Before filing suit under the California Fair Employment and Housing Act ("FEHA"), an employee must exhaust her administrative remedies with the Department of Fair Employment and Housing ("DFEH"). In the recently decided case of Wills v. Superior Court, the court gave little leeway to an employee, finding that she failed to exhaust her administrative remedies because her DFEH complaint only alleged discrimination based on a denial of family/medical leave, while her lawsuit raised different allegations of disability discrimination, retaliation, harassment, and failure to accommodate. Wills was diagnosed with bipolar disorder prior to beginning employment with the Superior Court of Orange County (the "OC Court"). During her employment, she took numerous medical leaves of absences related to the treatment of her disorder, but neither she nor her doctor informed the OC Court of her medical condition.

On one occasion, when Wills was assigned to work at the Police Department, she had to wait outside for several minutes before she was admitted into the building. After being admitted, Wills angrily swore at police department employees and accused them of intentionally leaving her outside. Wills further told one officer that she had added him and another employee to her "Kill Bill" list, which both employees understood was a list of people she intended to kill. Both employees felt threatened.

These events allegedly occurred during the early stage of a severe manic episode. A few days later, Wills' doctor placed her on medical leave for treatment. While on leave, Wills forwarded a cell phone ringtone to a coworker, that stated: "I'm going to blow this b***ch up if you don't check your messages right now!...F*** you!" The coworker reported the incident and complained of being disturbed and frightened. Wills also sent numerous threatening emails to coworkers.