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

California employers should take notice of the conclusion drawn in the Higgins-Williams case–an employee's claimed inability to work under a supervisor because of the supervisor's causing the employee anxiety and stress during standard oversight of the employee's performance, does not entitle the employee to a viable claim for disability discrimination under the California Fair Employment and Housing Act (FEHA).

Is Stress Caused By Supervisors An FEHA Claim?

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,” which her physician described as a disabling stress condition caused by her interactions with her manager and company Human Resources (HR) representatives.

Sutter granted her a stress-related leave of absence of slightly more than 30 days. But after she returned to work, she received her first negative performance evaluation. She also asserted experiencing additional conflicts with her manager, describing her manager as “curt and abrupt” to her during their interactions, gave her a disproportionate share of work, and, one day, yelled at her, causing her to suffer a panic attack and leave work, never to return.

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. The company agreed to extend her leave several times, but it ultimately advised her that it would terminate her employment unless she provided information regarding (1) her anticipated return to work date, and (2) whether additional leave as an accommodation would effectuate her return to work. When she failed to supply this information, Sutter terminated her employment, and she filed suit.

Alleged Disability Discrimination

In her lawsuit, Higgins-Williams alleged disability discrimination under FEHA, violation of the California Family Rights Act (CFRA), wrongful termination, and related claims. The Court of Appeal (Court) affirmed the lower court's ruling for the employer on summary judgment, holding that the employee did not qualify as “disabled” for purposes of her FEHA or wrongful termination claims 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.”

The Court noted that the outcome could be different if the supervisor was doing something other than “standard oversight of job performance,” but that there was no such evidence in the case. The Court further held that the employee's CFRA claim was properly dismissed because her testimony—that she did not think she could have returned to work but was willing to try—failed to raise a genuine issue of material fact as to whether the company unlawfully failed to reinstate her following her leave.

Key Takeaways

While all complaints about supervisors' treatment of employees should be documented and investigated as a matter of sound business procedures, California employers are not required to grant an employee's request to transfer to a different supervisor as a disability accommodation, even if the employee submits medical documentation that working under a current supervisor causes him or her to be “stressed.”

Consulting an experienced Los Angeles employment lawyer is an effective way to get answers to your questions about disability discrimination and FEHA. To discuss a potential claim on your behalf, feel free to contact leading California employment lawyers at Kingsley & Kingsley. Call us at (818) 990-8300 or click here to contact us via email.