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Your Boss Stresses You Out & You Claim It Is a Disability? Might Want to Reconsider That Disability Discrimination Claim


Higgins-Williams v. Sutter Medical Foundation - California Court of Appeal, Third Appellate District


Facts:  Michaelin Higgins-Williams ("Higgins-Williams") worked as a clinical assistant in Sutter's Shared Services Department.  Higgins-Williams reported to her treating physician that she was stressed because of her interactions with human resources and her manager.  After her physician diagnosed her with "adjustment disorder with anxiety", Sutter granted Higgins-Williams a stress related leave of absence for about 30 days.  

After Higgins-Williams returned to work, she received a negative performance evaluation and had additional conflicts with her manager.  Not long after, Higgins-Williams submitted a disability accommodation request form and sought to transfer to a different department and obtain an additional leave of absence.  After additional leaves of absence that last almost a year, Sutter terminated Higgins-Williams.

Higgins-Williams subsequently filed suit against Sutter and alleged disability discrimination, wrongful termination and other related claims.  The trial court granted Sutter's motion for summary judgment.

Holding:  In considering Higgins-Williams' appeal, the Court of Appeal first looked to what disabilities were recognized in California's Fair Employment and Housing Act ("FEHA").  In this instance, Higgins-Williams alleged she suffered from an anxiety and stress induced disability as a result of her supervisor.  However, the Court was quick to rely upon prior caselaw which held that "an employee's inability to work under a particular supervisor because of anxiety and stress related to the supervisor's standard oversight of the employee's job performance does not constitute a disability under FEHA. 

Judgment:  The California Court of Appeal affirmed the trial court's grant of summary judgment in favor of Sutter on the grounds that Higgins-Williams was not disabled, as recognized under the Fair Employment and Housing Act, simply because of her inability to work under a particular supervisor because of anxiety and stress related to the supervisor's oversight of Higgins-Williams' work.

The Takeaway:  Employees, let this case be a reminder to you:  Just because your boss/supervisor stresses you out and causes you some anxiety does not mean you are necessarily disabled and have a valid disability discrimination claim if you are terminated.  I think it is safe to say that we have all had a boss at one point or another who caused us to lose sleep, get our blood pressure up, etc.  However, that alone does not necessarily mean a disability discrimination claim exists.  If that were the case, I think the courts would be even more overrun than they already are...

Majority Opinion Judge:  Judge Butz

Date:  May 26, 2015

Opinion:  https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0CCEQFjAAahUKEwi5uMC12oXHAhUQD5IKHQm8D5k&url=http%3A%2F%2Fwww.courts.ca.gov%2Fopinions%2Fdocuments%2FC073677.PDF&ei=H5e7VfmsDZCeyASJ-L7ICQ&usg=AFQjCNFgg87XaAnwK_6FFOBGa6vNhtb_lg&sig2=aF0lEtRr0eoMMxytcK9eOA&bvm=bv.99261572,d.aWw

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