Employee’s Inability To Work For A Particular Supervisor Does Not Constitute A “Disability”

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Higgins-Williams v. Sutter Med. Found., 237 Cal. App. 4th 78 (2015)

Michaelin Higgins-Williams worked as a clinical assistant in Sutter’s Shared Services Department. Higgins-Williams reported to her treating physician that she was stressed because of interactions at work with human resources and her manager. Her physician diagnosed Higgins-Williams with “adjustment disorder with anxiety,” and Sutter granted her a stress-related leave of absence of slightly more than 30 days. After returning from the leave of absence, Higgins-Williams received a negative performance evaluation and had additional conflicts with her manager. Shortly thereafter, she submitted a disability accommodation request form in which she sought a transfer to a different department and an additional leave of absence. Following additional leaves of absence, which extended for more than a year, Sutter eventually terminated Higgins-Williams’ employment. In her lawsuit, Higgins-Williams alleged disability discrimination, wrongful termination and related claims. The trial court granted the employer’s motion for summary judgment, and the Court of Appeal affirmed on the ground that Higgins-Williams was not disabled because “an employee’s inability to work under a particular supervisor because of anxiety and stress related to the supervisor’s standard oversight of the employee’s job performance does not constitute a mental disability under FEHA.” Because Higgins-Williams had failed to indicate to the employer when or if she could return to work, her claim for violation of the CFRA/FMLA was also properly dismissed. See also Roman v. BRE Properties, Inc., 2015 WL 3767790 (Cal. S. Ct. 2015) (unsuccessful plaintiffs in housing disability discrimination lawsuit may not be liable for defendant’s costs under the FEHA).

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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