Section 815 applies to claims for wrongful termination in violation of public policy because the claim is considered a common law tort under California law.

Because the `classic Tameny cause of action'is a common law, judicially created tort... and not authorized by statute, it is not properly asserted against the Regents

When a... public entity establishes an internal grievance mechanism,... failure to exhaust those internal remedies precludes any subsequent private civil action

A tenured teacher is required to exhaust his or her internal administrative remedies before going to court

—the court set forth the important policy considerations supporting the exhaustion requirement: " `[A] n exhaustion of remedies requirement serves the salutary function of eliminating or mitigating damages. If an organization is given the opportunity quickly to determine through the operation of its internal procedures that it has committed error, it may be able to minimize …

—the Court of Appeal applied section 815 in a context similar to that presented here: a whistleblower retaliation claim against the University of California.

The requirement of exhaustion of the administrative remedy is "a jurisdictional prerequisite to resort to the courts

Indeed, one of the internal grievance procedures available in Palmer was the procedure implementing the university's obligations under section 8547.10

Terris acknowledged she "did not file an EEO complaint prior to pursuing claims for violation of [sections] 1101, 1102, and 1102.5