Randolph v. Trustees of the California State University: Trial Deadline and Missing Agreement

An employment plaintiff lost her action because it was not brought to trial within the applicable statutory period. A later trial setting and an opposing party’s silence did not establish the recorded agreement needed for the asserted extension.

Decision and publication history

Randolph v. Trustees of the California State University, No. C102901 (Cal. Ct. App. Dec. 30, 2025), affirmed a dismissal with prejudice. The opinion was filed December 30, 2025 without publication certification; the Third District certified it for publication on January 15, 2026. This updated analysis includes that later order. It does not describe the opinion as published precedent on January 1. Id., slip op. at 1, 4, 7; publication order at 1–2.

The employment claims and missed trial date

Teresa Randolph sued her former employer and others on April 19, 2019 for claims relating to employment discrimination, whistleblower retaliation, and termination. Code of Civil Procedure section 583.310 generally supplies a five-year trial deadline. The historical COVID emergency rule added six months for actions filed on or before April 6, 2020. The deadline in this action was October 19, 2024. Id., slip op. at 1–2.

At a March 27, 2024 case-management conference, the trial court set trial for February 3, 2025. After the statutory deadline passed, defendants moved to dismiss. Randolph argued that the parties had orally agreed to the later date, thereby extending the statutory time under section 583.330(b). Id., slip op. at 2–3.

The legal issue was proof of an oral extension

Section 583.330 allows a written stipulation or an oral agreement made in open court if entered in the minutes or reflected in a transcript. The question was whether the conference record established that second route. The Court of Appeal reviewed the dismissal for abuse of discretion while interpreting the statute de novo. Id., slip op. at 2, 4.

The minute order listed counsel’s appearances, the trial date, and other scheduled proceedings. It did not document a discussion or agreement extending time. No reporter’s transcript of the conference appeared in the appellate record. Counsel’s declaration in opposition to dismissal asserted that both parties agreed to the trial date, but the statute required the relevant oral agreement to be reflected in the specified court record. Id., slip op. at 3–5.

Why the comparison to Nunn failed

The panel distinguished Nunn v. JPMorgan Chase Bank, N.A., where a settled statement documented an exchange about a later trial date. That record described readiness for trial, defendants’ need for additional preparation, and both sides’ affirmative acceptance of the proposed date. As Randolph explained, that was more than a silent minute order showing that a hearing occurred and trial was set. Randolph, slip op. at 5–6.

The distinction is evidentiary and procedural. It is too broad to say a particular verbal formula is always necessary or that silence can never be considered in any procedural context. The holding rejected an inference of an oral extension from a minute order silent about an extension discussion, even though defendants had not objected to the late trial date. The panel declined to dispense with the statute’s requirement that the oral agreement be shown in the minutes or a transcript. Id., slip op. at 6–7.

The outcome did not resolve the merits of discrimination

The judgment was affirmed, with defendants entitled to appellate costs. The court did not decide whether Randolph had suffered discrimination or retaliation. Nor did it purport to resolve every statutory exclusion from the five-year period; the asserted oral agreement was the question presented. Id., slip op. at 4, 7.

That distinction matters to employees evaluating an adverse result. A procedural dismissal can end a potentially substantial claim without adjudication of its factual merits. A scheduled trial date does not establish that the court has extended every applicable statutory deadline.

Application to another California employment action

The first step is to calculate the relevant deadline independently, including any legally supported exclusions or extensions. The next is to obtain the documents supporting that calculation. If an extension is claimed, identify the written stipulation or the conference record reflecting the oral agreement. If the record is incomplete, appellate counsel must assess what lawful record procedures remain available; a later declaration should not be assumed to replace a required court record.

The emergency extension applied in this 2019 action is historical and not a general six-month addition for all employment cases. This analysis also should not be confused with administrative claim-filing or appellate deadlines. Our trial-deadline records guide addresses the practical documents to assemble, and our employment litigation practice can assess the actual procedural history.