A California appellate court recently held that an employee diagnosed with an adjustment disorder triggered by stress caused by her supervisor’s standard oversight of her job performance is not disabled under the California Fair Employment and Housing Act (“FEHA”). Higgins-Williams v. Sutter Medical Foundation, 2015 Cal.App.LEXIS 455 (May 26, 2015). In so doing, the court bucked the current trend of expanding protection of employees unable to work due to medical conditions.
Employed as a clinical assistant, Michaelin Higgins-Williams reported to her personal (non-work) treating physician that she was stressed because of interactions at work with human resources and her manager. In leave paperwork submitted to her employer, her physician reported her condition as “stress when dealing with her Human Resources and her manager.” After one of her leave requests was denied and she was instead terminated, she sued for disability discrimination and failure to accommodate her disability in violation of the FEHA.
The court affirmed summary judgment for her employer on the ground she was not disabled as a matter of law. The court noted a previous case had held a mental condition that prevented an employee from working under a particular supervisor or performing one particular job did not constitute a disability under FEHA: Hobson v. Raychem Corp., 73 Cal.App.4th 614 (1999). Hobson applied the now-discarded standard that a medical condition must substantially limit a major life activity to qualify as a disability; the current standard under the FEHA is that a medical condition need only limit a major life activity, whether or not that limitation is substantial. However, the court held Hobson remains good law on the point that inability to work under a specific supervisor because of anxiety and stress related to the supervisor’s standard job performance oversight does not constitute a mental disability under FEHA. Moreover, the court held the supervisor engaged in standard oversight as a matter of law, even though the supervisor allegedly singled Higgins-Williams out for negative treatment and on one occasion grabbed her arm and yelled at her.
Ordinarily a physical or mental condition that limits an employee’s ability to work will be deemed a disability requiring reasonable accommodation, and accordingly employers will generally want to accommodate employees with such conditions where possible. However, this case places a welcome common-sense boundary around employee disability claims: an employee cannot claim she is disabled because her supervisor stresses her out.