California Court of Appeal Sides with Employers Regarding Stress-Related Disability

Employers are often confronted with the difficult question of how far they must go to accommodate disabilities which arise from work-related stress.  The answer?  Probably not as far as you might think.  In Higgins-Williams v. Sutter Medical Foundation, 237 Cal. App. 4th 78 (2015), the California Court of Appeal recently held that an employee's stress-related inability to work under her particular supervisors did not qualify as a disability under the California Fair Employment & Housing Act ("FEHA"). 

Plaintiff Higgins-Williams worked for Defendant Sutter Medical Foundation as a clinical assistant in Sutter's Shared Services Department, doing patient intake.  Throughout Higgins-Williams' employment, the Shared Services Department was overseen by Perry.  Higgins-Williams' direct supervisor was Prince, who reported to Perry.  In June 2010, Higgins-Williams reported to her physician that she was experiencing stress because of interactions at work with her manager and human resources.  Higgins-Williams' physician diagnosed her with an "adjustment disorder with anxiety," and Sutter granted her a stress-related leave of absence under the California Family Rights Act and the federal Family Medical Leave Act.  Higgins-Williams exhausted this leave on August 2, 2010, and returned to work the next day, August 3. 

On August 3, Prince gave Higgins-Williams a negative performance evaluation, a first for Higgins-Williams in multiple years of employment.  Around September 8, Perry began singling Higgins-Williams out for negative treatment, giving Higgins-Williams a disproportionate share of work and being curt and abrupt with her while being friendly to Higgins-Williams' co-workers.  On September 9, Prince inaccurately accused Higgins-Williams of being irresponsible in the care of her identification badge.  That same day, Perry grabbed Higgins-Williams' arm and yelled at her, prompting Higgins-Williams to have a panic attack and leave work, never to return. 

Higgins-Williams then requested that Sutter accommodate her alleged disability - adjustment disorder with anxiety - in the form of a transfer to a different department, an extended leave of absence, and a specific hourly schedule.  Sutter granted only the leave, and subsequently extended it for multiple months.  As the end of the leave approached, Sutter requested that Plaintiff provide more specific information as to when she could return to work.  Plaintiff was terminated when she failed to provide that information. 

Higgins-Williams filed suit in the Sacramento County Superior Court, alleging disability discrimination under FEHA, wrongful termination, and related claims.  The trial court granted summary judgment in favor of Sutter on all of Plaintiff's disability discrimination claims and her wrongful termination claim, finding that Higgins-Williams' stress did not qualify as a disability. 

 The Court of Appeal affirmed, premising its reasoning on a previous decision, Hobson v. Raychem Corp., 73 Cal. App. 4th 614, 628 (1999), which held that "the inability to perform one particular job, or to work under a particular supervisor, does not constitute a qualified disability" under FEHA.  Acknowledging that certain aspects[1] of Hobson had been disapproved or questioned by other cases, the Court nonetheless affirmed that Hobson's holding relevant to Higgins-Williams remains good law.  Specifically, "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." Higgins-Williams, at 85-86.  Given that the alleged disability underlying all of Higgins-Williams' disability discrimination claims was her inability to work under Perry and Prince due to stress related to their oversight of her performance, the Court affirmed summary judgment in favor of Sutter on those claims.  In so holding, the Court also appears to have implicitly found that the conduct of Perry and Prince amounted to "standard" oversight of Higgins-Williams' job performance. 

While the specific holding of Higgins-Williams is narrow, the Court struck an important balance between the legitimate interests of employers in maintaining a productive workplace, and the rights of employees who experience work-related stress as a result of unreasonable or discriminatory supervisorial oversight to be protected from disability discrimination.  This decision recognizes that normal workplace interactions between supervisors and supervisees naturally involve a degree of inherent conflict.  As in Higgins-Williams' case, those interactions sometimes result in stress which does not qualify as a disability, and thus may not trigger the employer's obligations under FEHA to engage in the interactive process with the employee, or to provide a reasonable accommodation.  On the other hand, those employees who experience work-related stress as a result of discriminatory or unreasonable oversight from their supervisors would potentially remain covered by FEHA's disability discrimination provisions.  We anticipate that subsequent decisions by the Court of Appeal will further define the circumstances under which work-related stress gives rise to a qualifying disability under FEHA, and will provide updates as this issue develops. 

This article is presented for informational purposes only and is not intended to constitute legal advice.