for California employees, even though it wasn't a win on the merits.
● California Labor Code wage claims generally carry a three-year statute of limitations, and wage statement claims carry a one-year statute of limitations — deadlines that can pass quickly for employees still working through disputes with a former employer
● Wrongful termination claims brought under common law carry a two-year statute of limitations, separate from claims brought under the Fair Employment and Housing Act
● Even statewide emergency rules, like the COVID-19 tolling order that extended deadlines by 178 days, have limits, and missing a deadline by even a few months can result in permanent dismissal of otherwise valid claims
● This case underscores why employees who believe they've experienced wage violations, discrimination, or wrongful termination should consult an employment attorney as soon as possible, rather than waiting
A Brief Overview of the Case
● March 18, 2019: Tekoma Chaney begins working for Transdev as a bus driver
● January 24, 2020: Transdev terminates Chaney's employment, citing absenteeism and tardiness
● November 17, 2023: Chaney files her complaint, asserting sixteen causes of action
● Transdev moves for judgment on the pleadings, arguing several claims are time-barred
● April 9, 2026: The court grants Transdev's motion, dismissing Chaney's overtime, rest break, meal break, waiting time penalty, wage statement, retaliation, and wrongful termination claims without leave to amend as untimely
FAQs: Chaney v. Transdev Services
Q: What is a statute of limitations?
A: A statute of limitations is a legal deadline for filing a lawsuit. If a claim is filed after that deadline passes, courts will typically dismiss it regardless of whether the underlying allegations are true.
Q: How long do I have to file a wage claim in California?
A: Most California Labor Code wage and hour claims carry a three-year statute of limitations, while inaccurate wage statement claims generally carry a shorter, one-year deadline.
Q: How long do I have to file a wrongful termination claim in California?
A: It depends on the legal theory. Common law wrongful termination in violation of public policy generally carries a two-year deadline, while claims brought under the Fair Employment and Housing Act follow a different timeline tied to administrative filing requirements.
Q: Did COVID-19 extend filing deadlines for California employment claims?
A: Yes, temporarily. California's Emergency Rule 9 tolled certain civil statutes of limitations from April 6, 2020 through October 1, 2020, but as this case shows, that extension has limits and doesn't cover deadlines missed by a significant margin.
Q: Can a case be dismissed even if the employee's allegations are accepted as true?
A: Yes. Courts accept factual allegations as true for purposes of certain motions, but if a claim is untimely as a matter of law, it can still be dismissed regardless of the underlying facts.
Q: What should I do if I think I have a wage or wrongful termination claim but I'm not sure how much time I have left to file?
A: Contact an employment attorney as soon as possible. Filing deadlines vary by claim type, and waiting even a few months can permanently bar an otherwise valid case.
Worried You've Waited Too Long to File a Wage or Termination Claim?
Chaney v. Transdev Services is a powerful reminder that timing matters just as much as the facts of your case. If you believe you've experienced wage violations or wrongful termination, don't wait to find out if you're still within your filing window. Contact Blumenthal Nordrehaug Bhowmik DeBlouw LLP. Knowledgeable employment law attorneys are ready to assist you in law firm offices located in Riverside, San Francisco, Sacramento, San Diego, Los Angeles, and Chicago.
