A California appeals court ruled May 26 that stress and anxiety caused by a particular supervisor does not entitle an individual to protection under disability discrimination law, even under California’s uniquely broad framework.
“The plaintiff employee’s alleged disability – an inability to work under a particular supervisor because of anxiety and stress related to the supervisor’s standard oversight of job performance – is not a disability recognized in California’s Fair Employment and Housing Act,” the court wrote in the 13-page decision [PDF].
Michaelin Higgins-Williams worked at Sutter Medical Foundation from 2007 to 2011. In the summer of 2010, she took leave pursuant to the Family Medical Leave Act. Upon returning to work, her supervisor gave her a negative performance evaluation and allegedly increasingly singled-out Higgins-Williams for criticism.
She applied for a reasonable accommodation under the CFRA, to be moved to a different department. Eventually her employment was terminated in February 2011.
Higgins-Williams proceeded to file a lawsuit against the Sutton Medical Foundation under the CFRA.
The Superior Court of Sacramento County ruled in favor of Sutter on all counts. The Court of Appeal of the State of California for the Third Appellate Court agreed, preventing the case from moving forward to a jury.
Under the Americans with Disabilities Act, a person has a disability if he or she has a “physically or mental impairment that substantially limits one or more of an individual’s major life activities.”
Under California’s relaxed standard, the phrase “substantially limited” is replaced with “limited,” thus expanding its applicability.