Higgins-Williams v. Sutter Medical: Employee's Inability to Work under Particular Supervisor Because of Stress Related to Standard Oversight Does Not Constitute Disability under FEHA

In Higgins-Williams v. Sutter Medical Foundation (5/26/15) --- Cal.App.4th ---, the plaintiff, Higgins-Williams, complained to her employer, Sutter, that she suffered stress from interactions with her supervisor and Sutter's HR department. Her physician diagnosed her with adjustment disorder with anxiety, placed her on intermittent leave, and stated that she could return to work without limitation if transferred to a different department. After several months of leave, Sutter advised Higgins-Williams that it would terminate her, unless she provided information as to (1) when she could return to work and (2) whether additional leave as an accommodation would effectuate her return to work. She did not supply the information, and Sutter terminated her.

Higgins-Williams sued, alleging disability discrimination, CFRA, and wrongful termination claims. The trial court granted Sutter's motion for summary judgment on all claims, and the Court of Appeal affirmed, holding as follows:

Higgins-Williams did not suffer from a disability as defined in the FEHA and could not prevail on her FEHA or wrongful termination claims. "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."

Higgins-Williams also could not prevail on her CFRA claims because she exhausted her available CFRA and FMLA leave, and Sutter granted her an additional five months of leave thereafter. Higgins-Williams's testimony that she didn't think she could have returned to work but would have tried failed to raise a genuine issue of material fact that Sutter failed to reinstate her following leave.

Finally, Higgins-Williams also could not prevail on her claim that Sutter wrongfully terminated her for asserting her CFRA rights. The evidence showed that Sutter had a legitimate business reason for terminating Higgins-Williams, and Higgins-Williams failed to raise a genuine issue of material fact as to whether that reason was pretextual.

The opinion is available here.