In Fitzsimons v. California Emergency Physicians Medical Group, a California court of appeal revived an emergency room physician's retaliation claim against the partnership of which she is a member.  The physician claimed that the partnership removed her from her regional director position and created a hostile working environment for her because she reported that officers and agents of the partnership were sexually harassing female employees.  The partnership argued, and the trial court agreed, that the anti-retaliation protections applied only to employees and did not extend to members of the partnership.  The appellate court disagreed, finding the statutory language and legislative purpose supported a broader reading of the statute and recognizing protection for partners who oppose sexual harassment of the partnership's employees.