In Alvarado v. Cajun Operating Co., the Ninth Circuit held that the ADA does not allow a claimant to recover compensatory or punitive damages for alleged retaliation for having complained about disability discrimination. Plaintiff, a cook at a Church’s Fried Chicken franchise in Tucson, Arizona, was allegedly discharged after complaining about disability discrimination. The court held that only equitable relief was available, and that plaintiff did not have a right to a jury trial or damages. California employers should note that, under state law, such a complaint followed by termination could support a common law claim wrongful termination claim, which would allow the plaintiff to seek monetary damages