Higgins-Williams v. Sutter Medical Foundation: Stress Caused By "Standard Oversight Of Job Performance" Is Not A Disability Under FEHA

In Higgins-Williams v. Sutter Medical Foundation (2015) 237 Cal.App.4th 78, Plaintiff Michaelin Higgins-WIlliams ("Plaintiff") was hired by Defendant Sutter Medical Foundation ("Defendant") as a clinical assistant.  In 2010 she reported to her physician that she was stressed because of interactions at work with human resources and her supervisor and was diagnosed with adjustment disorder with anxiety. 

She was granted a stress-related (disability) leave of absence under the FMLA and CFRA.  Her disabling condition was described as "stress[] when dealing with her Human Resources and her manager."  After Plaintiff exhausted her leave of absence under the FMLA and CFRA she returned to work and immediately received a negative performance evaluation from her supervisor.  The regional manager also began singling Plaintiff out for negative treatment: she was "curt and abrupt" with Plaintiff and gave her a disproportionate amount of work compared to other coworkers.  Later, Plaintiff's supervisor grabbed her arm and yelled at her, causing Plaintiff to suffer a panic attack and take another leave of absence.

Plaintiff thereafter requested, as a reasonable accommodation for her disability, a transfer to a different department so that she could work under a different supervisor and manager.  Plaintiff's physician repeatedly made clear to Defendant that Plaintiff would be able to function without limitation in a different department under a different manager.  Instead of providing Plaintiff with the transfer, Defendant opted to extend Plaintiff's leave of absence and eventually terminated her.

Plaintiff sued, alleging disability discrimination, among other things.  The trial court granted Defendant's motion for summary judgment on all claims, and the Court of Appeal affirmed, holding that Plaintiff did not suffer from a disability as defined by California Fair Employment and Housing Act: "[a]n 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 disability under FEHA."

It is important to note, however, that had the facts of this case been different and Plaintiff been subjected to behavior from her supervisor and manager beyond the "standard oversight" of her performance, she may have been entitled to her requested accommodation.  Therefore, if you are suffering from a stress related disability because of a supervisor, you should still contact an employment attorney to determine if you have a claim.

The opinion is available here.