On May 26, 2015, in the case of Higgins-Williams v. Sutter Medical Foundation, a California Court of Appeal held an employee’s “inability to work under a particular supervisor because of anxiety and stress related to the supervisor’s standard oversight of job performance” was not a protected disability under the Fair Employment and Housing Act (FEHA).
Facts of the Case
The Plaintiff in this case, Ms. Higgins-Williams (“Ms. Higgins”), worked as a clinical assistant for the Defendant, Sutter Medical Foundation (“Sutter”). As a result of her interactions with the Human Resources department and her manager at Sutter, Ms. Higgins was diagnosed with adjustment disorder and anxiety, defined by her doctor as simply “stress when dealing with her Human Resources and her manager.” Following this diagnosis, Ms. Higgins requested medical leave which she was given. After exhausting her medical leave, Ms. Higgins was not ready to return to work so Sutter gave her an additional five months of leave. Ms. Higgins’s employment was terminated when she failed to provide Sutter with requested information related to her continued leave including a possible date when she would be able to return to her position.
Ms. Higgins filed a lawsuit against Sutter alleging that it discriminated against her based on a disability (her anxiety) and failed to prevent such discrimination in violation of FEHA.
The Decision of the Court
In order to allege a case of mental disability discrimination under FEHA, three elements must be proven: (1) the employee suffers from a mental disability which is recognized by FEHA; (2) the employee is otherwise qualified to do the job with or without reasonable accommodation; and (3) the employee was subjected to adverse employment action because of the disability. Regarding the first element, the court held that “the inability to… work under a particular supervisor, does not constitute a qualified disability under FEHA.” Failing to prove the first element of her case, the court ruled in favor of Sutter.
A Note to Employers
Despite the favorable ruling of this case for employers, proper training of all employees on what an appropriate work environment looks like, and what forms of discipline are appropriate in the work environment, is essential. Additionally, an important element in favor of Sutter in this case was its willingness to work with Ms. Higgins and provide her with the appropriate leave when requested along with the employee’s failure to provide a reliable return to work date.