Many dramas and comedies, on both the small and big screens, have focused on the ups and downs of workplace life. In some situations, though, the conditions at a place of employment can go beyond just normal irritations and inconveniences. One employee, who suffered a stress condition because of her supervisors, sued her employer for discrimination when it terminated her instead of transferring her to a new department. The California Court of Appeal recently ruled that the employee did not have a valid Fair Employment and Housing Act case because her disorder did not amount to a recognized disability under the law.
In 2007, Michaelin Higgins-Williams started a job with Sutter Medical Foundation. In June 2010, Higgins-Williams’ doctor diagnosed her with adjustment disorder after the employee reported experiencing stress stemming from her interaction with Debbie Prince, her immediate supervisor, Norma Perry, a regional manager over both Prince and Higgins-Williams, and Sutter’s human resources department. As a result of that diagnosis, Sutter gave the employee five weeks of leave under the California Family Rights Act and the federal Family and Medical Leave Act.
The employee returned to work in August, but things did not improve. On Sept. 9, 2010, after a tense exchange with Perry, Higgins-Williams suffered a panic attack and left work, never returning. Sutter again placed the employee on leave, but, after several months, and with Higgins-Williams’ doctor only clearing her to return to work if the employer transferred her to a different department, the employer eventually terminated the woman.
Higgins-Williams sued her employer for violating the FEHA, but Sutter successfully persuaded the trial court to award it summary judgment. The employee appealed, but the appeals court also sided with the employer. The key problem with Higgins-Williams’ case, according to the appeals court, was that the employee did not have a condition that constituted a valid mental disability under FEHA.
When it comes to mental disabilities recognized by FEHA, the law has, for many years, been clear that the inability to work under one specific supervisor is not enough. The evidence in Higgins-Williams’ case, including her doctor’s communications with Sutter, made it clear that the diagnosis of disability in this case stemmed directly from the employee’s inability to deal with Perry and Prince’s “standard oversight” of the employee’s workplace performance.
The employee’s additional claims accusing Sutter of failing to make a good-faith effort to engage in an interactive process, retaliating against her for seeking a discrimination accommodation, and wrongfully terminating her also all failed. All of these claims require that the employee have a recognized disability. Since Higgins-Williams’ anxiety condition did not amount to a valid disability under the statute, these claims could not survive.
Employers have a statutory duty to accommodate employees with legally recognized disabilities. Before launching a disability discrimination lawsuit, it is important to understand the boundaries of the law and that your stress or anxiety condition may not necessarily amount to a disability under the statute. Consult the Oakland employment attorneys at the Law Offices of Stephen M. Fuerch. Our employment law attorneys have helped many people understand their rights and analyze their options. Contact us through our website or call our office at (925) 463-1073 to schedule your confidential initial consultation today.
More Blog Posts:
California Employers Not Required to Eliminate Essential Job Duties to Accommodate Employees With Disabilities, Oakland Personal Injury Attorney Blog, March 13,2015
California Disability Law Does Not Require Providing Employees With Indefinite Leave, Oakland Personal Injury Attorney Blog, Feb. 13,2015