After Daniel Huffman, a sales manager in Pomona for Interstate Brands Co. (IBC), was demoted, he sued for age bias and emotional distress arising from a knee injury incurred in the new job, which required him to perform heavy physical work. A trial court awarded him $2 million for emotional distress from the knee injury, but now a California appeals court has thrown out the award, ruling that workers’ compensation was Huffman’s only remedy. An employee can recover damages for emotional distress arising from an illegal demotion, but workers’ comp is the sole remedy for an industrial injury occurring after the illegal demotion—unless the discriminatory act was a substantial factor in causing the injury, which wasn’t the case here. An example of when the bias would be a substantial factor would be if an employer demoted a disabled worker to a job the employer knew the worker couldn’t safely perform because of the disability, and the worker then was injured.