A California Court recently ruled that an employee who was unable to work with a particular supervisor because of stress did not have a recognized disability under California law. However, under California law, in some situations, extreme anxiety at work may be considered a disability.
In this case, Higgins-Williams v. Sutter Medical Foundation, the Sutter Medical Foundation hired Michaelin Higgins-Williams to work as a clinical assistant in 2007. In 2010, Higgins-Williams told her doctor that working with her manager and the human resources department caused her stress. Her doctor diagnosed her as having adjustment disorder with anxiety. As a result of this diagnosis, her employer gave her a stress-related leave of absence. When she returned to work, she received a negative performance evaluation from her supervisor and the regional manager, the first she had received during her time with the company.
After the negative performance evaluation, interactions with her supervisor and regional manager caused her to have a panic attack. She decided to leave work and did not return. She later asked for a disability accommodation that included her transfer to a different department and a leave of absence. The employer granted the leave of absence, and extended it a couple of times. Finally, the employer told Higgins-Williams that it had to know by February 1 when she could return to work, or her employment would be terminated. On January 28, her doctor told her employer that Higgins-Williams was not medically cleared to return to work. The employer terminated her on February 1.
Higgins-Williams filed a complaint against Sutter Medical Foundation for disability discrimination and wrongful termination under both federal and state law. Sutter Medical Foundation filed to dismiss the lawsuit, claiming that Higgins-Williams did not allege a disability that was recognized by law.
The California Court of Appeals agreed with the employer, ruling that Higgins-Williams did not have a disability that was recognized under the Fair Employment and Housing Act. The Court of Appeals found that California and federal courts have ruled that an employee’s inability to work with a particular supervisor because of anxiety and stress that is related to the supervisor’s standard oversight of the employee’s job performance does not constitute a mental disability under the Fair Employment and Housing Act.
Furthermore, the Court found that Higgins-Williams’ claims for disability discrimination and wrongful termination failed for lack of factual support. The facts showed that almost all of Higgins-Williams’ interactions with her bosses that caused her anxiety was standard oversight of her job performance. The only non-standard oversight that she encountered occurred when she returned from her first leave of absence. One of her supervisors began being curt to her, but friendly to other employees. The supervisor also gave her a larger share of work and reportedly grabbed her arm and yelled at her.
The Court also ruled that Higgins-Williams’ testimony was confusing and incomplete given the facts.
Many jobs can be stressful, and working with particular bosses can also be very stressful. However, if the stress is related to normal oversight and performance evaluations, that alone is not sufficient to create stress that is considered a disability under the law. Other types of stress could be considered a disability that requires reasonable accommodation. If your supervisor displays abusive behavior, that could cause stress that is severe enough to require reasonable accommodation.
Disability discrimination cases are very fact-dependent, and if you believe you have been discriminated against in the workplace, you should consult with an attorney. Call Micha Star Liberty, Oakland disability discrimination attorney, at 510-645-1000 or 415-896-1000. She will provide you with a free consultation on your case.
