In Sisemore v. Master Financial, Inc., ___ Cal.App.4th ___ (Jun. 12, 2007), the Court of Appeal (Sixth Appellate District) addressed a UCL "unlawful" prong claim predicated on alleged violations of the Fair Employment and Housing Act (Gov. Code §§12955 et seq.) and the Unruh Act (Civ. Code §§51 et seq.). Notably, this case is an individual UCL action, not a putative class action.
(For a discussion of the appellate practice aspects of the Sisemore decision, see this post at The Appellate Practitioner.)