In Alexander v. Community Hospital of Long Beach, the Court held that that the employee must name their employer in the Fair Employment and Housing Act (“FEHA”) complaint. The Court held that a group of plaintiffs failed to exhaust their administrative remedies against their former employer where they failed to name their employer in their FEHA complaint. The Court held that there was no equitable exception to the rule where the defendant received actual notice of the complaint and an opportunity to participate in the administrative process.  

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