In a ruling that could simplify the defense of retaliation claims in California, the California Supreme Court recently held that there exists no individual liability for retaliation under California’s Fair Employment and Housing Act (FEHA). Jones v. The Lodge at Torrey Pines P’ship, (Cal. Mar. 3, 2008). Although the FEHA prohibits discrimination by "an employer," in contrast, it prohibits retaliation by "any employer, labor organization, employment agency, or person." Based on the legislative history, the court determined that the legislature did not intend to provide for personal liability when it added the word "person."