My Boss Drives Me Nuts! But Is That A Disability?

Managing interpersonal conflict in the workplace is always a delicate and time-consuming duty for managers and Human Resources personnel. But what happens when an employee claims that he or she suffers from a disability due to stress from working with a specific manager or supervisor? Must the employer accommodate the alleged disability by transferring the employee (or the supervisor!) to another role within the company? According to a recent opinion from the California Court of Appeals, Higgins-Williams v. Sutter Medical Foundation, 237 Cal. App. 4th 78 (3d Dist. 2015), the answer is No.

Michaelin Higgins-Williams was a clinical assistant at Sutter Medical Foundation. Initially hired in 2007, in June 2010 Higgins-Williams reported to her treating physician that she was experiencing stress because of interactions with her manager and with human resources. Her physician diagnosed her as having adjustment disorder with anxiety and Higgins-Williams was granted a stress-related disability leave of absence from work under the California Family Rights Act (CFRA) and the federal Family Medical Leave Act (FMLA). At the expiration of her entitlement to leave under each act, Higgins-Williams returned to work and received a negative performance review. Following this review, Higgins-Williams claimed that she was being singled out for negative treatment and, after a September 2010 encounter in which her supervisor grabbed her arm, Higgins-Williams had a panic attack, left work and did not return.

Following these events, Higgins-Williams requested a leave of absence, which her employer granted. After an additional leave of absence that extended into January 2011, her treating physician stated that she could not return to work until March 2011 and then only on light duty. Sutter Medical Foundation requested additional information from Higgins-Williams and informed her that if she did not comply with the request, her employment would be terminated on February 1, 2011. Higgins-Williams responded that she did not feel she could return to work on February 1 but that she would try to return on March 1 instead. Sutter terminated Higgins-Williams' employment as of February 1, 2011.

Higgins-Williams filed suit, claiming that Sutter violated the...