By: Sam G. Sherman, Esq. In a case argued and briefed by Higgs, Fletcher & Mack's appellate team of John Morris and Victoria Fuller, the Second Circuit Court of Appeals in Haligowski v. Superior Court rejected an attempt to impose individual liability against supervisors for claims of servicemember discrimination in violation of Section 394 of California's Military and Veteran's Code. California courts previously rejected the imposition of individual liability against managers for discrimination under the Fair Employment and Housing Act (FEHA). (Reno…