Was Randolph’s California Employment Case Properly Dismissed Under the Five-and-a-Half-Year Rule?

Randolph v. Trustees of the California State University is a California employment law case that turned less on the underlying discrimination claims and more on a strict procedural deadline. The 2026 decision of the California Court of Appeal upheld the dismissal of Teresa Randolph’s case; it found that the record did not show a valid oral agreement to extend the statutory deadline to bring the action to trial.

Case: Randolph v. Trustees of the Cal. State Univ.

Court: California Court of Appeal

Case No. Super. Ct. No. 19CV01226

Who Is the Plaintiff in the Case?

The plaintiff is Teresa Randolph, a former employee of California State University, Chico. According to the appellate opinion, she filed suit against her prior employer and other defendants on April 19, 2019, asserting claims of employment discrimination, whistleblower retaliation, and termination of her employment. The opinion does not resolve whether those underlying employment allegations were true, because the appeal focused on whether the case was brought to trial in a timely manner. As a result, the published decision addresses whether her lawsuit could proceed after missing the governing trial deadline.

Who Is the Defendant in the Case?

The lead defendant is the Trustees of California State University. The opinion states that Randolph sued her prior employer and several others (collectively, the defendants). During the trial court proceedings, the defendants moved to dismiss the case after the trial date was set beyond the statutory deadline for bringing the action to trial, arguing that no exception applied and that the action therefore had to be dismissed under California’s mandatory dismissal rules.

The Plaintiff’s Allegations: Randolph v. Trustees of the Cal. State Univ.

Randolph’s underlying lawsuit involved employment discrimination, whistleblower retaliation, and wrongful termination-related claims arising from her prior employment at California State University, Chico. The appellate dispute, however, was procedural. Randolph argued the parties had effectively agreed in open court to a February 3, 2025, trial date, even though the statutory deadline to bring the case to trial was October 19, 2024. The defendants responded that there was no valid stipulation extending the deadline because the minute order did not reflect any such agreement, and no transcript of the hearing was included in the appellate record. The trial court agreed and dismissed the case with prejudice, and the Court of Appeal affirmed.

What Is Mandatory Dismissal? This means the court must dismiss a case if it is not brought to trial within the time required by law, unless a recognized exception applies. In Randolph’s case, the Court of Appeal held that dismissal was required because the statutory deadline had expired and the claimed exception was not established in the record.

What Is an Oral Stipulation Made in Open Court? Under Code of Civil Procedure section 583.330, parties can extend the deadline to bring a case to trial by oral agreement in open court, but only if that agreement is entered in the court’s minutes or preserved in a transcript. The appellate court held that the requirement was not satisfied here.

What Is the Main Question in the Case?

The central question on appeal was whether the parties entered into a valid oral agreement extending the deadline to bring Randolph’s case to trial. Randolph argued that both sides agreed to the February 2025 trial date at the March 27, 2024, case management conference and that this was enough to avoid mandatory dismissal. The Court of Appeal disagreed, explaining that section 583.330 requires the oral agreement to appear in the court minutes or in a transcript, and the record contained neither. Because the minute order showed only that the trial date was set, without reflecting mutual assent to extend the deadline, the dismissal stood.

FAQ: Randolph v. Trustees of the Cal. State Univ.

Q: What Was Randolph v. Trustees of the California State University About?

A: The underlying lawsuit involved employment discrimination, whistleblower retaliation, and termination-related claims by a former California State University, Chico employee. The appellate decision, however, focused on whether the case was properly dismissed for not being brought to trial within the statutory deadline.

Q: Why Was Randolph’s Case Dismissed?

A: The case was dismissed because it was not brought to trial within the five-year deadline, as extended by six months under Judicial Council emergency rule 10 during the COVID-19 period. The Court of Appeal held that no valid statutory exception was shown in the record.

Q: What Was the Deadline to Bring the Case to Trial?

A: The Court of Appeal said Randolph filed suit on April 19, 2019, and that the five-year-plus-six-month deadline to bring the action to trial was October 19, 2024. The trial court later set the trial for February 3, 2025, which was beyond that deadline.

Q: Why Didn’t the February 2025 Trial Date Count as an Agreed Extension?

A: The appellate court said an oral agreement to extend the deadline must be reflected in the minutes of the court or preserved in a transcript. Here, the minute order simply listed the dates that were set and did not record any oral stipulation, and there was no reporter’s transcript in the record.

Q: What Did the Court of Appeal Decide?

A: The Court of Appeal affirmed the judgment of dismissal. It held that the oral-agreement exception in Code of Civil Procedure section 583.330, subdivision (b), did not apply because the record lacked the documentation required by the statute.

Q: Why Does This Case Matter in California Employment Litigation?

A: This case is a reminder that even serious workplace claims can be lost on procedural grounds if statutory deadlines are missed. For both employees and employers, it underscores the importance of preserving any trial-deadline extension in a written stipulation, a minute order that clearly reflects the agreement, or a transcript.

If you have questions about employment discrimination, whistleblower retaliation, wrongful termination, or procedural issues that may affect your right to pursue a California employment case, the employment law attorneys at Blumenthal Nordrehaug Bhowmik De Blouw LLP can help. Contact one of our offices in Los Angeles, San Diego, San Francisco, Sacramento, Riverside, or Chicago today to learn how to hold your employer accountable.