Taking the Stress Out of Employee Claims of Disability Caused by the Stress of Working for a Particular Supervisor

Dorsey & Whitney LLP

Navigating an employee’s claim of stress-related disability continues to challenge employers. Recently, the California Court of Appeal provided helpful guidance for employers when an employee claimed to be unable to work under a particular supervisor due to the anxiety and stress triggered by that supervisor’s standard of oversight of the employee’s job performance.

In Higgins-Williams v. Sutter Medical Foundation, (May 26, 2015), the Court of Appeal held that an employee’s inability to work for a specific supervisor is not a cognizable mental disability under the Fair Employment and Housing Act. In this disability discrimination case, an employee sought an extended medical leave, and requested permanent reassignment in order to return to work, arising out of her stressed interactions at work with both her supervisor and human resources. Higgins-Williams, a clinical assistant, complained to her treating physician regarding stressful interactions at work. Her physician diagnosed her with having adjustment disorder with anxiety, as a result of “dealing with her Human Resources and her manager.” Her employer, Sutter Medical Foundation (“Sutter”), granted the plaintiff her requested stress-related leave of absence under the California Family Rights Act and the Family and Medical Leave Act.

Originally published in Orange County Business Journal - June 2015.

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