On October 27, 2008, the California Supreme Court held that the one-year statute of limitations on claims under the Fair Employment and Housing Act (“FEHA”) is subject to equitable tolling when an employee voluntarily pursues an internal administrative remedy. McDonald v. Antelope Valley Community College Dist., 45 Cal. 4th 88 (Cal. Oct. 27, 2008). This case effectively extends FEHA’s oneyear statute of limitations on the filing of discrimination claims during appropriate internal proceedings.