Stressed Out By Your Supervisor? Too Bad, Say California Courts

California employers may finally rejoice: there is now an employer-friendly state court decision, Higgins-Williams v. Sutter Med. Found., 237 Cal. App. 4th 78 (2015). The case takeaway is straightforward: 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).

Case Summary

The case involved a clinical assistant who worked in a company's shared services department. She provided the company with a report from her physician that indicated she was suffering from "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. In response, that company granted her a 30-day, stress-related leave of absence. But after she returned to work, she received her first negative performance evaluation. She also asserted experiencing additional conflicts with her manager, who allegedly was "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. Instead, she submitted a disability accommodation request for a transfer to a different department (for "forever") 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, the company terminated her employment, and she filed suit.

Her suit alleged disability discrimination under FEHA, violation of the California Family Rights Act (CFRA), wrongful termination, and related claims. The...